2010 CRWD SWPPP Annual Report

C Capittol Regio R on Wate W ersh hed D District 1410 En nergy Park D Dr., Suite 4, S St. Paul, MN 55108 Phonee: (651) 644-8 8888 Fax: (6651) 644-88994 www.cap pitolregionwd d.org

CRW WD Storm S mwatter Po ollution Prev vention P Progrram

201 10 An nnual Repo ort

Jun ne 20, 2011 1

“Our mission is to pro otect, manage, and improve th he water resouurces of the Cap apitol Region W Watershed Disttrict.”

Table of Contents Page Acronyms and Glossary

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1.0

Introduction

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2.0

Summary of Stormwater Pollution Prevention Program

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3.0

2010 SWPPP Activities

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4.0

Anticipated Stormwater Activities in 2011

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5.0

SWPPP Modifications

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6.0

References

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Appendices Appendix A Completed 2010 MPCA Annual Report Form Appendix B East Kittsondale Illicit Discharge Letter

Tables Table 1

Best Management Practices for Each Minimum Control Measure

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Table 2

2010 WaterShed Partners Media Campaign

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Figures Figure 1

Capitol Region Watershed District Map

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ACRONYMS BMPs CAC CIP CRWD CWA EPA MPCA MS4 NPDES O&M PSA SWPPP TBI TMDLs WSP

Best Management Practices Citizen’s Advisory Committee Capital Improvement Program Capitol Region Watershed District Clean Water Act Environmental Protection Agency (U.S.) Minnesota Pollution Control Agency Municipal Separate Storm Sewer System National Pollutant Discharge Elimination System Operation and Maintenance Public Service Announcement Stormwater Pollution Prevention Program Trout Brook Storm Sewer Interceptor Total Maximum Daily Loads Watershed Partners

GLOSSARY Term Arlington Pascal Stormwater Improvement Project

Bacteria

Best Management Practices (BMPs)

Clean Water Act

Green infrastructure

Definition Major Capital Improvement Project undertaken by the District in conjunction with the City of St. Paul. Project includes Como Golf Course Pond, Arlington Underground Storage, infiltration trenches and rain gardens.

Microorganisms that can live in a variety of conditions, some types can cause illness in humans. The quantity of E. coli, a specific type of bacteria, is used as a metric to evaluate potential fecal contamination in surface water resources.

Methods used to control the speed and total amount of stormwater that flows off a site after a rainstorm and used to improve the quality of the runoff water. Can also refer to practices for control of sediment and erosion.

Passed in 1972, the Clean Water Act is a U.S. federal law that regulates the discharge of pollutants into the nation's surface waters, including lakes, rivers, streams, wetlands, and coastal areas.

A stormwater management approach that utilizes natural landscape features and hydrologic processes to treat stormwater by infiltration, evapotranspiration, and/or reuse of runoff. Green infrastructure also achieves other environmental goals such as carbon sequestration, reductions in urban heat island effect, improved air quality, improved wildlife habitat and increased opportunities for outdoor recreation. Adapted from US EPA

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Term Illicit discharges

Impervious surfaces

Infiltration

Macroinvertebrates

Phase II Stormwater Rule

Stormwater BMPs

Stormwater infrastructure Stormwater/Runoff Subwatershed

Total Maximum Daily Loads (TMDLs)

Trout Brook Storm Sewer interceptor

Water Quality

Definition Any contribution to the storm sewer system that isn't stormwater (i.e. illegal connections to the storm sewer, dumping of materials in the storm sewer).

Surfaces that severely restrict the movement of water through the surface of the earth and into the soil below.

Impervious surface typically refers to manmade surfaces such as non-porous asphalt or concrete roadways, buildings, and heavily compacted soils.

The movement of water into the soil.

Aquatic insects used as a metric of water quality. Different macroinvertebrates will live in water with poor water quality than live in water with high water quality, thus the different types of macroinvertebrates present are an indication of the quality of the water.

Promulgated in 2000 by US EPA, Phase II Stormwater Program requires small, urbanized MS4s to develop and implement a program of activities, practices, and projects that controls polluted stormwater runoff and improves water quality.

Non-structural and structural methods used to control the speed and total amount of stormwater that flows off a site after a rainstorm and used to improve the quality of the runoff water.

Methods used to control the speed and total amount of stormwater that flows off a site after a rainstorm and used to improve the quality of the runoff water.

The water that flows off a site after a rainstorm.

A smaller geographic section of a larger watershed unit with a drainage area of typically between 2 and 15 square miles and whose boundaries include all the land area draining to a specified point.

The total amount of a pollutant or nutrient that a water body can receive and still meet state water quality standards.

TMDL also refers to the process of allocating pollutant loadings among point and nonpoint sources.

Major storm sewer pipe carrying flows through the eastern portion of the District. The District took over ownership from the Met Council which previously owned the pipe when it carried combined storm and sanitary flows.

Water quality is a term used to describe the chemical, physical, and biological characteristics of water, usually in respect to its suitability for a particular use. In the case of surface waters, uses are typically swimming and fishing.

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1.0

INTRODUCTION

Capitol Region Watershed District (CRWD) is a special purpose unit of government established in 1998 to manage, protect and improve the water resources of the Capitol Region Watershed District in the Twin Cities metropolitan area of Minnesota. CRWD drains an area of 41 square miles from a large portion of the City of Saint Paul and smaller portions of the Cities of Roseville, Falcon Heights, Maplewood, and Lauderdale. A major responsibility of CRWD is to own, operate and maintain the Trout Brook Storm Sewer Interceptor System, a trunk conveyance stormwater system that collects and conveys runoff from the cities of Saint Paul, Roseville, Falcon Heights, and Maplewood (Figure 1). The Trout Brook subwatershed drains nearly 8,000 acres, including the subwatersheds of Como Lake in Saint Paul and Lake McCarrons in Roseville, making it the largest subwatershed in CRWD. Land use in the subwatershed is highly urbanized with 42% imperviousness and a mix of residential, industrial, and commercial uses. The Trout Brook storm sewer interceptor is almost six miles in length and varies in size from a five-foot diameter round, reinforced concrete pipe to over 11-foot cast-in-place box sections. The interceptor receives stormwater runoff from municipally-owned lateral pipes and conveys it to the City of Saint Paul’s trunk storm sewer before eventually discharging to the Mississippi River.

