Acknowledgements
The updated Truckee Meadows Storm Water Management Program (SWMP) document was prepared by the MS4 Co-Permittees, which include City of Reno, City of Sparks and Washoe County. The updated SWMP was prepared under the guidance of the Truckee Meadows Storm Water Permit Coordinating Committee (SWPCC). The SWPCC members are:
E. Terri Svetich, P.E., Committee Coordinator John Martini, P.E., Committee Chair City of Reno Environmental Engineering City of Sparks Engineering
Andy Hummel, P.E. Kyle West, P.E. City of Sparks Public Works City of Reno Community Development
Walter West, P.E. Christian Kropf Washoe County Public Works Washoe County Water Resources
Susan Ball Rothe John Buzzone, P.E. (former SWPCC member) City of Reno, Deputy City Attorney Washoe County Water Resources
Funding for the SWMP Update was provided by the Western Regional Water Commission (WRWC).
Special thanks to Lynell Garfield, M.S., City of Reno Public Works and Steve McGoff, P.E., Nevada Division of Environmental Protection, who regularly participated in SWPCC meetings, providing input.
Others who regularly attended SWPCC meetings and were involved in review and development of the SWMP document, including the Best Management Practice (BMP) Fact Sheets include:
Jim Smitherman, Washoe County Department of Water Resources, WRWC Chris Wessel, Washoe County Department of Water Resources, WRWC Candice Elder, Kennedy Jenks Consultants Jeff Jesch, Hillside Design Ben Jesch, P.E., Hillside Design Toby Ebens, City of Sparks Environmental Control (former SWPCC member)
Staff from Stantec Consulting who were responsible for the updated SWMP document and associated BMP Fact Sheets include:
Jeffry Curtis, Ph.D., Project Manager John Enloe, P.E., Principal Engineer Sarah McIlroy, P.E., CPESC, Managing Senior Associate Brooke Long, P.E., Project Engineer Trina Magoon, P.E., Senior Engineer Niki Linn, Office Administrator
The efforts and passion of the late Chris Conway with respect to storm water issues in the Truckee Meadows are acknowledged with gratitude by those involved with the preparation of this document.
Truckee Meadows Storm Water Management Program Acronyms / Table of Contents
Acronyms
303(d) Clean Water Act Section Specifying the Preparation of Nevada’s List of Impaired Waters AGC Association of General Contractors APWA American Public Works Association ASCE American Society of Civil Engineers BANN Builders Association of Northern Nevada BMP Best Management Practice CASQA California Stormwater Quality Association CFR Code of Federal Regulations CMP Coordinated Monitoring Plan CWR Clean Water Act DRI Desert Research Institute EC Environmental Control (Local Jurisdictions) EPA U.S. Environmental Protection Agency GIS Geographic Information System HAZMAT Hazardous Materials IC Industry Category IDDE Illicit Discharge Detection and Elimination I/I Inflow and Infiltration KTMB Keep Truckee Meadows Beautiful LA Load Allocation LID Low Impact Development LRWQCB Lahontan Regional Water Quality Control Board MCL Maximum Contaminant Level MEP Maximum Extent Practicable mg/L Milligrams per Liter MGD Million Gallons per Day MOU Memorandum of Understanding MS4 Municipal Separate Storm Sewer System NDEP Nevada Division of Environmental Protection NDOT Nevada Department of Transportation NDOW Nevada Department of Wildlife NEMO Non-point Education for Municipal Officials NEPA National Environmental Policy Act NNWPC Northern Nevada Water Planning Commission NPDES National Pollutant Discharge Elimination System NTD North Truckee Drain NWRA Nevada Water Resources Association O&M Operations and Maintenance
Truckee Meadows Storm Water Management Program Acronyms / Table of Contents
PLPT Pyramid Lake Paiute Tribe RCRA Resource Conservation and Recovery Act RWQCB Regional Water Quality Control Board SAP Sampling and Analysis Plan SARA Superfund Amendments and Reauthorization Act SOP Standard Operating Procedure SWMP Storm Water Management Program SWPCC Storm Water Permit Coordinating Committee SWPPP Storm Water Pollution Prevention Plan TDS Total Dissolved Solids TKN Total Kjeldahl Nitrogen TM Truckee Meadows TMDL Total Maximum Daily Load TMWA Truckee Meadows Water Authority TMWRF Truckee Meadows Water Reclamation Facility TMSA Truckee Meadows Service Area TMWC Truckee Meadows Watershed Committee TN Total Nitrogen TP Total Phosphorus TRFMA Truckee River Flood Management Authority TRFP Truckee River Flood Project TRIG Truckee River Information Gateway TROA Truckee River Operating Agreement TSS Total Suspended Solids T-TSA Tahoe-Truckee Sanitation Agency UDFCD Urban Drainage and Flood Control District UNCE University of Nevada Cooperative Extension UNR University of Nevada, Reno USFWS US Fish and Wildlife Service USGS U.S. Geological Survey WCDWR Washoe County Department of Water Resources WCDHD Washoe County District Health Department WCSD Washoe County School District WHPP Wellhead Protection Plan WLA Waste Load Allocation WQv Water Quality Volume WRCC Western Regional Climate Center WRWC Western Regional Water Commission
Truckee Meadows Storm Water Management Program Acronyms / Table of Contents
Table of Contents
Section 1 – Introduction 1.1 Background and Perspective ...... 1-1 1.1.1 Overview of the Program Area ...... 1-2 1.1.2 Truckee Meadows Storm Water Permit Coordinating Committee ...... 1-3 1.1.3 Storm Water Quality Management ...... 1-4 1.2 Truckee Meadows Storm Water Management Program ...... 1-8 1.2.1 Program Goals ...... 1-9 1.3 Document Organization ...... 1-9 1.4 SWMP Organization ...... 1-10 1.5 Comments ...... 1-10
Section 2 – Storm Water Management 2.1 Regulatory Requirements ...... 2-1 2.1.1 The NPDES Storm Water Program...... 2-1 2.1.2 Requirements of the Truckee Meadows NPDES MS4 Permit ...... 2-2 2.1.3 Permissible Non-Storm Water Discharges ...... 2-4 2.2 MS4 Boundaries ...... 2-5 2.3 Imparied Waters within the MS4 Permit Area ...... 2-5 2.3.1 Truckee River TMDL ...... 2-5 2.3.2 Nevada 303(d) Listed Waters and Impairments...... 2-7 2.4 Review of Legal Authority ...... 2-7 2.4.1 Truckee Meadows SWPCC Interlocal Agreement ...... 2-9 2.5 Storm Water Monitoring ...... 2-9 2.5.1 Current Monitoring Program ...... 2-10 2.5.2 Evaluation of the Existing Characterization Data ...... 2-12 2.5.3 Future Monitoring Priorities ...... 2-23 2.6 Best Management Practices (BMPs) ...... 2-24 2.6.1 Permit Requirements Relating to Storm Water BMPs ...... 2-24 2.6.2 Existing Truckee Meadows Storm Water BMPs ...... 2-25 2.6.3 Process for Selecting New Storm Water BMPs ...... 2-31 2.6.4 SWMP Incorporation of New BMPs ...... 2-31
Truckee Meadows Storm Water Management Program Acronyms / Table of Contents
2.6.5 Use and Selection of BMPs ...... 2-32 2.6.6 Organization of New BMPs ...... 2-32
Section 3 – Program Elements 3.1 Public Outreach and Education ...... 3-1 3.1.1 Permit Requirements (EDU) ...... 3-1 3.1.2 Practices (EDU) ...... 3-2 3.2 Illicit Discharge Detection and Elimination (IDDE) ...... 3-9 3.2.1 Permit Requirements (IDDE) ...... 3-9 3.2.2 Practices (IDDE) ...... 3-10 3.3 Industrial Facility Monitoring and Control (IND) ...... 3-15 3.3.1 Permit Requirements (IND) ...... 3-15 3.3.2 Practices (IND) ...... 3-16 3.4 Municipal Operations (MUNI) ...... 3-21 3.4.1 Permit Requirements (MUNI)...... 3-21 3.4.2 Practices (MUNI) ...... 3-21 3.5 Post Construction for New Development and Significant Redevelopment (POST) ...... 3-26 3.5.1 Permit Requirements (POST) ...... 3-26 3.5.2 Practices (POST) ...... 3-30 3.5.3 Future Regional Flood Projects (POST) ...... 3-36 3.5.4 Design Standards (POST) ...... 3-37 3.6 Construction Site Discharge (CONST) ...... 3-38 3.6.1 Permit Requirements (CONST) ...... 3-38 3.6.2 Practices (CONST) ...... 3-39 3.7 Intergovernmental Coordination (GOV) ...... 3-42 3.7.1 Permit Requirements (GOV) ...... 3-42 3.7.2 Practices (GOV) ...... 3-49
Section 4 – Management, Reporting and Assessment 4.1 Coordination and Stakeholders ...... 4-1 4.2 Priorities for Implementing BMPs ...... 4-2 4.2.1 Permit Requirements for BMP Implementation ...... 4-3 4.2.2 BMP Implementation and Priorities ...... 4-3 4.3 Staff and Resources for Program Implementation ...... 4-9
Truckee Meadows Storm Water Management Program Acronyms / Table of Contents
4.4 Annual Reporting Requirements...... 4-9 4.4.1 Permit Requirements for the Annual Report ...... 4-11 4.4.2 Measurable Goals and Determining SWMP Effectiveness ...... 4-14 4.4.3 Determining the Impacts of Storm Water on Impaired Waters ...... 4-15 4.4.4 Assessing the Effect of the SWMP on Drinking Water Supplies ...... 4-17
Section 5 – References ...... 5-1
Section 6 – BMP Fact Sheets ...... 6-1
EDU-01 Public Outreach and Education - Typical Events EDU-02 Public Outreach and Education Materials EDU-03 Storm Drain Labeling Program EDU-04 Partnerships and Affiliations EDU-05 Regional Program Website - TMStormwater.com EDU-06 Truckee River Watershed Map Tool EDU-07 Demonstration Projects - Typical EDU-08 Workshop and Training Seminars IDDE-01 Illicit Discharge Report and Response Database IDDE-02 Spill Control and Prevention IDDE-03 IDDE Corrective Action and Follow-Up Protocols IDDE-04 Sanitary and Storm Sewer Inspection Program IDDE-05 Household Hazardous Waste Program IND-01 Commercial and Industrial Storm Water Inspections IND-02 Commercial and Industrial Storm Water Outreach and Education IND-03 Housekeeping – Commercial/Industrial IND-04 Commercial/Industrial Facility Inventory IND-05 Industrial and Commercial Storm Water BMP Handbook MUNI-01 Storm Drain and Channel Maintenance MUNI-02 Street Sweeping MUNI-03 Maintenance of City and County Owned Facilities MUNI-04 Pesticide, Herbicide and Fertilizer Application Management - Internal MUNI-05 Staff Training – Operations and Maintenance - Internal POST-01 Land Development POST-02 Truckee Meadows Structural Controls Design Manual POST-03 Truckee Meadows Low Impact Development Handbook POST-04 Truckee Meadows Standard Design Guidance Worksheets POST-05 Future Regional Flood Projects CONST-01 Construction Site Inspections CONST-02 Construction Site BMP Training
Truckee Meadows Storm Water Management Program Acronyms / Table of Contents
CONST-03 Construction Site BMP Handbooks GOV-01 Intergovernmental Coordination GOV-02 Municipal Codes and Ordinances GOV-03 Complaint Hotline GOV-04 Truckee Meadows Regional Drainage Manual GOV-05 Code Enforcement GOV-06 Plan Review MS4-01 Outfall, Channel and Tributary Inspections and Assessments MS4-02 MS4 Mapping MS4-03 Monitoring - Dry Weather MS4-04 Monitoring - Wet Weather MS4-05 Identification of New Storm Water BMPs MS4-06 SWMP Effectiveness Assessment MS4-07 SWMP Effect on Drinking Water Quality MS4-08 Impaired Waters
List of Tables Table 1-1 Typical Pollutants Associated with Urban Land Use Activities Table 2-1 Summary of Truckee River Total Maximum Daily Loads, Wasteload and Load Allocations Table 2-2 Impaired Waters in the Truckee Meadows MS4 Permit Area (NDEP, 2009) Table 2-3 Agencies Currently Conducting Monitoring or Water Quality Studies on the Truckee River and Tributaries Table 2-4 SWMP 2010 Monitoring Site Summary Information Table 2-5 Summary of the Truckee Meadows RSQMP Monitoring Data Table 2-6 Summary of the Truckee Meadows RSQMP Monitoring Data, Field Determinations Table 2-7 Storm Water BMPs listed in the Truckee Meadows Structural Control Design Manual Table 2-8 Storm Water BMPs listed in the Nevada Contractors Field Guide for Construction Site Best Management Practices Table 2-9 Storm Water BMPs listed in the Truckee Meadows Construction Site Best Management Practices Handbook Table 2-10 Storm Water BMPs listed in the Truckee Meadows Industrial and Commercial Storm Water Best Management Practices Handbook Table 2-11 Storm Water BMPs listed in the Truckee Meadows Low Impact Development Handbook Table 2-12 Storm Water BMPs listed in the Truckee Meadows Regional Drainage Manual Table 2-13 Storm Water BMPs listed in the Truckee Meadows Regional Storm Water Quality Management Program, December 2001 Table 3-1 Permit Requirements and Activities for Public Outreach and Education Table 3-2 Permit Requirements and Activities for Illicit Discharge and Detection
Truckee Meadows Storm Water Management Program Acronyms / Table of Contents
Table 3-3 Permit Requirements and Activities for Industrial Facility Monitoring and Control Table 3-4 Permit Requirements and Activities for Municipal Operations Table 3-5 Permit Requirements and Activities for Post Construction for New Development and Significant Redevelopment Table 3-6 Permit Requirements and Activities for Construction Site Discharges Table 4-1 Task and Implementation Schedule for New and Enhanced BMP Components Table 4-2 BMP Component Implementation Schedule by Required Date Table 4-3 Annual Co-Permittee Estimated Labor for BMP Implementation Table 4-4 Summary of Additional Permit Required Annual Reporting Requirements Table 4-5 Summary of Annual Reporting Requirements in the BMP Fact Sheets Table 6-1 SWMP Programmatic BMPs
List of Figures Figure 2-1 North Truckee Drain Water Quality (Upstream and Downstream) Figure 2-2 Steamboat Creek Water Quality (Upstream and Downstream) Figure 2-3 Thomas Creek Water Quality (Upstream and Downstream) Figure 2-4 Whites Creek Water Quality (Upstream and Downstream) Figure 2-5 Average Total Nitrogen and Total Phosphorus Concentrations in the Truckee River by Sampling Location and Year (1999 – 2004) Figure 2-6 Average Total Nitrogen and Total Phosphorus Concentration in the Truckee River by Sampling Location and Year (2005 – 2010)
Appendices A – Copy of the Truckee Meadows 2010 NPDES MS4 Permit B – Copy of the 2004 Interlocal Agreement C – MS4 Permit Area Map D – CASQA Effectiveness Assessment Fact Sheet E – Review of Legal Authority
Truckee Meadows Storm Water Management Program
Section 1 - Introduction
Summarized in this document and appendices is a description of the latest activities associated with the Truckee Meadows Regional Storm Water Quality Management Program (RSQMP). In May 2010, the Nevada Division of Environmental Protection (NDEP) re-issued a municipal separate storm sewer (MS4) discharge permit (Permit No. NVS000001, issued May 26, 2010, hereafter referred to as the “permit”) to the City of Reno, City of Sparks, and Washoe County, Nevada. The new permit requires the continued administration, implementation and enforcement of Storm Water Management Program (SWMP) to mitigate pollution in storm water runoff within the Truckee Meadows MS4 permit area for the five year term of the permit.