CRWD is considered a regulated non-traditional operator of a small municipal separate stormwater sewer system (MS4) and is required to obtain a 5-year general stormwater discharge permit under Phase II of the National Pollutant Discharge Elimination System (NPDES) stormwater program of the federal Clean Water Act. The Phase II Rule requires MS4 operators to develop and implement an enforceable stormwater pollution prevention program (SWPPP) that will reduce the discharge of pollutants from their MS4 to the ‘maximum extent practicable’ to protect water quality, and to satisfy the appropriate water quality requirements of the Clean Water Act (US EPA, 2000).

In August 2006, CRWD submitted to the Minnesota Pollution Control Agency (MPCA) a permit application and the SWPPP, which outlines CRWD’s best management practices (BMPs) to control and reduce stormwater pollution. Two years later in November 2008, MPCA determined that the CRWD SWPPP is adequate and issued CRWD a 5-year MS4 General Permit under the NPDES program.

As part of the SWPPP, CRWD is required to prepare and submit an annual report of progress made-to-date on implementing the BMPs and meeting the measurable goals of the SWPPP and of any proposed revisions. Although CRWD is only legally required to develop and implement its SWPPP in the Trout Brook subwatershed, CRWD applies all of its SWPPP minimum control measures throughout the watershed district.

This report summarizes the stormwater management work conducted for the Trout Brook storm sewer system as well as the entire watershed district in 2010. This is the fourth annual SWPPP report prepared by CRWD.

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Figure 1. Capitol Region R Wa atershed District

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STORMWATER POLLUTION PREVENTION PLAN

As part of the Trout Brook Storm Sewer Interceptor System NPDES discharge permit, CRWD has prepared and is implementing the SWPPP to control and reduce the discharge of stormwater-related pollutants from the MS4 to protect water quality of the Mississippi River. The SWPPP consists of a combination of six minimum control measures: 1) public education and outreach; 2) public participation and involvement; 3) illicit discharge detection and elimination; 4) construction site stormwater runoff control; 5) post-construction runoff control; and 6) pollution prevention and good housekeeping. Based on consideration of the sources of pollutants, the potentially polluting activities in the watershed and the sensitivity of the receiving waters, CRWD has selected the best management practices for each minimum control measure to accomplish federal and state regulatory requirements and CRWD water quality goals.

CRWD provides BMP summary worksheets that include practice descriptions, the measurable goals, the implementation schedule and procedures, and the responsible staff person for implementation. Table 1 lists the required BMPs for each minimum control measure.

CRWD refers to several supporting documents for carrying out the SWPPP which includes the Watershed Management Plan (CRWD, 2010), CRWD Rules (CRWD, 2009), and BMP Inspection and Maintenance Protocols (CRWD, 2009). The 10-year Watershed Management Plan, adopted by CRWD’s Board of Managers in 2010, defines the watershed goals and policies of CRWD, describes the current watershed issues, provides an inventory of the land and water resources, and defines the activities and measures to protect and restore the watershed. In the fall of 2006, CRWD promulgated rules to minimize the water quality, erosion, sedimentation and flooding impacts of development and redevelopment on local waters. The latest revision to CRWD Rules was made and approved by CRWD Board of Managers in January 2009. CRWD’s BMP Inspection and Maintenance Protocols outline the procedures and maintenance schedules for BMPs owned or under agreement for maintenance by CRWD. 3.0

2010 SWPPP ACTIVITIES

Below is a narrative description of the stormwater management accomplishments in 2010. Appendix A includes the completed MPCA Annual Report Form for 2010, which summarizes CRWD’s stormwater-related activities and accomplishments with particular emphasis on Minimum Control Measure No. 3, Illicit Discharge Detection and Elimination Stormwater Measures.

3.1

Public Education and Outreach – Minimum Control Measure No. 1

In 2010, CRWD implemented a variety of watershed education and outreach activities that focus on local stormwater issues and on public behaviors and activities to address these issues. CRWD raises awareness about the watershed and environmentally sensitive behaviors and activities through presentations to students and residents,

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Table 1. Best Management Practices for Each Minimum Control Measure BMP ID

Best Management Practices for Each Minimum Control Measure

MCM #1: Public Education & Outreach Distribute Educational Materials Implement an Education Program Education Program: Public Education and Outreach - District Website Education Program: Public Education and Outreach – Como Water Festival Education Program: Public Education and Outreach – WaterShed Partners Education Program: Public Education and Outreach – Media Communication Education Program: Public Participation Education Program: Illicit Discharge Detection and Elimination Education Program: Construction Site Runoff Control Education Program: Post Construction Stormwater Management Education Program: Pollution Prevention/Good Housekeeping Coordination of Education Program Annual Public Meeting MCM #2: Public Participation/Involvement 2a-1 Comply with Public Notice Requirements 2b-1 Solicit Public Input and opinion on SWPPP 2c-1 Consider Pubic Input MCM #3: Illicit Discharge Detection and Elimination 3a-1 Storm Sewer System Map 3b-1 Regulatory Control Program 3c-1 Illicit Discharge Detection and Elimination Plan 3d-1 Public and Employee Illicit Discharge Information Program 3e-1 Identification of Non-Stormwater Discharges and Flows MCM #4: Construction Site Stormwater Runoff Control 4a-1 Ordinance or other Regulatory Mechanism 4b-1 Construction Site Implementation of Erosion and Sediment Control 4c-1 Waste Controls for Construction Site Operators 4d-1 Procedure for Site Plan Review 4e-1 Procedure for Receipt of Reports of Stormwater Non-compliance 4f-1 Procedures for Site Inspection and Enforcement MCM #5: Post Construction Stormwater Management for New Development/Redevelopment 5a-1 Development and Implementation of Structural and/or Non-structural BMPs 5b-1 Regulatory Mechanism to Address Post Construction Runoff for Development 5c-1 Long-term Operation and Maintenance of BMPs MCM #6: Pollution Prevention/Good Housekeeping for Municipal Operations 6a-1 Municipal Operations and Maintenance Program 6b-2 Annual Inspection of All Structural Pollution Control Devices 6b-3 Inspection of MS4 Outfalls, Sediment Basins, and Ponds 6b-4 Inspection Follow-up 6b-5 Record Reporting and Retention of Inspections and Responses to Inspections 6b-6 Evaluation of Inspection Frequency

1a-1 1b-1 1c-1.1 1c-1.2 1c-1.3 1c-1.4 1c-2 1c-3 1c-4 1c-5 1c-6 1d-1 1e-1

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CRWD newsletters, press releases to local newspapers and supportive partnerships with Saint Paul district planning councils and community organizations. CRWD also provides technical assistance through our Stewardship and Partner Grant Programs for water quality improvement projects and when possible through environmental learning service projects in area schools.

2010 Outreach In 2010, CRWD developed and implemented a new public outreach program, known as “Stop the Rain Drain,” to encourage and facilitate activities and practices that reduce runoff from residential properties. The primary goal of the program is to get as many downspouts draining to lawns or garden areas instead of hard surfaces. CRWD provided funds for downspout redirection and gutter and rain barrel installation to 33 households in 2010.

CRWD held or sponsored 10 rain garden, native plant, or rain barrel workshops in 2010 for the Saint Paul District Planning Councils (D4, D6, D12, D13 and D16) and others. CRWD also participated in several environmental related events including the Roseville Home and Garden Fair, the East Side Neighborhood Development Fair, the Living Green Expo, the Friends of Parks and Trails in Saint Paul Anniversary Event. In addition, 40 people attended a walking tour of CRWD’s rain gardens in the Como neighborhood of Saint Paul.

CRWD also sponsored and participated in several events within Como Lake and its subwatershed. With funding from CRWD, the Como Lake Neighborhood Network conducted a curbside cleanup in a Como Lake neighborhood in April. To minimize nutrient loading to Como Lake, twenty-five volunteers collected leaves and organic debris from their sidewalks and streets. CRWD also held the annual summer, “Bugs Night Out” event, which educates young students about ecology and water quality.

CRWD completed its 10-year Watershed Management Plan in 2010. The 2010 plan incorporates input from stakeholders and the general public on the programs, projects and activities of CRWD that will minimize stormwater pollution and protect and restore water quality of CRWD lakes, wetlands and ponds and the Mississippi River.

CRWD staff served on the planning committee and was an endorsing sponsor for a Green Infrastructure for Clean Water conference held last fall at the Minnesota Landscape Arboretum. The intent of the conference was to raise the awareness of green infrastructure as a sustainable, cost-effective, and environmentally-friendly approach to managing stormwater. Keynote speakers for the event were Andrew Reese, nationally recognized expert on stormwater at AMEC Earth and Environmental, and Jim Patchett, Founder of Conservation Research Institute/Conservation Design Forum. CRWD invited municipal officials and employees to the conference. Six municipal representatives accepted CRWD’s invitation and attended the conference.

Other mechanisms for disseminating information about stormwater, water quality improvement projects and CRWD’s stewardship grant program were print media, such

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as newsletters, press releases about CRWD events and programs, and newspaper articles, and digital media.

CRWD also hosts and maintains a website, www.capitolregionwd.org, which was redesigned in 2009. Besides the existing information about the watershed, stormwater quality data, stormwater funding opportunities, and CRWD’s Permitting Program, the new website also includes additional information about Trout Brook Storm Sewer Interceptor System and a Stormwater 101 page that provides basic information about the natural and man-made water cycles and the pollutants found in stormwater. Also to be found on the new site is tips on how different audiences (i.e., homeowners, businesses, developers and students) can reduce their impact on local water resources.

Municipal Education/Training In partnership with the University of Minnesota Extension Services, CRWD sponsored two stormwater-related trainings for municipal staff in CRWD. In February 2010, CRWD held a construction erosion and sediment control training for the City of Saint Paul Regional Water Services. Twelve City employees attended the training. Later in the summer, CRWD held an illicit discharge detection and elimination training with over 50 municipal employees from various departments, including public works, parks and recreation, fire and police, attended the training.

2010 WaterShed Partners Participation CRWD also regularly attends monthly meetings of the Metro WaterShed Partners (WSP), a coalition of more than 50 public, private and non-profit organizations in the Twin Cities metro area. The Partners collaborate on outreach projects and share resources with the goal of inspiring people to act within their watershed. The WSP website, www.cleanwatermn.org, is a source for public stormwater pollution prevention education materials and products for stormwater educators, students, municipal and watershed organization staff.

WaterShed Partners Media Campaign Staff also participated in quarterly meetings of the WSP subcommittee, Minnesota Water — Let’s Keep It Clean! media campaign. Since 2007, the collaborative has launched an annual media campaign that has included radio and cable television service announcement spots aimed at educating the public about polluted runoff prevention. Billboards throughout the metro area including have been used to raise awareness about water pollution prevention. Table 2 lists the 2010 WSP media activities.

2010 Blue Thumb™ Participation Staff also participated in quarterly meetings of the Blue Thumb™ Partnership, a program that promotes the use of native plants to watershed residents as an alternative to turf in raingardens, native plant gardens, and shoreline restoration projects. Blue Thumb™ Partners created a website of gardening resources for use by residents, and share print materials for distribution to local residents. Partners also benefit from the shared technical assistance of partners, and the opportunity to cultivate a consistent message when communicating with watershed residents. In

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2010, CRWD contributed 38 hours of citizen outreach on behalf of Blue Thumb including attendance at the Living Green Expo in May and MN State Fair Eco Experience in August.