The Truckee Meadows Storm Water Management Program has been in effect for over 10 years. This document is a revised and updated version of the SWMP document first issued in December 2001. The term RSQMP and SWMP are equivalent and, for consistency with permit language, the term SWMP will be used within this document. The purpose of the program (SWMP) is to reduce the pollution in municipal storm water discharges to the maximum extent practicable.
Presented in this section is an introduction to the program, the Truckee Meadows region, issues associated with storm water management, program history, goals, and the organization of the document. 1.1 Background and Perspective
The water bodies that are authorized to receive storm water runoff from the co-permittees are the Truckee River and its tributaries. The majority of the municipal storm water runoff in the Truckee Meadows discharges to the Truckee River. Because the river is a major source of the area’s drinking water supply and is a year-round river located in an arid environment, its protection is particularly important. The Truckee River has a number of programs that have been instituted for its protection. The SWMP is designed to address the pollution associated with urban runoff and to help support the water quality goals for the Truckee River, the quality of life of the Truckee Meadows, the health of the river downstream and water quality in Pyramid Lake.
Although precipitation is infrequent in northern Nevada, contaminants that accumulate on private and public property, roadways and parking lots are often transported by urban runoff through the area’s municipal storm drain system and directly into the Truckee River. Discharges from the area’s municipal storm drain system occur not only as a result of rainfall and snowmelt events, but also during dry weather from sources such as water draining into streets from construction site activities, watering and cleaning activities at residential and commercial sites, flushing fire hydrants and illicit discharges and connections. These so-called dry weather flows can also transport significant amounts of pollution into local water bodies (Pitt and Lalor, et. al., 1993). Polluted urban
Truckee Meadows Storm Water Management Program 1-1 Section 1 - Introduction runoff threatens public health, fish, wildlife, recreational and aesthetic values in the Truckee Meadows. Studies conducted by the U.S. Environmental Protection Agency indicate that polluted urban runoff is a leading cause of impairment to approximately 40 percent of the surveyed water bodies in the country (USEPA, 2000).
Under the Clean Water Act, Congress mandated the National Pollutant Discharge Elimination System (NPDES) Storm Water Program in 1990. This program provides a comprehensive approach for addressing non-agricultural sources of pollution that are adversely affecting the quality of our nation's waters. NPDES storm water permits require cities to implement source controls designed to reduce and prevent harmful pollutants from being washed by runoff into local water bodies. In Nevada, the NPDES Program is administered and implemented by the state through the NDEP. The requirements of the permit apply to all urban development, whether public or private. As stated in the NPDES permit issued to the co-permittees, “The Permittees shall continue to implement and enforce their Stormwater Management Program designed to reduce the discharge of pollutants from the Permittees’ MS4 to the maximum extent practicable to protect water quality and to satisfy the appropriate water quality requirements of the Clean Water Act”.
The Total Maximum Daily Load (TMDL) Program is another federal program designed to manage water pollution to water bodies that are not meeting federal (and State) water quality standards, such as the Truckee River. Although the SWMP is a separate program and its activities are not required by the TMDL Program, it could have the secondary benefit of helping to manage the TMDLs that have been established for the Truckee River. Under the storm water MS4 permit, the co-permittees are required to provide pollutant load estimates for storm water discharges and pollutant load reductions attributable to the program activities. The NPDES and TMDL Programs are discussed in greater detail in Sections 2.1 and 2.3 respectively.
The SWMP is a comprehensive program that has been developed over the past decade through a series of meetings and workshops attended by local government representatives, area professionals, and private citizens. The SWMP has been designed to address the unique political, socioeconomic, geographic and climatic conditions of the Truckee Meadows, as well as the conditions of the permit. Presented in this document is a comprehensive approach to implementing the SWMP, along with priorities, approaches, guidance and schedules for programs, activities and effectiveness evaluation for the term of the current permit. This SWMP is a living document that will require periodic modifications to ensure that it is effectively accomplishing its objectives.
1.1.1 Overview of the Program Area
The area known as the Truckee Meadows (TM) consists of the Cities of Reno and Sparks and the immediate adjacent urbanized areas in the southern portion of Washoe County. The new permit issued jointly to the permittees authorizes discharge of municipal storm water runoff to the
Truckee Meadows Storm Water Management Program 1-2 Section 1 - Introduction
“receiving waters of the United States” within the Cities of Reno and Sparks, and Washoe County that are located within the Truckee Meadows. Discharge of municipal storm water runoff to the Truckee River and its tributaries is contingent upon monitoring requirements, Best Management Practices (BMP) implementation, and other conditions set forth in the permit. The permitted area includes the limits of the urbanized area within the Truckee Meadows Service Area (TMSA) as established by the Truckee Meadows Regional Planning Agency (TMRPA). This area includes areas which are, or could reasonably be, urbanized within the time covered by the permit.
The Truckee River originates in the Sierra Nevada Mountains, flowing from the Lake Tahoe Basin in California/Nevada and terminating at Pyramid Lake in Nevada. The Truckee River is approximately 120 miles in length and the watershed is approximately 2,300 square miles in area, containing parts of the Nevada counties of Washoe, Pershing, Churchill, Lyon, Douglas, Carson City, and Storey County. The Truckee River bisects the Truckee Meadows into north and south sections and provides the major source of drinking water supply for the area. It also provides numerous recreational opportunities and habitat for fish and wildlife. The climate in the Truckee Meadows area is arid, with low humidity and an average annual rainfall of approximately seven inches. Protecting the Truckee River from storm water runoff remains a priority for the region.
Development activity in the Truckee Meadows from 2003 to 2006 was approximately double the historical average, and Nevada was the fastest growing state in the Country. This period of rapid growth was followed by a sharp decrease beginning in late 2006. Statewide unemployment peaked at 14.9 percent during 2010, and currently is over 13 percent. Nevada continues to rank as one of the top states in home foreclosure rates. This fundamental change to the economy has affected both short and long range population forecasts, and will impact future development and the level of municipal services for several years to come.
The co-permittees operate and maintain municipal storm drainage systems in the Truckee Meadows that consists of more than 9,100 catch basins, 300 miles of underground storm drain pipes, 100 miles of open ditches, and a number of wet pond structures and dry pond detention basins that are used primarily for flood control. The majority of the storm water that drains into the Truckee Meadows municipal storm drain system is conveyed to the Truckee River or its tributaries.
1.1.2 Truckee Meadows Storm Water Permit Coordinating Committee
The Truckee Meadows Storm Water Permit Coordinating Committee (SWPCC) is responsible for the development, administration, and implementation of this Storm Water Management Program. Initially, the “Truckee Meadows Interlocal Storm Water Committee” was formed in response to the initial NPDES permit issued jointly to the City of Reno, the City of Sparks and Washoe County, and the Nevada Department of Transportation (NDOT) in 1990. That same year, an Interlocal Agreement between the parties was signed to identify responsibilities and promote joint cooperation. The Interlocal Agreement was later amended on June 22, 2004 reflecting the removal
Truckee Meadows Storm Water Management Program 1-3 Section 1 - Introduction of NDOT as a co-permittee; however, NDOT and the three co-permittees have a 2001 Interlocal Agreement in place that facilitates coordination on storm water pollution prevention activities.
The 2004 Interlocal Agreement defines member's roles, procedures, responsibilities, duties and requirements to effectively and jointly administer the permit. The City of Reno is the lead agency under the 2004 Interlocal Agreement. The agreement establishes the SWPCC with two representatives per entity (i.e., City of Reno, City of Sparks and Washoe County). A copy of the Interlocal Agreement is presented in Appendix B. Responsibilities of the committee include the following:
1. Complying with the NPDES permit conditions; 2. Coordinating and participating in committee meetings; 3. Funding and implementing NPDES permit compliance efforts; 4. Coordinating and implementing annual operating budgets for jointly shared tasks; 5. Submitting reports prepared by various parties to NDEP and the USEPA as required by the NPDES permit; and 6. Maintaining knowledge of current and proposed state and federal policies, regulations and programs that impact “non-point”[1] source pollution programs.
Under the permit and the Interlocal Agreement, the SWPCC is responsible for the development, administration, implementation and enforcement (via ordinances) of this SWMP. The importance of maintaining these Interlocal Agreements and similar Memorandum of Understanding(s) (MOUs) is outlined in BMP Fact Sheet GOV-01, located in Section 6 of this document.
1.1.3 Storm Water Quality Management
Improved construction and engineering techniques in the 1950s through the 1970s led to the development of efficient storm drainage systems designed to quickly convey rainwater from streets and other impervious urban surfaces to streams and rivers. It soon became apparent that localized flooding was often caused by increased urban growth and the importance of storm water detention basins was recognized. Detention facilities became a standard site development requirement in many urban areas across the country and regional storm water quantity management and planning became commonplace. Water pollution control efforts at the time focused on regulation of point sources of pollution, such as monitoring and onsite treatment of industrial process water prior to discharge to a receiving water body.
In the 1980s, the environmental movement led to numerous studies, such as the National Urban Runoff Program (USEPA, 1983), which provided a body of information that urban areas contribute a
1 Non-point source pollution is a regulatory term referring to diffuse pollution sources (i.e., without a single point of origin or not introduced into a receiving stream from a specific outlet). Pollutants are generally carried off the land by storm water from sources such as agriculture, forestry, urban, mining, construction, dams, channels, land disposal, and city streets (USEPA, 1997).
Truckee Meadows Storm Water Management Program 1-4 Section 1 - Introduction
significant amount of non-point source pollution to local water bodies through storm water discharges from municipal storm drain systems. These studies and numerous legal actions by environmental organizations culminated in the early 1990s with the publication of Federal regulations that required municipalities to control pollution in urban runoff. Comprehensive storm water quality management began across the nation with the emphasis initially being placed on regulating the largest cities.
In the Truckee Meadows, municipal storm drainage facilities include gutters, swales, ditches, culverts, storm drain inlets, catch basins, storm drain pipes and detention basins. These facilities have been primarily designed to provide efficient drainage and flood control. The design, planning and construction of these facilities is regulated and managed under existing policies and ordinances with dedicated staff. Existing standard plans and specifications, public works design manuals and jurisdictional drainage design manuals provide technical guidance (see BMP Fact Sheets POST-02, POST-03, and POST-04). Dedicated staff and equipment financed by street and road budgets routinely conduct maintenance of publicly owned facilities.
Some privately owned storm drainage facilities, such as detention basins, tend to be poorly maintained, becoming ineffective nuisances and eyesores. Pollution control programs and structural controls can become susceptible to the same fate if appropriate institutional mechanisms, which provide legal authority, financial support, organizational structure and technical guidance, are not in place. One goal of this SWMP document is to outline priorities, approaches and guidance to ensure that these institutional mechanisms are in place and the program is successful. In addition to being a Federal and State requirement, storm water quality management is a key element to maintaining and enhancing the quality of life in the Truckee Meadows.
Storm water quality management programs across the country typically include a number of elements to address the wide range of pollutant sources in urban storm water runoff. These program elements typically include public outreach, municipal operations, storm water discharge monitoring, land use planning and structural controls for new development and redevelopment, construction and industrial site elements and illegal discharges. Each of these program elements requires the implementation of Best Management Practices (i.e. BMPs, activities that directly or indirectly protect water quality).
Sources of Pollutants in Urban Storm Water Runoff Pollutant sources in urban storm water runoff include industrial, commercial and residential sites, construction sites and municipal facilities such as parks, parking lots and roadways. In an urban setting, anything dumped, dropped or leaked onto the ground and exposed to rainfall, washing or watering activities can and often does contribute to storm water pollution. Agricultural sources of pollution in storm water runoff are typically not addressed in municipal storm water quality management programs and are addressed under separate State and Federal programs.
Truckee Meadows Storm Water Management Program 1-5 Section 1 - Introduction
Presented in Table 1-1 is a summary of the typical types of pollutants and contaminants that are often present and transported in urban storm water runoff. Each of the land use types listed in Table 1-1 can also contribute trash and debris (fast-food wrappers, cigarette butts, packaging materials, etc.) into local creeks and rivers. Atmospheric deposition of pollutants from such sources as automobile exhaust and industrial activities is another significant source of pollutants. In addition, combined sewer systems and cross connections between the sanitary sewer and storm drain systems exist in the older portions of some cities. If these structures discharge directly to a water body without treatment, they can contain human and industrial waste, toxic materials and debris. Finally, illegal discharges from illicit connections or illegal disposal of wastes into the storm drain system pose an important threat to receiving water bodies.