Table 2. 2010 WSP Media Campaign Media Type/Channel Channel 45, KSTC TV PSAs

Number of Ads

Message

Impressions

- 165 30-sec PSAs in May - 50 30-sec PSAs in August

“Rubber Ducks” and “Fish bowl” ads to keep stormwater clean – rake, sweep and pick up Message of “Clean streets mean clean water.”

“Rubber Ducks” and “Fish Bowl” ads to keep stormwater clean – rake, sweep and pick up Fertilizer use, dog waste pickup and car washing

537,500

MPR

- Streaming PSAs in June

Comcast Cable

- 151 30-sec PSAs plus 2,540 bonus spots in Fall

Billboards

- 12 metro billboards – one in CRWD

Saint Paul Saints Baseball

- 96 30-sec PSAs during baseball season

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50,000

886,000

6,638,800

1,152,000

Public Involvement and Participation

CRWD established a citizen’s advisory committee (CAC) in 1998 to advise and assist the Capitol Region Watershed District Board of Managers with: • • • •

CRWD organizational development, planning processes, and program implementation; CRWD communications between the citizenry and the Board of Managers; consensus building and conflict resolution; and additional roles as jointly determined by the CAC and the Board of Managers.

CAC meetings are held on a monthly basis and open to the public. CRWD provides program and project updates to CAC members and solicits their input on CRWD activities including stormwater management projects and CRWD rules and permitting.

Currently there are 15 CAC members.

Public input on CRWD’s SWPPP was solicited in late spring 2011. A 30-day public comment period on the SWPPP and CRWD’s 2010 stormwater management activities

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was held from May 23, 2011 to June 21, 2011. In addition, a public meeting was held in junction with the Board of Manager’s meeting on June 15, 2011. CRWD provided advanced notice of the public meeting on our website, www.capitolregionwd.org and in the Saint Paul Pioneer Press.

3.3

Illicit Discharge Detection and Elimination

MPCA’s 2010 Annual Report highlights Minimum Control Measure #3, the Illicit Discharge Detection and Elimination Stormwater Measure. The MS4 Permit requires the development and implementation of an ordinance or other regulatory mechanism to effectively prohibit non-stormwater discharges into the storm sewer system, along with appropriate enforcement procedures and actions, by June 30, 2010. CRWD developed and promulgated a set of Rules in 2006 for its Permitting Program that regulates illicit discharges and connections (CRWD, 2006). Under Rule G, illicit connections and discharges to CRWD’s MS4 are prohibited and any new direct connections are not allowed if the connection will cause or exacerbate water conveyance problems in the system. The rule also outlines the inspection and enforcement protocols for illicit discharges.

Trout Brook Subwatershed A potential illicit discharge was identified in the Trout Brook subwatershed in 2010. In May 2010, CRWD monitoring staff observed a white, turbid flow at the TBI West Branch monitoring station. The odor from TBI was not unusual. This type of discharge was not observed again in TBI. The public can report possible illegal stormwater discharges or improper dumping into storm drains or a waterbody on CRWD’s website or via email or phone. In 2010, no illegal stormwater discharges were reported by the public in TBI or other locations.

East Kittsondale Subwatershed Over the past several years, CRWD’s stormwater monitoring data has indicated that there was an illicit discharge issue in the East Kittsondale storm sewer, which is outside of CRWD’s regulated Trout Brook subwatershed. In 2009 and 2010, CRWD conducted extensive monitoring of East Kittsondale to better understand the extent and magnitude of the bacteria issues and identify the potential source(s) of the bacteria, which included collection of more bacteria samples and other IDDE parameters to distinguish between discharge types. During dry weather from January to mid-May 2010, bacteria levels in TBI greatly exceeded the State Maximum Surface Water Quality Standard for bacteria of 1,260 cfu/100mL and in some instances, concentrations were greater than 100,000 colony forming units per 100 milliliters.

CRWD also analyzed samples for other IDDE parameters to help distinguish between four major discharge types: sanitary wastewater, washwater, natural water, and tap and/or irrigation water. The four IDDE parameters included ammonia, potassium, fluoride and surfactants. Ammonia and potassium in high levels may indicate the presence of sanitary wastewater. A ratio of ammonia and potassium greater than 1.0 likely indicates sanitary wastewater in the discharge. Fluoride levels greater than 0.25 mg/L likely indicate potable water source in areas where water supplies are

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fluoridated. Surfactants are the main components of commercial detergents that detach dirt from clothing. Concentrations greater than 0.25 mg/L likely indicate washwater contamination.

The results of these four IDDE parameters were varied with no strong, evident conclusions to differentiate the types of discharge. Out of the 26 samples analyzed for both ammonia and potassium, none of them had an ammonia/potassium ratio greater than 1.0. Nearly 80% of the fluoride samples exceeded the benchmark level of 0.25 mg/L indicating that these samples may have had significant tap water. Half of the surfactant samples, which exceeded the benchmark level of 0.25 mg/L, were indicative of possible washwater contamination.

Daily flows in East Kittsondale provide another source of evidence of illicit discharges into the storm sewer. During periods of baseflow when no appreciable rain fell within 72 hours of sampling or after the previous storm’s hydrograph fell, daily flows would surge and on some occasions, double in volume. The most notable month of daily surges in flow occurred on September 2009 with nine likely illicit discharges. Several of these surges were fairly significant in volume. On September 2nd, 18th, and 23rd, volumes were greater than 500,000 cubic feet. Several hydrographs from September 2009 are enclosed for your review.