Environmental Impacts on Receiving Waters The water quality of urban streams and rivers is typically impacted by two phases of urbanization: construction and post development. Significant sediment loads from upland construction sites typically enter urban streams during rainfall runoff events, even if erosion and sediment control measures are in place (Roesner and Urbonas et al., 1998). For any given urban land area, sediment contributions typically decline to less than predevelopment levels once impervious structures and surfaces are constructed and landscaping is in place. The dominant source of storm water pollution then becomes the accumulated deposits on developed impervious surfaces that are washed into urban streams during storms or watering and washing activities. Although sediment loading may decrease, the range and concentration of other constituents in storm water runoff tend to increase.
In general, constituent concentrations in urban streams are one to two orders of magnitude greater than those in undisturbed and undeveloped watersheds (Roesner and Urbonas et al., 1998). The degree of loading has been shown to be directly proportional to the percentage of watershed imperviousness (Schueler, 1987). Higher loadings can cause water quality problems such as increased turbidity, nutrient enrichment, bacterial contamination, deposition of toxic compounds, increases in water temperature and deposition of trash and debris. When left uncontrolled, storm water pollution can result in the destruction of fish, wildlife, and habitats; threats to public health due to contaminated food and drinking water supplies; and losses of recreational and aesthetic values of waterways.
Truckee Meadows Storm Water Management Program 1-6 Section 1 - Introduction
Table 1-1. Typical Pollutants Associated with Urban Land Use Activities Land Use Type Activities Typical Pollutants
Landscape/yard maintenance Pesticides, herbicides, fertilizers, landscape debris, detergents, oil and Car washing grease, solvents, paints, household Car maintenance (e.g., oil changing) chemicals and pet wastes Residential Painting and remodeling Note: Excess runoff from over Storage and disposal of household watering is a problem, since this chemicals and hazardous wastes water carries additional pollutants to Pet management local creeks and rivers Landscape maintenance Outdoor (exposed) loading areas, material Pesticides, herbicides, fertilizers, and equipment storage detergents, oil and grease, solvents, Commercial/Light Public parking areas paints, metals, sediments/gravel Industrial Painting and remodeling (from landscape and parking areas) Storage and disposal of chemicals and and other wastes hazardous wastes Outdoor (exposed) loading areas Outdoor (exposed) material and equipment storage (including above ground storage tanks) Oil and grease, hydraulic fluids, Outdoor (exposed) petroleum hydrocarbons, solvents, Heavy Industrial manufacturing/processing areas metals, sediment/ gravel, detergents Fueling areas and other materials and wastes used Vehicle and equipment washing, at the facility maintenance, and/or parking areas Storage and disposal of chemicals and hazardous wastes Sediment/gravel (from eroded Clearing and grading surfaces or stored materials), Concrete and asphalt work concrete slurry, paints, oil and Painting grease, hydraulic fluids, petroleum Construction Sites Dewatering activities hydrocarbons, pesticides, herbicides Exposed storage of materials onsite and fertilizers, contaminated pumped Landscaping groundwater and other waste materials Continuous automobile, truck and bus use Oil and grease, hydraulic fluids, Utility company trenching and construction petroleum hydrocarbons, metals (e.g., activities copper, lead, zinc), sediment/gravel, Transportation Corridors Road repair and resurfacing activities deicing chemicals (e.g., salt, brine, Roadside vegetation maintenance sand), pesticides, herbicides and Truck spills fertilizers, spilled waste materials Deicing activities Fertilizers, herbicides, pesticides, Parks, Recreational Landscape maintenance sediment/gravel, landscape debris, Areas and Golf Courses Use by pets and livestock fecal waste (bacteria/pathogens) Source: Modified from Sacramento County Stormwater Quality Improvement Plan – November 2000 Draft
Truckee Meadows Storm Water Management Program 1-7 Section 1 - Introduction
Reducing Environmental Impacts with Best Management Practices Comprehensive storm water quality best management practices establish methods and strategies to: 1) control pollution at the source, and 2) treat polluted storm water with structural controls. Source controls include programs, activities and regulatory measures to prevent pollutants from entering runoff. Maintenance of the storm water collection system is also considered a source control; accumulations and deposits within the system can become pollutant sources if not removed prior to storm events. Structural controls are engineered solutions specifically designed to filter, trap and remove pollutants in the storm drain system prior to discharge into receiving waters. Source and structural controls are the two primary types of BMPs. Successful storm water quality management programs across the country apply a wide range of these two types of BMPs on a watershed-wide basis.
1.2 Truckee Meadows Storm Water Management Program
This SWMP consists of BMPs, ordinances, municipal activities, guidance documents, cooperative agreements and staff activities to reduce the pollutants in storm water runoff within the MS4 permit area to the MEP and enforce the requirements of the MS4 permit. There are seven primary program “elements” to the Truckee Meadows SWMP. They are:
1. Public Outreach and Education, 2. Illicit Discharge and Detection, 3. Industrial Facility Monitoring and Control, 4. Municipal Operations (MS4 maintenance activities and good housekeeping practices), 5. Post-Construction Storm Water Management Program for New Development and Significant Redevelopment, 6. Construction Site BMP Program, and 7. Intergovernmental Coordination.
The activities, controls and procedures associated with each of the program elements are detailed in Section 3 of this document. Each entity (Reno, Sparks, and Washoe County) is responsible for their own ordinances, inspections, inventories, operations, plan review, and maintenance activities within their jurisdiction. The SWMP consists of a combination of structural and non-structural BMPs, Low Impact Development (LID) guidelines, pollution prevention strategies, maintenance practices, and municipal ordinances (both existing and under development). Collectively, the SWPCC and co-permittee’s staff will implement, manage and support the storm water activities and policies outlined in this document.
Programmatic principles for storm water quality enhancement and protection of water resources include reducing or maintaining runoff to predevelopment conditions, controlling sources of pollutants, and treating storm water runoff (via structural and non-structural BMPs) prior to discharging to a storm drain system or to receiving waters. When fully implemented, collectively all
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of the various program components are considered by the USEPA to treat storm water runoff to the maximum extent practicable.
1.2.1 Program Goals
As provided in the permit, the primary goal of the Truckee Meadows SWMP is to reduce the discharge of pollutants in storm water runoff to the MEP. Additional SWMP goals include:
Encourage LID practices throughout the Truckee Meadows Protect area surface and groundwater resources Be efficient and cost-effective Maintain and coordinate storm water activities and implementation with area agencies Achieve compliance with water quality standards.
The program outlined in this document was created to accomplish the above listed goals.
1.3 Document Organization
The Truckee Meadows SWMP Document is organized as follows:
Section 1 – Introduction: Presented in this section is an introduction to the Truckee Meadows Storm Water Management Program, a description of the program background, sources of pollutants in storm water runoff, the use of BMPs, program elements and details of the document organization and terminology.
Section 2 – Storm Water Management in the Truckee Meadows: Section 2 contains a description of the regulatory requirements, the program area, impaired waters within the MS4 permit area, a review of legal authority, storm water monitoring and the use, selection and identification of storm water BMPs.
Section 3 – Program Elements: Presented in this section are the details of how the co- permittees address storm water management for each of the seven program elements.
Section 4 – Program Management, Assessment and Reporting: Section 4 contains a description of the various management activities required to administer the SWMP. The timetable for BMP implementation, program resources and reporting requirements are included in this section.
Section 5 – References: The various documents used and referenced in the preparation of this document are listed in this section.
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Section 6 – BMP Fact Sheets: The BMPs used in support of this SWMP are assembled in Section 6. Listed in each fact sheet is the status of the practice, use rationale, objectives, data collection requirements, labor estimates and an implementation schedule.
Appendices
A – Copy of the Truckee Meadows 2010 NPDES MS4 Permit B – Copy of the 2004 Interlocal Agreement C – Maps of the MS4 Permit Area D – CASQA Effectiveness Assessment Fact Sheet E – Review of Legal Authority
1.4 SWMP Terminology
There are a few terms that are frequently used in this document. For clarity:
The term “Annual Report” refers to the report generated by the co-permittees and submitted to NDEP each January 15 summarizing SWMP activities of the previous fiscal year.
Unless otherwise qualified, “permit” means the 2010 Truckee Meadows MS4 Permit (Permit No. NVS000001) issued May 26, 2010 to the City of Reno, City of Sparks and Washoe County.
In this document, “co-permittee” is used to describe the three entities (City of Reno, City of Sparks and Washoe County) listed as permittees in the permit.
1.5 Comments
Comments and questions relating to the Truckee Meadows Storm Water Management Program may be directed to:
Ms. E. Terri Svetich, P.E. Storm Water Program Coordinator City of Reno Public Works Department P.O. Box 1900 Reno, Nevada 89505 Phone: (775) 334-2350 Email: [email protected] Website: www.TMstormwater.com
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Presented in this section is a discussion of the new permit, regulatory requirements and the NPDES program. Impaired waters within the MS4 permit area, both 303(d) and TMDLs are briefly discussed in this section. As required in the permit, a review of legal authority, storm water monitoring and the BMP selection process is also included. 2.1 Regulatory Requirements
The Truckee Meadows SWPCC is legally bound to address the contaminants associated with urban runoff based on the requirements of the National Pollutant Discharge Elimination System (NPDES) Stormwater Permit Program. In Nevada, this program is administered and implemented by the state through the Nevada Division of Environmental Protection (NDEP). The NPDES permit allows the City of Reno, the City of Sparks, and Washoe County to discharge municipal storm water runoff and requires these co-permittees to develop, administer, implement and enforce a storm water quality management program.
2.1.1 The NPDES Storm Water Permit Program
In 1987, Congress amended the Federal Water Pollution Control Act (also known as the Clean Water Act) in order to protect receiving water bodies from the impacts of urban runoff. The Clean Water Act prohibits the discharge of any pollutant to Waters of the United States from sources such as factories or sewage treatment plants, unless the discharge is authorized by an NPDES permit. These discrete, identifiable sources of water pollution are termed “point sources” and the NPDES program was designed to regulate such sources. The 1987 amendments to the Clean Water Act (CWA) defined storm water discharges as point source discharges and established a framework for regulating municipal and industrial discharges under the NPDES program. In response to the 1987 amendments, the USEPA promulgated the final regulations in 1990 that established the permit requirements for Phase I of the NPDES Stormwater Program (USEPA, 2000).
The Phase I NPDES Stormwater Program addressed sources of storm water runoff that had the greatest potential to negatively impact water quality nationwide. Under Phase I, EPA required NPDES permit coverage for storm water discharges from medium and large municipal separate storm sewer systems (MS4s) located in incorporated places or counties with populations of 100,000 or more. In addition, Phase I required permit coverage for discharges from eleven categories of industrial activities, including construction activities that disturb five or more acres of land. In response to the Phase I NPDES permit requirements; the State of Nevada issued the City of Reno, the City of Sparks, Washoe County and NDOT their first permit in July 1990.
In 1999, the EPA published the Phase II Final Rule for the NPDES Stormwater Program, which was effective March 2003. In addition to requiring permit coverage for storm water discharges from
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certain regulated small MS4s, Phase II also lowered the threshold for construction activities regulation from five acres to one acre of disturbance. Under Phase II, operators of regulated small MS4s are required to design their programs to reduce the discharge of pollutants in storm water to the “maximum extent practicable” (MEP), to protect water quality and to satisfy the appropriate requirements of the CWA.
While Phase II rules do not supersede the Phase I requirements, Phase I communities such as the Truckee Meadows are encouraged by EPA and the State of Nevada to meet these minimum requirements. The Phase II Rule defines a small MS4 storm water management program as a program comprised of six “minimum control measures” that, when implemented in concert, are expected to result in significant reductions of pollutants discharged into receiving water bodies (USEPA, 2000). These “minimum control measures” consist of the following elements: Public Education and Outreach, Public Participation/Involvement, Illicit Discharge Detection and Elimination, Construction Site Runoff Control, Post Construction Runoff Control and Pollution Prevention/Good Housekeeping. The Truckee Meadows SWMP has been developed to meet these “minimum control measures”.
2.1.2 Requirements of the Truckee Meadows NPDES MS4 Permit
In accordance with the provisions of the Federal Water Pollution Control Act, the City of Reno, as lead agency for the Truckee Meadows SWPCC applied for and was granted a NPDES MS4 permit in 2000, 2005 and 2010. The co-permittees own and operate the municipal storm drain system in the Truckee Meadows. The 5-year NPDES permit authorizes the permittees to discharge municipal storm water runoff to the receiving waters of the Truckee River. The permit requires that the permittees develop and implement a SWMP that includes the following elements:
1. Public Outreach and Education - Outreach to the public to provide information on storm water pollution and its management and to ensure public participation in program development and implementation.
2. Illicit Discharge Detection and Elimination - Development and implementation of a program to detect and eliminate illegal discharges.
3. Industrial Facility Monitoring and Control – Implementation of a program to inventory facilities within the permit area and reduce the likelihood of industrial related storm water discharges.
4. Municipal Operations - BMPs for local government operations, including standard plans and specifications, storm drain maintenance, street sweeping, litter control, spill response and hazardous material disposal.
5. Post-Construction Storm Water Management for New Development and Significant Redevelopment – Development of institutional, source and structural controls for developments within the permit area.
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6. Construction Site BMP Program – Development and implementation of a program to minimize storm water runoff and erosion from disturbed areas and construction sites.
7. Intergovernmental Coordination - Inclusion of appropriate government agencies in implementation of the program.
These elements are typical of municipal storm water quality management programs across the country and largely similar to those in the Truckee Meadows 2005 permit. The permit also requires the submittal of annual reports. Requirements that must be addressed and summarized in an annual report are discussed in Section 4.5. Construction disturbances one acre or greater and certain industrial activities require a separate NDEP permit. These discharges are authorized under Permit NVR100000 and Permit NVR050000, respectively.
New Permit Components In comparison to the previous Truckee Meadows MS4 permit, the new permit has revised, added or deleted language that addresses the following subjects:
Revise the Existing Storm Water Management Program (“SWMP”). The new permit requires the co- permittees to review, revise as necessary and submit an updated SWMP to NDEP for its review and approval within eighteen (18) months of the effective date of this permit and then implement the revised SWMP no later than two (2) years after receiving NDEP’s approval.
Adequate Legal Authority. The new permit requires that the co-permittees have ordinances in place that prohibits illicit discharges into the MS4, requires structural and non-structural BMPs at construction sites, requires the co-permittees to inspect construction sites over one (1) acre to ensure compliance with the site’s Storm Water Pollution Prevention Plan (“SWPPP”), inspect industrial sites to ensure compliance with the facility’s SWPPP, and establish escalating enforcement procedures for non-compliance with the ordinance.
MS4 Maintenance Activities. The new permit requires the co-permittees to include a description of structural and source control measures in the updated SWMP that are expected to minimize pollutants from storm water runoff from commercial and residential areas that are discharged from the MS4. These activities impact streets, roads, flood control projects, landfills, and pesticide, fertilizer and herbicide use.
New Development and Significant Redevelopment Controls. The updated SWMP is required to include a description of planning procedures including a plan to reduce the discharge of pollutants to the MS4s, which receive discharges from areas of new development and significant redevelopment. These planning procedures are to include Low-Impact Development practices, long- term maintenance of post construction structures, an inventory and tracking system for post construction structures, and an inspection and enforcement program.
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Industrial Facility Monitoring and Control. The new permit requires the updated SWMP to include additional requirements related to industrial facilities including an inventory of all industrial facilities which discharge storm water associated with industrial activities and all commercial and municipal facilities which may be significant sources of pollutants. The co-permittees are also required to notify NDEP within ten (10) business days after a permittee determines that a facility is in significant non-compliance or is a “non-filer” under NDEP’s industrial storm water program.
Construction Site BMP Program. The new permit requires the co-permittees to inspect construction sites one acre or larger to ensure compliance with their ordinances. In addition, the permit requires a schedule of inspections for sites meeting certain criteria.
Minor Changes in Permit Language and Updating Relevant Information. Minor changes have been made to wording in the permit and acronyms have been used when appropriate. In addition, address changes were made to reflect NDEP’s new office location.
2.1.3 Permissible Non-Storm Water Discharges
Unless identified as contributing pollutants to the co-permittees storm drain system and/or the receiving waters of the U.S., the co-permittees are authorized to accept, pass through and discharge, without requiring BMPs or other measures, the following non-storm water sources:
Water line flushing Diverted stream flows Rising ground waters and springs Uncontaminated ground water infiltration into the storm drain system Discharges from potable water sources Foundation drains Air conditioning condensation Irrigation water from lawns and landscaping Water from residential crawl space pumps Individual residential car washing Flows from riparian habitats and wetlands De-chlorinated swimming pool discharges Water incidental to street sweeping Discharges from fire-fighting activities Dewatering activities not requiring a separate discharge permit
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As noted above, some of these non-storm water discharges or flows may require regulation, treatment, or elimination if they contribute pollutants to the storm drain system and/or the receiving waters of the U.S. For example, it is not permissible to wash spilled substances such as oil and grease from roadways into the storm drain system or directly into receiving waters. Although discharges from fire-fighting activities may contain significant pollutant concentrations, NDEP and EPA consider this a relatively infrequent activity that is allowed to occur out of necessity to protect public health and safety. 2.2 MS4 Boundaries
The permit authorizes storm water discharges into receiving waters of the United States within the Cities of Reno and Sparks, and Washoe County. The permitted area includes the limits of the urbanized area within the Truckee Meadows Service Area as established by the Truckee Meadows Regional Planning Agency. This area includes areas which are, or could reasonably be, urbanized within the time covered by the permit. Maps of the permit area are included in Appendix C. 2.3 Impaired Waters within the MS4 Permit Area
In addition to the NPDES Stormwater Permit Program, the Clean Water Act also established a program to manage water pollution to water bodies that are not meeting federal water quality standards. Section 303(d) requires that states establish a list of water bodies that are impaired by water pollution, and to assess the sources of that pollution. For water bodies listed as impaired, states must assess the amount of pollution that a water body can receive without violating water quality standards. That amount of pollution is termed a “Total Maximum Daily Load” (TMDL). The TMDL is then allocated among the different sources, including point sources, runoff sources and natural sources, and management activities are implemented to reduce the pollution.
2.3.1 Truckee River TMDL
Under Section II.B.1 of the new permit, the co-permittees are required to determine whether storm water from the MS4 permit area discharges into a waterbody for which a TMDL has been developed and approved by NDEP. TMDLs have been established on the Truckee River for three constituents, total nitrogen (TN), total phosphorus (TP), and total dissolved solids (TDS). The control point is at Lockwood under the assumption that if the TMDLs are being met at this location (downstream from the Truckee Meadows Water Reclamation Facility [TMWRF]) they are being met on the rest of the impaired river reach (NDEP, 1994).
Waste load allocations (WLAs) have been determined for each identified pollutant at each point source of pollution. Presently, there are allocations for TMWRF, Vista Canyon, and the Sparks Marina Park, which all discharge to the Truckee River. Each entity must comply with its NPDES permit requirements, including discharge limitations designed to meet the WLAs. Load allocations
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(LAs) have also been determined for background and non-point sources. The TMDLs are summarized in Table 2-1.
Table 2-1. Summary of Truckee River Total Maximum Daily Loads, Waste Load and Load Allocations
Source Nitrogen Phosphorus TDS Non-Point Sources/ Background 450 lbs/day 75.25 lbs/day None assigned (LA) TMWRF 500 lbs/day (annual avg.) 134 lbs/day 120,168 lbs/day (WLA) 500 lbs/day (30 day avg. May–Oct.) Vista Canyon Group 16.7 lbs/day 4.75 lbs/day 9,730 lbs/day (WLA) Sparks Marina Lake WLA Trade 33.3 lbs/day 19,390 lbs/day (WLA) Agreement
TMDL 1,000 lbs/day 214 lbs/day 900,528 lbs/day
The Truckee River TMDL was set to minimize dissolved oxygen (DO) violations for the 1988 low flow year. Both the TP and TDS TMDL were set based on average annual flow conditions. TP and TN were addressed in TMDLs due to the relation between nutrient loads, algal breakouts, and the resulting depletion of DO. Once a constituent is addressed in a TMDL, it can be taken off the 303(d) list; therefore, TN, TP and TDS were removed in 1994 (NDEP, 1994; 2011 Regional Water Management Plan, WRWC, 2011).
Presented in Section 2.5 of this document is a discussion of tributary and storm water quality within the Truckee Meadows permit area. In general, the TMDL listed constituents (TN, TP, TDS) are present in the waters of the tributaries monitored (see Table 2-4) and are expected to be present in storm water runoff. To date, NDEP has not set specific requirements for TMDL implementation by the local governments’ management of their storm water. However, the activities that will be implemented under this SWMP will serve to improve water quality in the Truckee River and should support the goals of the TMDL program.
Water quality standards are under review by NDEP. The need for an iterative approach to control pollutants in storm water discharges is recognized. In the event that storm flows in the Truckee Meadows are issued WLAs, control measures will be implemented as part of a subsequent SWMP document, which will be modified to include a schedule and an assessment of the need for additional control measures. The status of the Truckee River TMDL will be reported annually in the Annual Report to NDEP.
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2.3.2 Nevada 303(d) Listed Waters and Impairments
NDEP is required to prepare and submit an updated 303(d) list to the Environmental Protection Agency (EPA) every two years. The most current 303(d) list is Nevada's 2006 303(d) Impaired Waters List, finalized in February of 2009 (NDEP, 2009). Presently, there are seven different waterbodies on the State’s 303(d) list within the MS4 permit area, many of which have multiple segments listed. Presented in Table 2-2 are the names, ID number, reach and impairment of each of the listed waters within the MS4 permit area. All of these waterbodies and most (but not all) of the reaches are likely influenced by storm water runoff within the MS4 permit area. A discussion of determining the impacts of storm water runoff on the 303(d) listed waters within the MS4 permit area can be found in Section 4.5.3 of this document and in BMP Fact Sheet MS4-08 (Impaired Waters) in Section 6.
The new 2010 MS4 Permit requires the co-permittees to “evaluate whether storm water discharges from any part of the MS4 contributes directly or indirectly to the listing of a waterbody on the most current 303(d) list. Methodology to conduct this assessment is presented in Section 4.4.3. 2.4 Review of Legal Authority
Section IV.A.4 of the permit requires the updated SWMP to present a “review of legal authority to ensure adequate authority to implement the requirements of this permit and the updated SWMP”. The co-permittees and consultant staff reviewed the existing Truckee Meadows ordinances, articles and codes for the City of Reno, the City of Sparks, and Washoe County for the purpose of identifying whether each jurisdiction has adequate authority to enforce the requirements in the new permit. Codes and ordinances reviewed include:
City of Reno Code, Chapter 18.12 General Development and Design Standards, Article IV Limits on Grading, Erosion Prevention, and Sedimentation Control
City of Reno Code, Chapter 12.16 Sewer Service, Article IV Storm Water Management and Discharge Control, Division 2 Storm Water Regulations and Requirements
City of Sparks Code, Chapter 13.55 Definitions for Storm Water Management and Discharge Control
City of Sparks Code, Chapter 13.60 General Provisions for Storm Water Management and Discharge Control
City of Sparks Code, Chapter 13.65 Storm Water Regulations and Requirements
City of Sparks Code, Chapter 13.70 Environmental Control Permits for Storm Water Management and Discharge Control
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Table 2-2. Impaired Waters in the Truckee Meadows MS4 Permit Area (NDEP, 2009)
Water Name Waterbody ID Location/Reach WQ Impairment TMDL Status Arsenic Steamboat From gauging station (10-349300) Boron NV06-SC-42-D_00 Low Priority Creek to confluence w/ Truckee River Iron Zinc Boron From origin to east line of Sec. 33, NV06-SC-53-A_00 Zinc Low Priority T.18N., R.19E., M.D.B. & M. Arsenic Phosphorus Below east line of Sec. 33, T.18N., Boron NV06-SC-54-B_00 R.19E., M.D.B. & M. to Steamboat Arsenic Low Priority White’s Creek Ditch TDS Zinc Boron Zinc NV06-SC-63-B_00 Below Steamboat Ditch Low Priority Fecal Coliform Arsenic From source to National Forest Zinc NV06-SC-55-A_00 Low Priority Boundary From National Forest Boundary to Zinc NV06-SC-63-B_00 Low Priority Thomas Creek Steamboat Ditch Arsenic NV06-SC-64_00 Below Steamboat Ditch Zinc Low Priority Boron NV06-TR-02_00 From Stateline to Idlewild Temperature Low Priority From Idlewild to East McCarran TSS NV06-TR-03_00 Low Priority Blvd. Temperature Truckee River Turbidity NV06-TR-05_00 From Lockwood to Derby Dam Low Priority Temperature Temperature NV06-TR-06_00 From Derby Dam to Wadsworth Low Priority Turbidity Total Nitrogen Sparks Marina NV06-TR-65_00 The entire reservoir Dissolved Oxygen Low Priority TDS Ortho Phosphorus E. coli Total Phosphorus TSS From its origin to the Truckee Alum Creek NV06-TR-76_00 Sulfates Low Priority River Temperature TDS Turbidity Iron Selenium From its origin to the Truckee TDS Chalk Creek NV06-TR-77_00 Low Priority River Ortho Phosphorus Sulfates Where: TDS = Total Dissolved Solids; TSS = Total Suspended Solids
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City of Sparks Code, Chapter 13.75 Enforcement of Storm Water Management and Discharge Control
Washoe County Storm Water Discharge Ordinance No. 1223
The initial task included a full review of the 2010 permit for language requiring (or inferring) that the co-permittees are required to have an ordinance in place. Next the existing codes and ordinances (those listed above) were matched to the permit requirements. Lastly, the code language was scrutinized with respect to intent and the adequacy of coverage. Note that the review was conducted by non-legal, engineering staff.
Results of the review indicate that all three jurisdictions have adequate coverage in their existing storm water codes to support the legal authority requirements in the new permit. The City of Sparks and Washoe County should add a section to their codes and articles to specifically address post-construction storm water management. The City of Reno has post-construction storm water code (Section 18.12.405) in conformance with the general terms of the permit that may be used as example language. All other change issues noted were recommended or advisory changes only (not required to comply with the new permit, but should be considered by the individual permittees). The full analysis of legal authority can be found in Appendix E. Recognizing the importance of storm water ordinances, a BMP Fact Sheet for Municipal Codes and Ordinances (GOV-01) can be found in Section 6 of this document.
2.4.1 Truckee Meadows SWPCC Interlocal Agreement
The formation of a committee to administer the SWMP is required by permit. The SWPCC is responsible for the development, administration, implementation and enforcement of this SWMP document. As described in Section 1.1.2, the 2004 Interlocal Agreement between the City of Reno, City of Sparks and Washoe County defines the member roles, procedures, responsibilities, duties and requirements to effectively and jointly administer the MS4 Permit. The City of Reno is the lead entity under the 2004 Interlocal Agreement. A copy of the Interlocal Agreement is presented in Appendix B. The importance of maintaining this agreement is outlined in BMP Fact Sheet GOV-01, located in Section 6 of this document.
Although not a requirement of the new permit, in the review of legal authority it was recommended that the co-permittees re-evaluate the Interlocal Agreement every permit cycle. As new permit requirements are established and the monitoring program revised, there needs to be a clear understanding of commitments and responsibilities by jurisdiction. 2.5 Storm Water Monitoring
Section IV.C.1 of the new permit requires the co-permittees to include in the updated SWMP document an evaluation of “characterization data previously submitted and include additional data
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collected in the same manner, and evaluate whether existing data collection programs should be modified to improve characterization of storm water discharges, effects of BMPs, or ambient water quality”. Over the past decade, the SWPCC has been involved in monitoring the water quality of the Truckee River and its tributaries. The current monitoring efforts, existing data and future monitoring plans are discussed in this sub-section.
2.5.1 Current Monitoring Program
An extensive number of water quality studies and monitoring efforts have and continue to be conducted on the Truckee River and its tributaries. Although not formally a part of the SWMP, recently a Coordinated Monitoring Program (CMP) was established to identify all of the different agencies and groups that conduct various types of monitoring activities on the Truckee River. Groups collecting water quality or flow measurements, some of whom were signatories to the CMP (Truckee Meadows, 2010) are listed in Table 2-3.