Since Spring 2008, CRWD staff have observed white, fuzzy masses attached to the bottom of the storm sewer in East Kittsondale. In November 2008, photos of the white growth were sent to a bacteriologist at the University of Minnesota who with 75% certainty believes that it is some type of sewer bacteria. In March 2009, CRWD submitted a sample of the white growth to Metropolitan Council’s (Met Council) Environmental Services Laboratory for microscopic examination.

Met Council identified an abundance of fungus in the flock with lesser amounts of filamentous bacteria and natural fibers.

In April 2010, CRWD provided a detailed technical memo to the City of Saint Paul outlining the evidence that points to an illicit discharge in East Kittsondale including water quality and flow data and photographs of sewer fungus. The City conducted a thorough investigation to pinpoint the source of pollution and eliminate the illicit connection. By early June 2010, the illicit connection was eliminated and water quality in East Kittsondale improved during dry weather. See Appendix B for the letter to the City of Saint Paul about the East Kittsondale illicit discharge.

3.3

Construction Site Stormwater Runoff Control

CRWD Rules have provisions for the control of erosion and sediment from any land disturbing activity equal to or greater than one acre. Developers are required to develop an erosion and sediment control plan for the construction period as part of their permit application. Erosion and sediment control measures shall be consistent with best management practices, and shall be sufficient to retain sediment onsite as demonstrated in the MPCA manual, “Protecting Water Quality in Urban Areas” (MPCA,

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2000). The measures must meet the design, operation and maintenance standards outlined in the NPDES general permit for stormwater discharges from construction activities (US EPA, 2005). CRWD Erosion and Sediment Control Rule F also includes a provision for disposal of construction site waste.

CRWD has developed and initiated a permit review process for site plans of new developments and redevelopments projects that meet CRWD’s size threshold of one acre of disturbance. The permit process flow chart outlines the steps for reviewing the permit application as well as lists who is involved, the timeline and deliverables. In 2010, 33 development projects equal to or greater than one acre were reviewed for compliance with CRWD’s erosion and sedimentation control rule. Development sites were inspected by CRWD staff on a regular basis, typically twice a month and after a rain event, during the duration of construction. CRWD placed higher inspection priority on the development projects with greater potential of off-site sediment runoff and/or poor compliance history. CRWD completed inspection reports or checklists of the erosion and sediment control measures implemented, such as inlet protection, stabilized entrance measures, and dewatering activities.

This rule also has enforcement mechanisms to ensure compliance, which include verbal warnings, written warnings, stop-work orders, forfeiture of security bond money and court injunction to stop work. In 2010, CRWD issued over 50 written warnings of violations to the erosion and sediment control rule with the most common problems being lack of street sweeping and inlet protection. No other enforcement actions were needed to ensure compliance in 2010. In addition, no outside reports of erosion and sedimentation issues were made to CRWD in 2010. A complaint can be brought to the attention of CRWD through our website, via email or by calling.

3.5

Post-Construction Stormwater Management

The requirements for post-construction stormwater management on new development and redevelopment sites equal to or greater than one acre are covered in CRWD’s Rules (Rule C). Through the permitting process, CRWD encourages developers and property owners to select, design and implement innovative BMPs on their properties.

These innovative BMPs filter and/or infiltrate stormwater runoff and mimic the natural water cycle by soaking water into the ground. They reduce stormwater volume and peak discharges, are more effective in removing pollutants, increase groundwater recharge, and aid in reducing flooding and erosion and sedimentation. CRWD requires permittees to reduce the stormwater volume generated from the first one-inch of rainfall because research indicates that this will address 90% of all precipitation events and about 87% of all rainfall volume in Minnesota.

Information on BMPs installed and volume of stormwater treated and/or retained by each BMP are entered into the permits database. In 2010, 33 (re)development projects greater than one acre applied for a CRWD permit. The total area disturbed by these projects was over 350 acres. The most common BMPs constructed were filtration basins, underground infiltration systems, and infiltration basins/rain gardens.

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There were two pervious pavement projects and no green roof projects. These BMPs will control runoff from over 190 acres of impervious area and treat a total of nearly 608,000 cubic feet out of 651,000 cubic feet of stormwater runoff. Three projects (62,000 cubic feet) have deferred meeting the stormwater volume treated on-site.

Seventy percent of the treated stormwater will be infiltrated into the ground while 30% will be filtered before discharging into the storm sewer system.

CRWD’s website provides information on innovative stormwater BMPs including a fact sheet on how to build a rain barrel, instructions on how to obtain the Blue Thumb Raingarden Guidebook, a link to the stormwater BMP section of the Minnesota Stormwater Manual (MPCA, 2005) and a fact sheet on permeable pavement. Also uploaded onto the website is information about CRWD’s Arlington-Pascal Stormwater Improvement Project, which includes an underground storage/infiltration facility, eight infiltration trenches, eight raingardens, and the Como Park golf course stormwater pond. These BMPs are located in the Como Lake subwatershed, which drains to Trout Brook storm sewer system. CRWD has established a BMP operation and maintenance program for these BMPs as well as the Villa Park wetland system in Roseville and the Sarita wetland and Sheep Pasture infiltration basin both located on the University of Minnesota-Saint Paul campus.

3.6

Pollution Prevention/Good Housekeeping for Municipal Operations

To ensure that BMPs operate according to design and achieve the highest level of pollutant removal, CRWD follows BMP operation and maintenance protocols that define the instructions and schedule for inspection and maintenance of the BMPs owned by CRWD or under agreement to be maintained by CRWD (CRWD, 2009).

The eight raingardens, Villa Park wetland, and Como Park golf course stormwater pond are inspected and maintained on monthly basis while the eight underground infiltration trenches and an underground storage facility are inspected semi-annually.

In addition, all BMPs including Sarita wetland and Sheep Pasture infiltration basin are inspected after a rainfall event equal to or greater than one inch. The inlets, catch basins and manholes to these BMPs are inspected and maintained semi-annually to ensure successful and effective operation. CRWD has created an EXCEL database for BMPs that lists the type of BMP, the date, time and number of hours of the inspection and/or maintenance activity, the staff involved in the activity, and description of maintenance performed.