Table 2-3. Agencies Currently Conducting Monitoring or Water Quality Studies on the Truckee River and Tributaries
Agency Purpose of Monitoring Truckee Meadows Water Reclamation Facility (TMWRF) CWA, NPDES Permit Nevada Division of Environmental Protection (NDEP) CWA, Identifying impaired waters Truckee Meadows Water Authority (TMWA) Safe Drinking Water Act compliance Truckee River Flood Management Authority (TRFMA) Monitor flow data Truckee Meadows Watershed Committee (TMWC) CWA, NPDES MS4 Permit Pyramid Lake Paiute Tribe (PLPT) Vigilance Desert Research Institute (DRI) Research Tahoe Truckee Sanitation District (T-TSA) NPDES Permit University of Nevada, Reno (UNR) Research United States Geological Survey (USGS) Monitor flow data
The motivation behind the CMP was the need for better data sharing and efficiencies among the resource management agencies and non-profit organizations involved in the general management and stewardship of the Truckee River. In 2010, these agencies and organizations developed and signed a memorandum of understanding (MOU) that sets goals for improving the exchange of river monitoring data and other related activities. Outlined in the MOU are specific goals for the development and maintenance of the CMP. They are:
1) Increasing efficiency and minimizing duplication of effort among the Parties; 2) Encouraging the Parties to utilize a central clearinghouse of technical and water-related information;
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3) Encouraging the Parties to develop robust data that may facilitate timely identification of potential problems with water quality or environmental degradation of the Truckee River, to the extent they have the authority and funding to do so; 4) Promoting the future protection of the Truckee River; and 5) Encouraging the Parties to share this information with each other, the public, and other interested parties. The main objectives of the CMP were to find efficiencies in sampling efforts, share data, and to facilitate a better understanding of health and processes in the Truckee River and its tributaries. Outlined in the CMP document (Truckee Meadows, 2010) are definitions and protocols to clarify procedures and nomenclature. Presented in the document is a general basis for data consolidation and format (metadata). Also provided in the document is information on what monitoring data is being conducted, by whom, and the frequency at which data is collected. The CMP sets forth a common monitoring site naming protocol and sampling and analysis definitions intended to clarify reporting procedures.
An important component of the CMP is the continued use of the existing Truckee River Information Gateway (TRIG, at http://truckeeriverinfo.org) for file and data management and information dissemination. TRIG is an ongoing project to provide water quality, hydrology, and biological data and other resources on the Truckee River and Truckee River watershed to all users. The TRIG website contains reports, data files, presentations, references, maps and images for use by all interested parties.
The monitoring program established by the SWPCC will continue as an independent program as required by the MS4 permit and not controlled or driven by the CMP.
Truckee Meadows Storm Water Quality Management Program Since 2003, storm event water quality samples have been collected as part of the overall Truckee Meadows Regional Storm Water Quality Management Program. Each October, a revised Sample Analysis Plan (SAP) is submitted to NDEP that outlines the general sampling program and approach. Described in the SAP are the tributaries sampled, sampling location, type (grab or composite), frequency and the parameters monitored.
Tributary grab samples are collected quarterly from 12 fixed sites on six tributaries of the Truckee River (Table 2-4). In general, the monitoring locations are located upstream and downstream of urban development for each tributary. Chalk Creek contains a single sampling site in the middle reach (perennial flow region). Samples are not collected in the upper reaches of Chalk Creek due to intermittent, ephemeral stream flow. Prior to 2010, the monitoring effort included the tributaries and sites listed in Table 2-4 with the exception of Alum Creek, Chalk Creek and Steamboat Creek at the Narrows.
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Table 2-4. SWMP 2010 Monitoring Site Summary Information Sampling Tributary Sampling Location Urban Area Frequency WQ Parameters Rhodes Rd Upstream 1. Steamboat Narrows Midstream Creek Clean Water Way Downstream Flow Rate (Q) Timberline Dr Upstream Total Nitrogen (TN) 2. Whites Creek Old Virginia Hwy Downstream Total Phosphorus (TP) Timberline Dr Upstream Total Suspended Solids (TSS) 3. Thomas Creek S. Meadows Pkwy Downstream Quarterly Total Dissolved Solids (TDS) 4. North Truckee Orr Ditch Upstream Temperature (Temp.) Drain Kleppe Ln. Downstream Specific Conductance (EC) pH 5. Chalk Creek Chalk Bluff Downstream Dissolved Oxygen (DO) Steamboat Canal Upstream 6. Alum Creek Truckee River Downstream
Tributary and storm event monitoring consists of both field and laboratory measurements. In the field, DO, pH, EC, water temperature and flow rate are measured and recorded. Grab (tributary) or composite (storm event) water samples are collected and analyzed for TDS, TSS, TP and TN (individual analyses of nitrate, nitrite and total Kjeldahl nitrogen (TKN), reported as total nitrogen) at a local, certified laboratory.
Storm event samples are collected using ISCO™ automatic samplers. One of the six tributaries listed in Table 2-4 is selected each year for storm event sampling. The selected tributary is sampled for one full year during storm events, with a minimum of two sampling events representing one wet season storm and one dry season storm, if possible. The tributary selected for storm water sampling events is identified each year in the Annual Report.
2.5.2 Evaluation of the Existing Characterization Data
For the past 7 years, the tributaries to the Truckee River have been monitored as part of the Truckee Meadows Regional Storm Water Quality Management Program. Data are available to the public on the TRIG website (www.truckeeriverinfo.org). Presented in Tables 2-5 and 2-6 is summary of the data, by tributary and location, of the data collected from March 2003 to September 2010.
Graphs of total nitrogen, total phosphorus and TSS concentrations in the samples from the North Truckee Drain, Steamboat Creek, Thomas Creek and Whites Creek are shown in Figures 2-1 through 2-4, respectively. Shown in each of the graphs are both the upstream site, above urban influence, as a dashed line, and the downstream site as a solid line. As can be seen in the figures, there are occasional spikes in all three parameters for unknown reasons, which appear to have some correlation with flow and season. Typically, there are lower concentrations of the three parameters found in the upstream sites with the exception of the NTD. A review of flow data for the NTD consistently shows higher flow volume at the downstream sampling location, indicating influx and dilution.
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Table 2-5. Summary of the Truckee Meadows RSQMP Monitoring Data, Laboratory Measurements
TSS (mg/L) TOT-P (mg/L) TOT-N (mg/L) Monitoring Site min max avg n min max avg n min max avg n North Truckee Drain at Kleppe Ln. 1 73 16 25 0.11 1.50 0.28 26 0.93 0.31 0.43 26 North Truckee Drain at Orr 3 252 38 25 0.09 0.57 0.24 26 1.00 5.90 2.89 26 Steamboat Canal at Clean Water Way 1 55 26 25 0.16 0.35 0.24 25 0.83 7.13 1.66 25 Steamboat Canal at Rhodes Rd. 1 78 9 24 0.04 0.38 0.13 26 0.30 1.57 0.65 26 Thomas Creek at South Meadows Pkwy 1 41 10 26 0.04 0.16 0.09 26 0.18 0.90 0.47 26 Thomas Creek at Timberline Dr. 1 14 5 25 0.04 0.08 0.06 25 0.10 0.50 0.24 26 Whites Creek at Old Virginia Hwy. 1 61 15 26 0.02 0.31 0.06 26 0.11 1.00 0.32 26 Whites Creek at Timberline Dr. 1 52 7 24 0.02 0.06 0.03 26 0.15 0.36 0.16 26
Table 2-6. Summary of the Truckee Meadows RSQMP Monitoring Data, Field Determinations
Temp (°C) Conductivity (mS/cm) pH Flow (cfs) Monitoring Site min max avg n min max avg n min max avg n min max avg n North Truckee Drain at Kleppe Ln. 5.1 20.7 13.4 22 0.58 1.27 0.87 22 7.1 8.3 7.7 22 0.0 54 13 26 North Truckee Drain at Orr 1.6 22.8 12.9 21 0.62 2.05 1.345 21 6.9 9.3 7.9 21 0.0 14 2.9 26 Steamboat Canal at Clean Water Way 0.2 23.3 14.3 21 0.09 1.19 0.62 21 7.9 9.0 8.2 21 0.0 72 31 26 Steamboat Canal at Rhodes Rd. 2.5 21.2 10.6 22 0.13 0.61 0.30 22 7.2 8.6 7.7 22 0.0 70 7.8 26 Thomas Creek at South Meadows Pkwy 0.1 22.3 10.8 20 0.02 0.17 0.12 20 7.1 8.7 7.6 20 0.0 11 2.2 26 Thomas Creek at Timberline Dr. 0.0 15.2 6.9 20 0.08 0.11 0.09 20 6.5 8.0 7.5 20 0.0 23 4.1 26 Whites Creek at Old Virginia Hwy. 0.0 18.0 9.3 20 0.06 0.77 0.14 20 6.7 8.1 7.5 20 0.0 15 2.9 26 Whites Creek at Timberline Dr. 0.2 14.8 5.6 20 0.05 0.10 0.07 20 6.1 12.1 7.1 20 0.0 13 4.0 26
Truckee Meadows Storm Water Management Program 2-13 Section 2 – Storm Water Management
North Truckee Drain Total Nitrogen 8.0
7.0 NTD at Orr (upstream)
6.0 NTD at Kleppe (downstream)
5.0
N/L) -
4.0
N (mg -
3.0 TOT
2.0
1.0
0.0 2003 2004 2005 2006 2007 2008 2009 2010 2011
North Truckee Drain Total Phophorus
1.4
1.2 NTD at Orr (upstream) NTD at Kleppe (downstream)
1.0
P/L) -
0.8 P (mg
- 0.6 TOT 0.4
0.2
0.0 2003 2004 2005 2006 2007 2008 2009 2010 2011
North Truckee Drain Total Suspended Solids 300
250 NTD at Orr (upstream) NTD at Kleppe (downstream) 200
150 TSS TSS (mg/L) 100
50
0 2003 2004 2005 2006 2007 2008 2009 2010 2011
Figure 2-1. North Truckee Drain Water Quality (Upstream and Downstream)
Truckee Meadows Storm Water Management Program 2-14 Section 2 –Storm Water Management
Steamboat Creek Total Nitrogen 8.0
7.0 Steamboat at Rhodes (upstream) 6.0 Steamboat at CWW (downstream)
5.0
N/L) -
4.0
N (mg -
3.0 TOT
2.0
1.0
0.0 2003 2004 2005 2006 2007 2008 2009 2010 2011
Steamboat Creek Total Phosphorus 0.5
0.4 Steamboat at Rhodes (upstream) Steamboat at CWW (downstream)
P/L) 0.3
- P (mg
- 0.2 TOT
0.1
0.0 2003 2004 2005 2006 2007 2008 2009 2010 2011
Steamboat Creek Total Suspended Solids 90
80 Steamboat at Rhodes (upstream) 70 Steamboat at CWW (downstream) 60
50
40 TSS TSS (mg/L) 30
20
10
0 2003 2004 2005 2006 2007 2008 2009 2010 2011
Figure 2-2. Steamboat Creek Water Quality (Upstream and Downstream)
Truckee Meadows Storm Water Management Program 2-15 Section 2 – Storm Water Management
Thomas Creek Total Nitrogen 2.0 1.8 Thomas Creek at Timberline (upstream) 1.6 Thomas Creek at SMP (downstream) 1.4
N/L) 1.2 -
1.0 N (mg
- 0.8 TOT 0.6 0.4 0.2 0.0 2003 2004 2005 2006 2007 2008 2009 2010 2011
Thomas Creek Total Phosphorus 0.5
0.4 Thomas Creek at Timberline (upstream) Thomas Creek at SMP (downstream)
P/L) 0.3
- P (mg
- 0.2 TOT
0.1
0.0 2003 2004 2005 2006 2007 2008 2009 2010 2011
Thomas Creek Total Suspended Solids 45
40 Thomas Creek at Timberline (upstream) 35 Thomas Creek at SMP (downstream) 30
25
20 TSS TSS (mg/L) 15
10
5
0 2003 2004 2005 2006 2007 2008 2009 2010 2011
Figure 2-3. Thomas Creek Water Quality (Upstream and Downstream)
Truckee Meadows Storm Water Management Program 2-16 Section 2 –Storm Water Management
Whites Creek Total Nitrogen 2.0 1.8 1.6 Whites Creek at Timberline (upstream) 1.4
N/L) 1.2 -
1.0 N (mg
- 0.8 TOT 0.6 0.4 0.2 0.0 2003 2004 2005 2006 2007 2008 2009 2010 2011
Whites Creek Total Phosphorus 0.5
Whites Creek at Timberline (upstream) 0.4 Whites Creek at OVH (downstream)
P/L) 0.3
- P (mg
- 0.2 TOT
0.1
0.0 2003 2004 2005 2006 2007 2008 2009 2010 2011
Whites Creek Total Suspended Solids 70 Whites Creek at Timberline (upstream) 60 Whites Creek at OVH (downstream)
50
40
30 TSS TSS (mg/L)
20
10
0 2003 2004 2005 2006 2007 2008 2009 2010 2011
Figure 2-4. Whites Creek Water Quality (Upstream and Downstream)
Truckee Meadows Storm Water Management Program 2-17 Section 2 – Storm Water Management
Truckee River As stated previously, numerous groups and agencies have monitored the water quality of the Truckee River for a variety of reasons. Two of the most extensive data sets of Truckee River water quality are those maintained by TMWRF and NDEP. Data sets are available on the TRIG website.
Presented in Figures 2-5 and 2-6 are a series of graphs showing average total nitrogen and total phosphorus concentrations in the Truckee River at Farad, Idlewild, E. McCarran, Vista and Lockwood. The sites are arranged from upstream to downstream. The Farad site is well upstream of urban influence while the Vista and Lockwood sites are below the TMWRF outfall, Steamboat Creek and the North Truckee Drain. The concentration of nitrogen and phosphorus in the Truckee River increases as the river progresses through the Truckee Meadows, illustrating the importance of the TMDL.