CRWD staff spent a grand total of nearly 400 hours maintaining the Arlington Pascal Stormwater BMPs in 2010. Maintenance activities included: • •

Sediment inspections documenting debris accumulation within the pretreatment chamber of the underground storage facility and within the underground storage facility; Sediment inspections of sumped manholes and catch basins draining to the infiltration trenches;

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• •

Routine inspections and maintenance of the eight rain gardens included removal of weeds and debris and placement of additional mulch material; and Inspections and maintenance of the inlet and outlet flow control structures and debris removal after storm events from the stormwater pond perimeter.

CRWD staff spent 121 hours maintaining rain gardens in 2010. On average, 15 hours were spent maintaining each rain garden. Volunteers spent an additional 19 hours maintaining rain gardens and City of St. Paul Parks and Recreation staff spent 104 hours maintaining the large rain garden at Hamline Avenue and Midway Parkway. In addition to assistance with maintenance of the large rain garden, City of St. Paul staff also spent an additional 90 hours assisting with debris removal from the perimeter of the stormwater pond.

4.0

ANTICIPATED KEY ACTIVITIES FOR 2011

For CRWD’s Education and Outreach Program in 2011, CRWD will continue its “Stop the Rain Drain” Program and expand it watershed-wide with the goal of serving as many as 90 homeowners. Besides redirecting downspouts to lawns or garden areas, CRWD will have contractors strongly encourage homeowners to install rain barrels.

CRWD will promote the program using media inserts in non-daily newspapers and through the Saint Paul District Planning Councils.

Based on the success of municipal trainings, CRWD will host additional stormwaterrelated trainings for municipal and private entities as the needs are identified. A training workshop on turf grass maintenance was held in March 2011. CRWD will also promote more leaf and lawn clipping cleanups in streets in 2011. This program has been developed by the Freshwater Society, a non-profit dedicated to the promotion of the conservation, protection and restoration of all freshwater resources, to target one of the most significant sources of nutrients to local waters.

Last year, the City of Saint Paul, with monitoring assistance from CRWD, eliminated the illicit discharge in the East Kittsondale storm sewer. For 2011, CRWD will continue to monitor East Kittsondale storm sewer and ensure that the water quality issues do not arise again. In addition, CRWD will offer to work with the City on identifying and tracking the source(s) of illicit discharges in other subwatersheds.

Last year, CRWD completed a technical analysis of lowering the development size threshold to less than an acre for CRWD Rules. This would require property owners of smaller sites to comply with the Rules for construction site erosion and sediment control and post construction stormwater management. CRWD will convene the technical advisory committee to discuss the analysis and assess the benefits, challenges and issues related to lowering the permit threshold.

5.0

RECOMMENDED MODIFICATIONS TO THE SWPPP

CRWD does not anticipate making any modifications to the SWPPP for 2011.

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REFERENCES

Capitol Region Watershed District, 2000. CRWD Watershed Management Plan 2000.

Roseville, MN. Capitol Region Watershed District, 2006.

Plan. Saint Paul, MN.

CRWD Stormwater Pollution Prevention

Capitol Region Watershed District, 2009. Capitol Region Watershed District Rules.

Saint Paul, MN. Capitol Region Watershed District, 2009. 2009 Best Management Practice Inspection and Maintenance Protocols. Saint Paul, MN. MPCA, 2000. Protecting Water Quality in Urban Areas Manual. Saint Paul, MN. MPCA, 2005. Minnesota Stormwater Manual. Saint Paul, MN US EPA, 2000. Stormwater Phase II Final Rule Fact Sheets, EPA 833-F-00-001. US EPA - Office of Water. Washington D.C. US EPA, 2005. NPDES General Permit for Stormwater Discharges from Construction Activities, 40 CFR Parts 9, 122, 123, & 124. EPA – Office of Water. Washington D.C.

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APPENDIX A: 2010 MPCA ANNUAL REPORT FORM

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MS4 Annual Report for 2010 Municipal Separate Storm Sewer Systems (MS4s) Reporting period January 1, 2010 to December 31, 2010 Due June 30, 2011 Doc Type: Permitting Annual Report

Instructions: By completing this mandatory MS4 Annual Report form, you are providing the Minnesota Pollution Control Agency (MPCA) with a summary of your status of compliance with permit conditions, including an assessment of the appropriateness of your identified best management practices (BMPs) and progress towards achieving your identified measurable goals for each of the minimum control measures as required by the MS4 Permit. If a permittee determines that program status or compliance with the permit can not be adequately reflected within the structure of this form additional explanation and/or information may be referenced in an attachment. This form has significant limitations and provides only a snap shot of MS4 compliance with the conditions in the Permit.

After reviewing the information, MPCA staff may need to contact the permittee to clarify or seek additional information. The MPCA enforcement policy is to provide the opportunity to respond to any alleged violations before any enforcement action is taken.

Submittal: This MS4 Annual Report must be submitted electronically to the MPCA using the submit button at the end of the form, from the person that is duly authorized to certify this form. All questions with an asterisk (*) are required fields (these fields also have a red border), and must be completed before the form will send. A confirmation e-mail will be sent in response to electronic submissions. To obtain an electronic copy of the 2010 MS4 Annual Report form, please visit the MPCA website at: http://www.pca.state.mn.us/water/stormwater/stormwater-ms4.html.

If you have further questions, please contact one of these MPCA staff members (toll-free 800-657-3864): • • •

Joyce Cieluch Scott Fox Amy Garcia

218-846-7387 651-757-2368 651-757-2377

General Contact Information (*Required fields) *Name of MS4: Capitol Region Watershed District *Mailing address:

*Contact name: Anna Eleria

1410 Energy Park Drive, Suite 4

*City: Saint Paul

*State: MN

*Zip code: 55108

*Phone (including area code):

*E-mail: anna@capitolregionwd.org (651) 644-8888 Check here if this contact information is different than the contact indicated on the mailing label.