Storm Event Monitoring and Sampling As outlined in the SAP, prior to, during and following rain events, storm water samples are collected using automatic samplers. Automatic samples collect water samples, at regular intervals, into 24 discrete bottles. Based on the duration of the storm event, multiple bottle sets may be used (greater than 24 samples taken). During the storm event sampling, stream flow is measured and recorded using a portable level recorder (often correlated with stream gauge stations). Based on the tributary flow rate data, a storm hydrograph is developed. The hydrograph is then used to assist in the preparation of composite sample splits for water quality determinations. Composite samples representing the different regions of the hydrograph including the base flow, rising limb, peak discharge, falling limb and return are prepared from the sample bottles taken. Composite samples are then submitted to the analytical laboratory for TDS, TSS, TN and TP determinations. An example hydrograph and the composite sample split is shown in Figure 2-7.
A summary of the storm event sample results is presented in Table 2-7. A total of six rain event samples have been collected under this program to date. By nature, sampling rain events can be difficult and not all attempts to collect event samples have been completely successful over the past 8 years. Thomas Creek has been sampled during three different rain events, Whites Creek twice and the North Truckee Drain once. Each tributary has both an upper and lower reach sample. All storm event samples have data for the background water quality and the rising and peak regions of the hydrograph (see Figure 2-7 for an example). Some sample event s also included composite samples from the falling limb of the hydrograph.
As can be seen from the data in Table 2-7, the concentration of TDS in the storm event samples remains relatively unchanged during the rain event, and in some instances, actually decreases in concentration. The data show that the highest concentrations of TSS are often associated with the rising and peak portions of the hydrograph. The concentration of TN and TP in the storm event samples typically follows the concentration of TSS (nutrients associated with or bound to particulates).
Truckee Meadows Storm Water Management Program 2-18 Section 2 –Storm Water Management
1999 2000 1.00 1.00
0.75 Total-P 0.75
Total-N
0.50 0.50
Avg Conc. (mg/L) Conc.(mg/L) Avg Avg Conc. (mg/L) Conc.(mg/L) Avg 0.25 0.25
0.00 0.00 Farad Idlewild E. McCarran Vista Lockwood Farad Idlewild E. McCarran Vista Lockwood
2001 2002 1.00 1.00
0.75 0.75
0.50 0.50
Avg Conc. (mg/L) Conc.(mg/L) Avg Avg Conc. (mg/L) Conc.(mg/L) Avg 0.25 0.25
0.00 0.00 Farad Idlewild E. McCarran Vista Lockwood Farad Idlewild E. McCarran Vista Lockwood
2003 2004 1.00 1.00
0.75 0.75
0.50 0.50
Avg Conc. (mg/L) Conc.(mg/L) Avg Avg Conc. (mg/L) Conc.(mg/L) Avg 0.25 0.25
0.00 0.00 Farad Idlewild E. McCarran Vista Lockwood Farad Idlewild E. McCarran Vista Lockwood
Figure 2-5. Average Total Nitrogen and Total Phosphorus Concentration in the Truckee River by Sampling Location and Year (1999 – 2004)
Truckee Meadows Storm Water Management Program 2-19 Section 2 – Storm Water Management
2005 2006 1.00 1.00
0.75 Total-P 0.75
Total-N
0.50 0.50
Avg Conc. (mg/L) Conc.(mg/L) Avg Avg Conc. (mg/L) Conc.(mg/L) Avg 0.25 0.25
0.00 0.00 Farad Idlewild E. McCarran Vista Lockwood Farad Idlewild E. McCarran Vista Lockwood
2007 2008 1.00 1.00
0.75 0.75
0.50 0.50
Avg Conc. (mg/L) Avg Avg Conc. (mg/L) Conc.(mg/L) Avg 0.25 0.25
0.00 0.00 Farad Idlewild E. McCarran Vista Lockwood Farad Idlewild E. McCarran Vista Lockwood
2009 2010 1.00 1.00
0.75 0.75
0.50 0.50
Avg Conc. (mg/L) Conc.(mg/L) Avg Avg Conc. (mg/L) Conc.(mg/L) Avg 0.25 0.25
0.00 0.00 Farad Idlewild E. McCarran Vista Lockwood Farad Idlewild E. McCarran Vista Lockwood
Figure 2-6. Average Total Nitrogen and Total Phosphorus Concentration in the Truckee River by Sampling Location and Year (2005 - 2010)
Truckee Meadows Storm Water Management Program 2-20 Section 2 –Storm Water Management
Figure 2-7. Typical Storm Event Hydrograph Showing the Approach to Preparing Storm Event Composite Samples
Truckee Meadows Storm Water Management Program 2-21 Section 2 – Storm Water Management
Table 2-7. Storm Event Water Quality Results
Storm Event Hydrograph TDS TSS Total-P Total-N Date Sample Region (mg/L) (mg/L) (mg/L) (mg/L) Background 60 <2 <0.04 <0.3 Upper Whites Creek Rising 62 <2 <0.04 <0.3 Peak 74 <2 0.05 <0.3 10/6/2008 Background 71 12 0.07 0.3 Lower Whites Creek Rising 67 <2 0.07 0.4 Peak 66 <2 <0.04 <0.3 Background 72 <2 <0.04 <0.3 Rising 78 7 0.05 <0.3 Upper Whites Creek Peak 74 3 0.04 <0.3 Falling 75 4 0.05 0.3 3/3/2009 Background 72 <2 0.04 <0.3 Rising 74 236 0.56 1.8 Lower Whites Creek Peak 136 472 1.1 2.5 Falling 75 28 0.21 0.7 Background 95 10 0.07 0.4 Rising 91 9 0.07 0.3 Upper Thomas Creek Peak 90 8 0.06 <0.3 Falling 83 6 0.05 0.4 5/1/2009 Background 101 7 0.07 0.4 Rising 102 19 0.1 0.4 Lower Thomas Creek Peak 101 18 0.11 0.4 Falling 98 10 0.08 0.5 Background 96 13 0.08 0.2 J Rising 123 366 0.69 2.0 Upper Thomas Creek Peak 121 268 0.55 2.4 10/13/2009 Falling 108 47 0.18 0.8 Background 142 6 0.15 0.8 Lower Thomas Creek Rising 151 397 0.79 3.8 Peak 156 33 0.31 1.3 Background 101 14 0.08 0.4 Rising 106 5 0.07 0.2 Upper Thomas Creek Peak 107 8 0.07 0.3 Falling 105 8 0.08 0.3 12/17/2010 Background 103 3 0.06 0.3 Rising 113 63 0.22 0.7 Lower Thomas Creek Peak 155 117 0.62 2 Falling 146 48 0.44 1.4 Background 786 15 0.18 2.1 Rising 759 14 0.32 2.2 N. Truckee Drain at Peak 425 240 0.80 4.8 Kleppe Falling 525 120 0.53 3.9 10/5/2011 Background 792 30 0.26 2.4 Background 1560 31 0.31 3.9 N. Truckee Drain at Rising 1540 34 0.33 4.3 Orr Peak 931 153 0.64 5.9 Falling 1270 40 0.58 4.2
Truckee Meadows Storm Water Management Program 2-22 Section 2 –Storm Water Management
2.5.3 Future Monitoring Priorities
Each October 1 the co-permittees are required to submit a Storm Water Monitoring Plan to NDEP for the following calendar year. In developing the plan, the co-permittees are asked to “evaluate whether existing data collection programs should be modified to improve characterization of storm water discharges, effects of BMPs, or ambient water quality”. Ambient water quality has been well characterized over the past seven years.
Although independent of this program, an important enhancement to the upcoming monitoring plan is the recent award of grant funds for water quality monitoring efforts on the Truckee River. Staff from DRI, TMWRF, the Cities of Reno and Sparks, NDEP, PLPT, Washoe County and the Truckee River Flood Project, developed a proposal for an integrated water quality monitoring plan on the Truckee River. In September of 2011, the Truckee River Fund Advisory Board awarded the grant to DRI with the understanding of the need for stop-gap funding to support the most urgent Truckee River water quality monitoring needs threatened by budget cuts. The DRI will lead and coordinate project efforts.
As outlined in the BMP Fact Sheets MS4-03 (Dry Weather Monitoring) and MS4-04 (Wet Weather Monitoring), the needs and details of a monitoring program will be reviewed each year. The review process will include a discussion of ways to improve the monitoring program, characterization needs, permit requirements, and SWMP effectiveness assessments. Examples of discussion points include:
Goals and objectives of the monitoring plan Data need and gaps Data usefulness and desired assessments Sampling location and collection frequency Parameters to be measured Effort, cost and program utility Flow measurements
Based on recent SWPCC discussions and the need for data relating to land use and future storm water WLAs, future monitoring efforts will likely shift from tributary monitoring to storm water outfall and catchment monitoring. The recent acquisition of additional automatic samplers will assist in this monitoring effort shift. Based on permit emphasis, additional monitoring efforts may include illicit discharge and industrial monitoring, 303(d) listed constituents, and data collection in preparation of future storm water WLAs. Future sampling efforts may well be performed in coordination with other agencies to make good use of resources and avoid duplication of monitoring efforts.
Truckee Meadows Storm Water Management Program 2-23 Section 2 – Storm Water Management
2.6 Best Management Practices (BMPs)
The definition of what constitutes a BMP is quite broad. Storm water BMPs can be specific instructions and specifications for a single treatment device (e.g., a structural treatment control BMP) or an operational/procedural practice (non-structural BMP). The new permit defines BMPs as “schedules of activities, prohibitions of practices, maintenance procedures, and other management practices to prevent or reduce the pollution of waters of the United States. BMPs also include treatment, operating procedures, and practices to control runoff, spillage or leaks, sludge or waste disposal, or drainage from raw material storage.”
Presented in this sub-section are the permit requirements relating to BMPs, a summary of existing Truckee Meadows BMPs, the process used for selecting new BMPs, how new BMPs are incorporated and used, and an overview of the new BMPs identified for inclusion in this SWMP document.
2.6.1 Permit Requirements Relating to Storm Water BMPs
The new permit requires the co-permittees not only to identify existing and new storm water BMPs but to describe implementation details and regional applicability. Permit language pertaining to BMPs is summarized below.
In Section IV.A of the permit, Stormwater Management Program-General Requirements, are the following provisions:
“The updated SWMP shall describe any new priorities for implementing structural and non- structural BMPs for each of the following elements: Public Outreach and Education; Illicit Discharge and Detection; Industrial Facility Monitoring and Control; Municipal Operations (MS4 maintenance activities and good housekeeping practices), Post-Construction Stormwater Management Program for New Development and Significant Redevelopment, and a Construction Site BMP Program and Intergovernmental Coordination;” (IV.A.13)
“The updated SWMP shall identify the measurable goals for the new BMPs as appropriate, including the months and years in which the Permittees will undertake required actions.” (IV.A.6)
In Section IV.A.5 of the permit, SWMP General Requirements, is the following provision:
“The updated SWMP shall identify existing BMPs and any new BMPs that the Permittees or another entity will implement.” (IV.A.5)
In Section IV.F.3 of the permit, Post-Construction Storm Water Management Program for New Development and Significant Redevelopment, is the following provision:
Truckee Meadows Storm Water Management Program 2-24 Section 2 –Storm Water Management
“Describe how the Permittees will develop any additional structural and non-structural BMPs that will remain in effect after construction is complete and are effective and appropriate for the Truckee Meadows and its environment. The program will outline the selected BMP measures found effective and appropriate for the Truckee Meadows along with a summary and schedule for implementation in the MS4.” (IV.F.3.a.iii)
2.6.2 Existing Truckee Meadows Storm Water BMPs
Presently there are seven different storm water related manuals and handbooks for use in the Truckee Meadows. They are:
1) Truckee Meadows Regional Storm Water Quality Management Program (December, 2001) 2) Truckee Meadows Watershed Protection Manual (August, 2005) 3) Truckee Meadows Industrial and Commercial Storm Water Best Management Practices Handbook (February, 2007) 4) Truckee Meadows Structural Control Design Manual (April, 2007) 5) Truckee Meadows Low Impact Development Handbook (August, 2007) 6) Truckee Meadows Construction Site Best Management Practices Handbook (June, 2008) 7) Nevada Contractors Field Guide for Construction Site Best Management Practices (June, 2008) 8) Truckee Meadows Regional Drainage Manual (April, 2009) 9) Watershed Assessment for Tributaries to the Truckee River (annual document, Spring, 2002 through 2011)
Listed in these manuals are the storm water BMPs presently in use in the Truckee Meadows MS4 Permit Area. The format of the BMP descriptions varies with the handbook or manual, with some being more detailed than others. The BMPs from the above handbooks and manuals are listed in Tables 2-8 through 2-14. Altogether, there are over 200 existing storm water related BMPs for use in the Truckee Meadows.