Minimum Control Measure 1: Public Education and Outreach [V.G.1] (*Required fields) A.

The permit requires each Permittee to implement a public education program to distribute educational materials to the community or conduct equivalent outreach activities about the impacts of stormwater discharges on water bodies and steps that the public can take to reduce pollutants in stormwater runoff. [Part V.G.1.a] Note: Please indicate which of the following distribution methods you used during the 2010 calendar year. Indicate the number distributed in the spaces provided (enter “0” if the method was not used or “NA” if the data does not exist): Media type

Number of media

Number of times published

Circulation/ Audience

Example: Brochures:

3 different brochures 1

published 5 times

about 10,000

1

500

1 0

2

1,000

Radio ads:

2 1 One PSA

1 1 June

50,000 10,000 50,000

Television ads:

30-sec. PSA

May and August

537,500

Cable Access Channel:

Two PSAs

Summer and fall PSAs

886,000

Other: Billboards

3 different billboards 30-sec. PSA

Summer 96 times during season

6,638,800 1,152,000

Brochures: Newsletter: Posters: Newspaper articles: Utility bill inserts:

Other: Saint Paul Saints Baseball Other:

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B.

*Do you use a website as a tool to distribute stormwater educational materials?

What is the URL:

C.

Yes

No

Yes

No

Yes

No

www.capitolregionwd.org

If you answered yes in question B. above, do you track hits to the site?

How many hits to the stormwater page during 2010:

D.

*Did you hold stormwater related events, presentations to schools or other such activities?

If yes, please describe:

CRWD held 10 rain garden, native plant or rain barrel workshops in 2010 for the Saint Paul District Planning Councils. CRWD also attended four environmental related events and gave presentations at local schools. Please see attached report for more information.

E.

*Have specific messages been developed and distributed during the 2010 calendar year for Minimum Control Measure (MCM): MCM 1:

Yes

No

MCM 4:

Yes

No

MCM 2:

Yes

No

MCM 5:

Yes

No

MCM 3:

Yes

No

MCM 6:

Yes

No

F.

*Have you developed partnerships with other MS4s, watershed districts, local or state governments, educational institutions, etc., to assist you in fulfilling the requirements for MCM 1?

G.

List those entities with which you have partnered during the 2010 calendar year to meet the requirements of this MCM and describe the nature of the agreement(s). Attach a separate sheet if necessary:

Yes

No

Local district planning councils, Watershed Partners, Blue Thumb, University of Minnesota. Please see attached report for description of our agreements with these entities.

H.

*Have you developed methods to assess the effectiveness of your public education/outreach program?

Yes

No

If yes, please describe:

Minimum Control Measure 2: Public Participation/Involvement [V.G.2] (*Required fields) A.

*Did you hold a public meeting to present accomplishments for calendar year 2010 and to discuss your Stormwater Pollution Prevention Program (SWPPP)? [Part V.G.1.e]

Yes

No

If no, explain:

06/15/2011

B.

What was the date of the public meeting:

C.

How many citizens attended specifically for stormwater (excluding board/council members and staff/hired consultants)?

D.

Was the public meeting a stand-alone meeting for stormwater or was it combined with some other function (City Council meeting, other public event, etc.)?

Stand-alone Combined

E.

*Each permittee must solicit and consider input from the public prior to submittal of the annual report. Did you receive written and/or oral input on your SWPPP? [Part V.G.2.b.1-3]

Yes

No

F.

*Have you revised your SWPPP in response to written or oral comments received from the public since the last annual reporting cycle? [Part V.G.2.c]

Yes

No

0

If yes, describe. Attach a separate sheet if necessary:

Minimum Control Measure 3: Illicit Discharge Detection and Elimination [V.G.3] (*Required fields) The permit requires permittees to develop, implement, and enforce a program to detect and eliminate illicit discharges as defined in 40 CFR 122.26(b)(2). You must also select and implement a program of appropriate BMPs and measurable goals for this minimum control measure.

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A.

*Did you update your storm sewer system map in 2010?

Yes

No

Yes

No

Yes

No

If yes, please explain which components (ponds, pipes, outfalls, waterbodies, etc.) were updated/added:

Note: The storm sewer system map was to be completed by June 30, 2008. [Part V.G.3.a] B.

*Have you modified the format in which the map is available?

C.

If yes, indicate the new format: Hardcopy only

D.

GIS system

CAD

Other system:

*Have you established an ordinance or other regulatory mechanism to prohibit illicit discharges and/or non-stormwater discharges from entering the MS4?

Note: The Permit requires the ordinance or other regulatory mechanism to be established by June 30, 2010 [Part V.G.3.b] If yes, indicate whether you’ve established an:

Ordinance or

Regulatory mechanism

E.

If you answered yes in question D. above, provide the date the ordinance or other regulatory mechanism was adopted:

F.

If you answered yes in question D. above, a complete copy of your illicit discharge prohibition ordinance or other regulatory mechanism addressing the requirements of Part V.G.3.b. of the Permit must be submitted with this MS4 Annual Report. Please provide the URL/reference where your illicit discharge ordinance or other regulatory mechanism may be found. Include specific code numbers if available:

09/06/2006

http://www.capitolregionwd.org/rules.html The ordinance may alternately be submitted as a separate electronic file attached to the e-mail submittal of this annual report. Are you submitting an electronic copy?

Yes

No

Minimum Control Measure 4: Construction Site Stormwater Runoff [V.G.4] (*Required fields) The permit requires that each permittee develop, implement, and enforce a program to reduce pollutants in any stormwater runoff to your small MS4 from construction activities within your jurisdiction that result in a land disturbance of equal to or greater than one acre, including the disturbance of less than one acre of total land area that is part of a larger common plan of development or sale if the larger common plan will ultimately disturb one or more acres. [Part V.G.4.]