Truckee Meadows Storm Water Management Program 2-25 Section 2 – Storm Water Management
Table 2-8. Storm Water BMPs listed in the Truckee Meadows Structural Control Design Manual Handbook BMP Number Title/Subject Truckee Meadows Structural SC-10 Roof Runoff Controls Control Design Manual, April SC-11 Efficient Irrigation 2007 SC-12 Storm Drain Labeling SC-20 Outdoor Material Storage SC-21 Outdoor Material Loading/Unloading SC-22 Fueling Areas SC-23 Outdoor Work, Maintenance and Wash Areas SC-24 Spill Prevention, Containment and Cleanup SC-25 Waste Handling and Disposal SC-30 Vehicle Wash Areas SC-31 Waste Handling Areas TC-10 Vegetative Swales TC-11 Vegetative Buffer Strips TC-20 Infiltration Trenches TC-21 Infiltration Basins TC-30 Landscape Detention TC-40 Sedimentation Basins TC-41 Sand Filter Basins TC-50 Storm Water Ponds TC-51 Storm Water Wetlands TC-60 Surface Sand Filter TC-61 Underground Sand Filter TC-62(a) Porous Pavement Detention TC-62(b) Open-Celled Block Paving TC-62(c) Open-Jointed Block Paving TC-62(d) Porous Concrete and Asphalt Pavement TC-62(e) Porous Turf TC-62(f) Porous Gravel TC-62(g) Open-Celled Plastic Grids TC-70 Oil and Water Separators MTC-10 Hydrodynamic Separators MTC-20 Wet Vaults MTC-30 Catch Basin Inserts MTC-40 Modular Wetlands MTC-50 Media Filtration Systems MTC-60 Landscape Filtration Systems MTC-70 Gross Solids Removal Device Notes: MTC = Manufactured Treatment Controls (Proprietary); TC = Treatment Controls (Public Domain); SC = Source Controls
Table 2-9. Storm Water BMPs listed in the Nevada Contractors Field Guide for Construction Site Best Management Practices Handbook BMP Number Title/Subject Nevada Contractors Field 1 Pre-Construction Planning Guide for Construction Site 2 Overview of Construction Phase Operations Best Management Practices 3 Diverting Upland Runoff around Exposed Soils (BMPs), June 2008 4 Protecting Soils with Vegetation, Mulch, and Binders 5 Using Silt Fence and Other Sediment Barriers 6 Protecting Slopes to Prevent Gullies 7 Protecting Culvert and Ditch Inlets and Outlets 8 Stabilizing Drainage Ditches 9 Installing Sediment Traps and Basins 10 Protecting Stream Channels, Wetlands, and Lakes 11 Maintaining & Closing Out Your Construction Project
Truckee Meadows Storm Water Management Program 2-26 Section 2 –Storm Water Management
Table 2-10. Storm Water BMPs listed in the Truckee Meadows Construction Site Best Management Practices Handbook Handbook BMP Number Title/Subject Truckee Meadows PL-1 Site Design Construction Site Best PL-2 Scheduling Management Practices PL-3 Phased Construction Handbook, June 2008 PL-4 Topsoil Reuse Update PL-5 Employee Training RC-1 Permanent Diversions RC-2 Temporary Diversion Berms & Ditches RC-3 Check Dams RC-4 Temporary Slope Drains EC-1 Preserving Existing Vegetation EC-2 Slope Terracing and Tracking EC-3 Mulching EC-4 Soil Binders EC-5 Wind Erosion and Dust Control EC-6 Rolled Erosion Control Products SC-1 Fiber Rolls SC-2 Brush and Rock Filters SC-3 Sand & Gravel Bag Barriers SC-4 Gravel Filter Berm SC-5 Silt Fences SC-6 Temporary Sediment Traps SC-7 Sediment Retention Basins SC-8 Construction Site Entrances & Exits SC-9 Construction Exit Tire Wash SC-10 Stabilized Construction Roadway SC-11 Synthetic Sediment Control Rolls SC-12 Compost Filter Berms & Socks DP-1 Temporary Stream Crossing DP-2 Stormdrain Outlet Protection DP-3 Stormdrain Inlet Protection DP-4 Catch Basin Filters GM-1 Water Conservation Practices GM-2 Stockpile Management GM-3 Solid & Demolition Waste Management GM-4 Dewatering Operations GM-5 Street & Surface Cleaning GM-6 Spill Prevention & Control GM-7 Vehicle & Equipment Cleaning GM-8 Vehicle & Equipment Maintenance & Fueling GM-9 Handling & Disposal of Concrete & Cement GM-10 Material Delivery, Handling, Storage & Use GM-11 Paints & Liquid Materials GM-12 Pavement Construction Management GM-13 Liquid Waste Management GM-14 Sanitary/Septic Waste Management GM-15 Landscaping Management GM-16 Contaminated Soil & Water Management GM-17 Hazardous Waste Management GM-18 Illicit Discharges & Connections Detection & Reporting GM-19 Drilling & Pile Driving Operations GM-20 Material & Equipment Use Over Water GM-21 Structure Demolition/Removal Over or Adjacent to Water GM-22 Temporary Batch Plants Notes: GM = General Site and Materials Best Management Practices; DP = Drainage Way Protection Best Management Practices; SC = Sediment Control Best Management Practices; EC = Erosion Control Best Management Practices; RC = Runoff Control Best Management Practices; PL = Planning Best Management Practices
Truckee Meadows Storm Water Management Program 2-27 Section 2 – Storm Water Management
Table 2-11. Storm Water BMPs listed in the Truckee Meadows Industrial and Commercial Storm Water Best Management Practices Handbook Handbook BMP Number Title/Subject Truckee Meadows Industrial IC-1 Vehicle & Equipment Repair and Maintenance and Commercial Storm IC-2 Vehicle Fueling Stations Water Best Management IC-3 Vehicle Body Repair, Painting, Plating and Powder Coating Practices Handbook, IC-4 Vehicle and Truck Washing Stations February 2007 IC-5 Vehicle Recycling IC-6 Scrap Material Recycling IC-7 Stone Cutting and Fabrication IC-8 Concrete Ready-Mix Operations IC-9 Mineral Testing Laboratories IC-10 Restaurants and Fast Food Facilities IC-11 Commercial Animal Handling IC-12 Manufacturing and Processing IC-13 Commercial Printing IC-14 Mobile Fueling & Lubrication Operations IC-15 Mobile Vehicle and Equipment Washing Operations IC-16 Mobile Surface Cleaning Operations IC-17 Mobile Carpet Cleaning Operations IC-18 Mobile Food Service Operations SC-1 Erosion and Sediment Control SC-2 Recordkeeping SC-3 Outdoor Loading and Unloading Areas SC-4 Vehicle Parking/Storage Area Maintenance SC-5 Building, Grounds and Landscaping Maintenance SC-6 Building Repair and Construction Notes: SC = Source Controls; IC = General Industry Category BMP Guide Sheets
Table 2-12. Storm Water BMPs listed in the Truckee Meadows Low Impact Development Handbook Handbook BMP Number Title/Subject Truckee Meadows Low 3.0.0 Landscape Detention Impact Development 3.0.1 Tree Box Filters Handbook, August 2007 3.0.2 Storm Water Planters 3.1 Swales and Buffer Strips 3.2 Porous Paving Systems 3.2.0 Porous Concrete and Asphalt 3.2.1 Permeable Pavers 3.3 Rainwater Catchment Systems 3.4 Green Roofs 3.5.0 LID Parking Lot Design 3.5.1 LID Street and Road Design 3.5.2 LID Driveway Design 3.5.3 LID Sidewalks and Bike Paths 3.6.0 Impervious Surface Reduction and Disconnection 3.6.1 Soil Amendments 3.6.2 Roof Leader Disconnection 3.6.3 Pollution Prevention and Good Housekeeping 3.6.4 Storm Water Education 3.7.0 Extended Detention Basins 3.7.1 Infiltration Trenches and Basins 3.7.2 Storm Water Ponds and Wetlands 3.8.2 Storm Water in Crawl Spaces 3.8.3 Mosquito Breeding
Truckee Meadows Storm Water Management Program 2-28 Section 2 –Storm Water Management
Table 2-13. Storm Water BMPs listed in the Truckee Meadows Regional Drainage Manual Handbook BMP Number Title/Subject Truckee Meadows Regional 303.3 Local Master Planning Drainage Manual, April 2009 303.4 Drainage Improvements 303.5 Drainage Planning Submittal and Review 303.6 Flood Plain Management 303.7 Storm Runoff Detention 303.8 Storm Runoff Retention 303.9 Water Quality and Construction Activities 303.10 Drainage Facilities and Maintenance 304.1 Storm Water Management Technology 304.2 Design Strom Events 304.3 Storm Runoff Determination 304.4 Streets 304.5 Culverts and Bridges 304.6 Flood Proofing 304.7 Alluvial Fans 305 Irrigation Facilities 305.1 Drainage Interaction 305.2 Irrigation Ditches 306 Preservation of Natural Drainage Ways 600 Rainfall 700 Storm Runoff 800 Open Channels 804.2 Natural Channel Morphology and Response 804.3 Natural Channel Design 804.4 Natural Channel Stabilization 805.2 Permanent Unlined Channels 805.3 Non-Reinforced Channels 805.4 Wetland Bottom Channels 900 Storm Sewer System 1306.4 Low Flow and Basin Dewatering 1306.5 Embankment Protection 1306.7 Local Detention Basin Siting Guidelines 1401 Debris Control Structures and Basins 1401.3 Debris Racks 1401.6 Debris Dams and Basins
Truckee Meadows Storm Water Management Program 2-29 Section 2 – Storm Water Management
Table 2-14. Storm Water BMPs listed in the Truckee Meadows Regional Storm Water Quality Management Program, December 2001
Handbook BMP Number Title/Subject Truckee Meadows Regional IC-1 Interagency/MOU for Intergovernmental Control Storm Water Quality IC-2 Programmatic for Intergovernmental Control Management Program, PO-1 Programmatic for Public Outreach December 2001 PO-2 Complaints/Reporting for Public Outreach PO-3 Web Site for Public Outreach PO-4 Public Outreach for Public Outreach MO-1 Programmatic for Municipal Operations MO-2 Technical Manual for Municipal Operations MO-3 Training for Municipal Operations MO-4 Database for Municipal Operations MO-5 Special Studies for Municipal Operations SWM-1 Interlocal Agreement/MOU for Storm Water Discharge Monitoring SWM-2 Programmatic for Storm Water Discharge Monitoring SWM-3 Technical Manual for Storm Water Discharge Monitoring SWM-4 Training for Storm Water Discharge Monitoring SWM-5 Database for Storm Water Discharge Monitoring SWM-6 Monitoring for Storm Water Discharge Monitoring SWM-7 Website for Storm Water Discharge Monitoring SWM-8 Public Outreach for Storm Water Discharge Monitoring SWM-9 Special Studies for Storm Water Discharge Monitoring LU-1 Programmatic for Land Use Planning LU-2 Regulatory for Land Use Planning LU-3 Training for Land Use Planning LU-4 Public Outreach for Land Use Planning LU-5 Special Studies for Land Use Planning SC-1 Programmatic for Structural Controls SC-2 Regulatory for Structural Controls SC-3 Technical Manual for Structural Controls SC-4 Training for Structural Controls SC-5 Database for Structural Controls SC-6 Complaints Reporting for Structural Controls SC-7 Web Site for Structural Controls SC-8 Public Outreach for Structural Controls CSD-1 Programmatic for Construction Site Discharge CSD-2 Regulatory for Construction Site Discharge CSD-3 Technical Manual for Construction Site Discharge CSD-4 Training for Construction Site Discharge CSD-5 Database for Construction Site Discharge CSD-6 Complaints Reporting for Construction Site Discharge CSD-7 Web Site for Construction Site Discharge IDDE-1 Programmatic for Illicit Discharge Detection and Elimination IDDE-2 Regulatory for Illicit Discharge Detection and Elimination IDDE-3 Technical Manual for Illicit Discharge Detection and Elimination IDDE-4 Training for Illicit Discharge Detection and Elimination IDDE-5 Database for Illicit Discharge Detection and Elimination IDDE-6 Mapping for Illicit Discharge Detection and Elimination IDDE-7 Complaints Reporting for Illicit Discharge Detection and Elimination IDDE-8 Web Site for Illicit Discharge Detection and Elimination IDDE-9 Public Outreach for Illicit Discharge Detection and Elimination IDDE-10 Special Studies for Illicit Discharge Detection and Elimination IP-1 Programmatic for the Industrial Program IP-2 Regulatory for the Industrial Program IP-3 Technical Manual for the Industrial Program IP-4 Training for the Industrial Program IP-5 Database for the Industrial Program IP-6 Monitoring for the Industrial Program IP-7 Complaints Reporting for the Industrial Program IP-8 Web Site for the Industrial Program Notes: IC = Intergovernmental Control; PO = Public Outreach; MO = Municipal Operations; SWM = Storm Water Discharge Monitoring; LU = Land Use Planning; SC = Structural Controls; CSD = Construction Site Discharge; IDDE = Illicit Discharge Detection and Elimination; IP = Industrial Program
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2.6.3 Process for Selecting New BMPs
The science and technology of storm water quality improvement is constantly evolving. Since the onset of the storm water program in the Truckee Meadows, the co-permittees have reviewed and approved numerous new BMPs to meet the MEP standard. The method used for approving new BMPs has been via guidance manual updates. When the manuals are being updated, new BMPs are evaluated and reviewed for inclusion by SWPCC members, consultants, engineers, contractors, city and county staff. The co-permittees will continue to review and update the storm water guidance manuals and handbooks approximately every five years.
The need for new BMPs can arise from an observed deficiency, the quest for efficiency, cost reduction or from new regulations. In the event that an existing BMP (or collection of BMPs) is insufficient or inadequate, the co-permittees are obligated to develop new or modified practices. New permit regulations also drive the need for new BMPs. As a component of this document, the requirements listed in the new Permit were matched up with existing program BMPs. In the event of a gap, a new BMP was developed or an existing BMP enhanced (Section 6).
The SWPCC proposes to identify and develop new structural and non-structural BMPs for use in the Truckee Meadows using the following methods or tasks.
1) Track the need and observed deficiencies with existing BMPs 2) Consider new BMPs observed at trade shows, in publications and via vendors 3) Compare Truckee Meadows BMPs to other comparable MS4 permit holders 4) Search EPA’s website and other BMP clearinghouse web-based resources 5) Solicit user input from local BMP designers, contractors and maintenance personnel
A BMP Fact Sheet for the Identification of New Storm Water BMPS (MS4-05) is included in Section 6. Outlined in this Fact Sheet are the rationale, objectives, measurable goals and a schedule of implementation for new programmatic storm water BMPs.
2.6.4 SWMP Incorporation of New BMPs
The incorporation of new structural control BMPs into the SWMP is typically a two-step process; a managerial and technical review of the proposed new control by the SWPCC; and a vetting step with developers, planners, design engineers, contractors and city and county inspection and maintenance staff. For a new BMP, a description and implementation schedule will first be included in the annual report until inclusion in the appropriate handbook.
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2.6.5 Use and Selection of BMPs
When selecting a single or multiple storm water BMPs for a particular application, factors like physical site constraints, reducing volume and peak runoff, and the removal of targeted pollutants are some of the primary considerations. Additional considerations include implementation and maintenance costs, aesthetic benefits (or liability), and public safety issues. Given this site specific complexity, no single formula or prescription for the precise selection of BMPs is practicable.
A series of structural control design and selection matrices were included in the April 2007 update of the Structural Controls Design Manual to assist site designers with the proper selection of public domain treatment controls. Matrix 1 indicates what types of treatment controls are applicable for a given type of land use. Matrix 2 provides a list of the physical design constraints that must be considered when siting public domain treatment controls. Matrix 3 indicates the potential storm water management capabilities of the treatment controls in addition to storm water quality enhancement. Matrix 4 provides a comparison of the community and environmental factors, such as ease of maintenance, safety considerations, and the potential for habitat creation, that are associated with public domain structural treatment controls. Matrix 5 provides a general summary of the expected pollutant removal effectiveness of the treatment controls presented in Section 6. More detailed information on pollutant removal effectiveness is provided on the individual BMP fact sheets presented in Section 6 of the Structural Design Manual.