A.

The permit requires an erosion and sediment control ordinance or regulatory mechanism that must include sanctions to ensure compliance and contains enforcement mechanisms [Part V.G.4.a]. Indicate which of the following enforcement mechanisms are contained in your ordinance or regulatory mechanism and the number of actions taken for each mechanism used during the reporting period (enter “0” if the method was not used or “NA” if the data does not exist).

Check all that apply.

Enforcement mechanism

B.

Number of actions

Verbal warnings

#

Notice of violation

#

Administrative orders

#

Stop-work orders

#

Fines

#

Forfeit of security of bond money

#

Withholding of certificate of occupancy

#

Criminal actions

#

Civil penalties

#

Other:

#

50

*Have you developed written procedures for site inspections?

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C.

*Have you developed written procedures for site enforcement?

Yes

No

D.

*Identify the number of active construction sites greater than an acre in your jurisdiction during the 2010 calendar year:

30

E.

*On average, how frequently are construction sites inspected (e.g., weekly, monthly, etc.)?

Bi-monthly; after rain

F.

*How many inspectors, at any time, did you have available to verify erosion and sediment control 2 compliance at construction sites during the 2010 calendar year:

Minimum Control Measure 5: Post-construction Stormwater Management in New Development and Redevelopment [V.G.5] (*Required fields) The permit requires each permittee to develop, implement, and enforce a program to address stormwater runoff from new development and redevelopment projects within your jurisdiction that disturb an area greater than or equal to one acre, including projects less than one acre that are part of a larger common plan of development or sale that discharge into your small MS4. Your program must ensure that controls are in place that would prevent or reduce water quality impacts. You must also select and implement a program of appropriate BMPs and measurable goals for this minimum control measure.

Note: The MS4 permit requirements associated with this minimum control measure were required to be fully developed and implemented by June 30, 2008.

A.

*Have you established design standards for stormwater treatment BMPs installed as a result of post-construction requirements?

Yes

No

B.

*Have you developed procedures for site plan review which incorporate consideration of water quality impacts?

Yes

No

C.

*How many projects have you reviewed during the 2010 calendar year to ensure adequate longterm operation and maintenance of permanent stormwater treatment BMPs installed as a result of post-construction requirements? [Part V.G.5.b.and Part V.G.5.c].

Yes

No

D.

*Do plan reviewers use a checklist when reviewing plans?

E.

*How are you funding the long-term operation and maintenance of your stormwater management system? (Check all that apply) Grants

Stormwater utility fee

33

Taxes

Other:

Minimum Control Measure 6: Pollution Prevention/Good Housekeeping for Municipal Operations [V.G.6] (*Required fields) The permit requires each MS4 to develop and implement an operation and maintenance program that includes a training component and has the ultimate goal of preventing or reducing pollutant runoff from municipal operations. Your program must include employee training to prevent and reduce stormwater pollution from activities, such as park and open space maintenance, fleet and building maintenance, new construction and land disturbances, and stormwater system maintenance.

A.

*Indicate the total number of structural pollution control devices (for example-grit chambers, sumps, floatable skimmers, etc.) within your MS4, the total number that were inspected in 2010, and calculate the percent inspected. Enter “0” if your MS4 does not contain structural pollution control devices or none were inspected in 2010. Enter “NA” if the data does not exist:

*Structural pollution control devices:

*Total number 9

*Number inspected 9

*Percentage 100

B.

*Did you repair, replace, or maintain any structural pollution control devices?

C.

*For each BMP below, indicate the total number within your MS4, how many of each BMP type were inspected and the percent inspected in 2010. Enter “0” if your MS4 does not contain BMPs or none were inspected in 2010. Enter “NA” if the data does not exist: Structure/Facility type

*Total number

*Number inspected

Yes

*Percentage

*Outfalls to receiving waters:

1

1

100

*Sediment basins/ponds:

4 5

4 5

100 100

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D.

Of the BMPs inspected in C. above, did you include any privately owned BMPs in that number?

E.

If yes in D. above, how many?

Yes

No

Section 7: Impaired Waters Review (*Required fields) The permit requires any MS4 that discharges to a Water of the State, which appears on the current U. S. Environmental Protection Agency (EPA) approved list of impaired waters under Section 303(d) of the Clean Water Act, review whether changes to the SWPPP may be warranted to reduce the impact of your discharge [Part IV.D].

A.

*Does your MS4 discharge to any waters listed as impaired on the state 303 (d) list?

Yes

No

B.

*Have you modified your SWPPP in response to an approved Total Maximum Daily Load (TMDL)?

Yes

No

Yes

No

Yes

No

If yes, indicate for which TMDL:

Section 8: Additional SWPPP Issues (*Required fields) A.

*Did you make a change to any BMPs or measurable goals in your SWPPP since your last report? [Part V.H.] If yes, briefly list the BMPs or any measurable goals using their unique SWPPP identification numbers that were modified in your SWPPP, and why they were modified: (Attach a separate sheet if necessary)

B.

C.

*Did you rely on any other entities (MS4s, consultants, or contractors) to implement any portion of your SWPPP? If yes, please identify them and list activities they assisted with: City of Saint Paul - Maintenance of storm sewer interceptor, stormwater ponds

Owner or Operator Certification (*Required fields) The person with overall administrative responsibility for SWPPP implementation and Permit compliance must certify this MS4 Annual Report. This person must be duly authorized and should be either a principal executive (i.e., Director of Public Works, City Administrator) or ranking elected official (i.e., Mayor, Township Supervisor). *Yes - 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 the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete (Minn. R. 7001.0070). I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment (Minn. R. 7001.0540). *Name of certifying official: Mark Doneux *Title: Administrator

*Date: 06/17/2011 (mm/dd/yyyy)

Submit

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APPENDIX B: EAST KITTSONDALE ILLICIT DISCHARGE LETTER

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