Also useful as a BMP selection tool are the Design Guidance Worksheets for structural treatment controls and LID practices available on the TMstormwater.com website. The worksheets utilize Excel spreadsheets with write-protected design criteria to assist with selection, sizing and design review of proposed structural treatment controls and LID practices in the Truckee Meadows.
2.6.6 Organization of New BMPs
To address the new permit requirements, a series of “BMP Fact Sheets” were prepared and included in Section 6 of this document. Most of the BMP Fact Sheets document existing practices, however, several new (priority) practices have been identified. Some existing BMPs have been enhanced with new components and measurable goals. Altogether, there are 45 programmatic BMPs, 33 of which are existing, 6 new and 6 considered enhanced.
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Presented in this section are the details relating to how various permit requirements for the seven required program elements are addressed in the Truckee Meadows. Section IV.A.13 of the new permit requires BMPs for seven different program elements. They are:
1. Public Outreach and Education (EDU) 2. Illicit Discharge and Detection (IDDE) 3. Industrial Facility Monitoring and Control (IND) 4. Municipal Operations (MUNI) 5. Post-Construction Stormwater Management Program for New Development and Significant Redevelopment (POST) 6. Construction Site BMP Program (CONST) 7. Intergovernmental Coordination (GOV & MS4)
With the exception of intergovernmental coordination, each of the elements has a corresponding permit section with specific requirements. In this section, each of the required elements and associated practices will be discussed. 3.1 Public Outreach and Education (EDU)
Described in this sub-section is the public outreach and educational component of the Truckee Meadows SWMP. The motivation behind this element is to educate the general population and businesses about storm water considerations, pollution and alternative practices to reduce the contaminants entering the Truckee River.
3.1.1 Permit Requirements (EDU)
Section IV.D of the permit contains the following public outreach and education requirements:
IV.D. Public Outreach and Education IV.D.1 The updated SWMP covering the duration of this permit shall describe public outreach and education to reduce the discharge of pollutants to the MEP; IV.D.2 The updated SWMP shall contain information about the different types of educational material distributed during environmental fairs or other public outreach events; and IV.D.3 The updated SWMP shall describe educational activities, public information activities, and other appropriate activities; IV.D.4 The updated SWMP shall describe how the Permittees will inform developers, contractors, operators, and agency staff about upcoming educational and training workshops on construction site erosion and sediment control and construction
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materials management sponsored by industry groups, professional organizations and public agencies; IV.D.5 The updated SWMP shall describe how the Permittees will inform local government officials, municipal development personnel, architects, and engineers about water quality problems associated with urban runoff and the requirements for meeting NPDES laws and program goals for properly managing the quality of urban runoff.
3.1.2 Practices (EDU)
Eight different EDU BMP Fact Sheets have been developed to document the practices related to public outreach and education. Listed in Table 3-1 are the BMPs used in the Truckee Meadows to satisfy the public outreach and education requirements of the permit. Most of the permit requirements are paired with multiple BMPs. The EDU BMPs developed are briefly summarized below along with the BMP objectives. A full description of the BMP, the joint responsibilities and the implementation schedule can be found in Section 6.
Public Outreach and Education – Typical Events (EDU-01) SWPCC staff and volunteers participate in community events to provide outreach each year. Primary storm water and watershed messaging is intended to educate about storm water, and that community activities, choices and behavior within the watershed often have unintended effects on surface water quality. Staff and volunteers strive to inform local citizens, school children, politicians, commercial and industrial managers and developers about BMPs intended to improve water quality, source control, illicit discharges and watershed protection. This is accomplished through staffing information booths providing printed information and active displays, providing coordinated opportunities to reach the community both in their daily lives and at community events. Outreach includes hosting or sponsoring training workshops related to BMP implementation for the development community, technical seminars and may include school visits.
BMP Objectives:
1. Educate the public about storm water quality, BMPs and protecting the Truckee River
2. Develop and distribute storm water quality informational materials at local events
3. Mitigate storm water pollution by providing community with clear, non-point source pollution prevention messaging
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Table 3-1. Permit Requirements and Activities for Public Outreach and Education Permit BMP Section Permit Requirement Number Title IV.D.1 “The updated SWMP covering EDU-01 Public Outreach and Education - Typical of Events the duration of this permit shall EDU-02 Public Outreach and Education Materials describe public outreach and EDU-03 Storm Drain Labeling Program education to reduce the EDU-04 Partnerships and Affiliations discharge of pollutants to the EDU-05 Regional Program Website - TMStormwater.com MEP” EDU-06 Truckee River Watershed Map Tool EDU-07 Demonstration Projects - Typical EDU-08 Workshop and Training Seminars IND-02 Commercial and Industrial Storm Water Outreach IV.D.2 “The updated SWMP shall EDU-01 Public Outreach and Education - Typical of Events contain information about the EDU-02 Public Outreach and Education Materials different types of educational EDU-03 Storm Drain Labeling Program material distributed during EDU-04 Partnerships and Affiliations environmental fairs or other EDU-05 Regional Program Website - TMStormwater.com public outreach events” EDU-06 Truckee River Watershed Map Tool EDU-07 Demonstration Projects - Typical EDU-08 Workshop and Training Seminars IV.D.3 “The updated SWMP shall EDU-01 Public Outreach and Education - Typical of Events describe educational activities, EDU-02 Public Outreach and Education Materials public information activities, EDU-03 Storm Drain Labeling Program and other appropriate EDU-04 Partnerships and Affiliations activities” EDU-05 Regional Program Website - TMStormwater.com EDU-06 Truckee River Watershed Map Tool EDU-07 Demonstration Projects - Typical EDU-08 Workshop and Training Seminars IV.D.4 “The updated SWMP shall EDU-01 Public Outreach and Education - Typical of Events describe how the Permittees EDU-02 Public Outreach and Education Materials will inform developers, EDU-04 Partnerships and Affiliations contractors, operators, and EDU-05 Regional Program Website - TMStormwater.com agency staff about upcoming EDU-07 Demonstration Projects - Typical educational and training EDU-08 Workshop and Training Seminars workshops on construction site erosion and sediment control and construction materials management sponsored by industry groups, professional organizations and public agencies” IV.D.5 “The updated SWMP shall EDU-01 Public Outreach and Education - Typical of Events describe how the Permittees EDU-02 Public Outreach and Education Materials will inform local government EDU-04 Partnerships and Affiliations officials, municipal development EDU-05 Regional Program Website - TMStormwater.com personnel, architects, and EDU-07 Demonstration Projects - Typical engineers about water quality EDU-08 Workshop and Training Seminars problems associated with urban runoff and the requirements for meeting NPDES laws and program goals for properly managing the quality of urban runoff”
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Public Outreach and Educational Materials (EDU-02) The SWPCC utilizes a wide variety of outreach items, from printed handouts to re-usable shopping bags to educate the public about storm water pollution. Printed materials are typically fact sheets which define storm water and describe practices that homeowners can adopt to reduce pollution and minimize runoff. Items like printed water bottles and re-usable shopping bags help to keep storm water protection reminders in the foreground of daily activities. Different materials are used at different venues. Materials used in the past include:
UNR Cooperative Extension/NEMO-prepared fact sheets on residential BMPs including management of pet waste, recreational activities, household chemicals, fertilizers and pesticides, landscape and garden, automobile care, general non-point source pollution prevention, water conservation, and Low Impact Development Sunscreen, visors, beach balls, water bottles, post-it™ notes, re-usable shopping bags, temporary tattoos- all with the Truckee Meadows Storm Water logo Banners and posters printed on laminated canvas, for use at booths and tables Use of the “Enviroscape” Watershed diorama in classrooms, booths, and hands-on presentations
BMP Objectives:
1. Continue to develop and use a variety of venue-appropriate items to educate the public 2. Identify the most effective materials and methods for conveying the storm water pollution prevention messages
Storm Drain Labeling Program (EDU-03) The Truckee Meadows storm drain labeling program includes volunteer and municipal efforts, and serves to educate citizens that anything littered or spilled in the streets such as motor oil, antifreeze, pet waste and other pollutants drain directly to waterways through the storm drain system. The volunteer portion of the program encourages individuals, citizen groups and schools to steward the river by spray painting stencils (or using a similarly effective labeling technique) with “No Dumping, Drains to River” above storm drains within the MS4 permit area. The municipal portion of the program includes the use of pre-stamped drop inlet covers with a similar message, focused on new development or redevelopment throughout the region. By educating the public, changed behavior may reduce contaminant loading to the Truckee River. By working together with partners and volunteer groups (e.g. Keep Truckee Meadows Beautiful, the University of Nevada, Reno[UNR]), the SWPCC can be more efficient in gathering and organizing volunteer events, while maximizing community education results.
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BMP Objectives:
1. Reduce pollutant discharge to the storm drains through increasing public awareness 2. Develop an effective storm water message for our community 3. Build stewardship by facilitating a volunteer program for service learning opportunities 4. Install permanent storm drain labeling by utilizing pre-stamped drop inlet covers
Partnerships and Affiliations (EDU-04) The SWPCC shares goals with numerous organizations, groups and agencies in the Truckee Meadows. Through collaboration and partnerships, the SWPCC can influence public awareness of storm water pollution and reduce pollutant transport to the MEP. Joint efforts are expected to better utilize expertise, technical and economic resources, and reach a much wider audience. There have been Memorandums of Understanding (Truckee River Coordinated Monitoring Program) and Interlocal Agreements (Storm Water, Watershed Protection and grant project contracts) between some of these agencies, formalizing cooperative relationships, and others have been more informal and based upon opportunities we find throughout the region. In this BMP, the SWPCC acknowledges and formalizes the importance of working collaboratively with various partners.
Examples of current partners and affiliations are:
University of Nevada, Reno (UNR) UNR Cooperative Extension (UNCE) U.S. Fish and Wildlife Service (USFWS) Nevada Department of Wildlife (NDOW) Nonpoint Education for Municipal Officials (NEMO) Nevada Desert Research Institute (DRI) Association of General Contractors (AGC) Builders Association of Northern Nevada (BANN) Nevada Department of Transportation (NDOT) Nevada Division of Environmental Protection (NDEP) Keep Truckee Meadows Beautiful (KTMB) Washoe County School District (WCSD) The Nature Conservancy (TNC) Truckee River Flood Management Authority (TRFMA) Sierra Nevada Concrete Association American Society of Civil Engineers (ASCE) Truckee River Watershed Council Truckee River Yacht Club Washoe County Environmental Health, Air Quality branch Nevada Land Conservancy Nevada Water Resources Association (NWRA) American Public Works Association (APWA)
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BMP Objectives:
1. Maintain the existing relationships with partners and look for shared opportunities to continue education efforts and reduce pollution within the MS4 permit area to the MEP 2. Remain in contact with the partners, educating them on our programmatic strengths, and facilitate collaboration for pollution mitigation and natural resource protection
Regional Program Website www.tmstormwater.com (EDU-05) The City of Reno hosts and maintains the website www.tmstormwater.com, which provides comprehensive information about the Truckee Meadows Regional Storm Water Management Program. Information on the website includes:
What is storm water? Information about the storm drain system and preventing storm water pollution Hotline information Glossary of Terms Truckee River Watershed Information, link to the Watershed Map Tool, link to the City of Reno Watershed Mapserver (GIS) Design guidance manuals for developers and planners, embedded as documents Construction BMP handbook and Commercial/Industrial BMP handbook, embedded with purchase sites referenced Scheduled trainings and upcoming events on news page Information on demonstration projects Best Management Practices pages for various industries Best Management Practices pages for residents Storm Water Permit Coordinating Committee and regulatory information Household hazardous waste
BMP Objectives:
1. Provide a single location for complete storm water program information 2. Be a clearinghouse for BMPs and TM SWMP-related documents 3. Provide information to the public relating to storm water and the Truckee River 4. Provide mechanism for public input
Truckee River Watershed Map Tool (EDU-06) The City of Reno developed an interactive web based map tool to educate and inform the citizens of the Truckee Meadows about their local watersheds. The interactive map tool was designed to be intuitive, non-technical, and easy for all audiences to use, regardless of GIS training. The target audience includes the entire public with a focus on middle and high school students.
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Classes have been offered to educators by City of Reno staff to demonstrate the capabilities and information contained within the interactive map tool. Previous classes have been attended by community members (teachers, students and Sierra Nevada Journeys staff) interested in learning more about the interactive map and using it in the classroom. The interactive map can be easily accessed through a link on the City of Reno’s website, by visiting www.tmstormwater.com, or directly through http://watershed.reno.gov/.
BMP Objectives:
1. Educate the public about creeks in their neighborhood, encouraging them to explore and ultimately steward the watershed 2. Inform the public about the interconnection of neighborhood drainages to the larger Truckee River, management practices, and our water supply 3. Provide the Truckee Meadows educational community with a practical online mapping tool for use by students and teachers at http://watershed.reno.gov
Demonstration Projects – Typical (EDU-07) Demonstration projects serve to inform local government officials, developers, architects, engineers, and the public about specific water quality problems and solutions. In the past, the SWPCC has participated in several different types of storm water treatment demonstration projects. Most have been grant funded (319(h) and/or Truckee River Fund) with matching funds or in-kind efforts coming from the co-permittees. These projects educate the public and technical sectors and increase the scientific understanding of storm water treatment in our local area. Projects conducted include Low Impact Development and structural controls projects, watershed restoration projects, water quality treatment on a 303(d) listed waterway, and Coordinated Monitoring Program efforts.
Past demonstration projects include:
The McKinley Arts & Cultural Center LID Demonstration Project (historical site, retrofit, rain garden and pervious concrete parking lot installation) Chalk Creek Watershed Assessment and Constructed Sulfate-Reducing Wetland Virginia Street Tree Box Filters Oxbow Bend Park bank stabilization Truckee River Coordinated Monitoring Program
The SWPCC will continue to look for demonstration project opportunities within the Truckee Meadows. Where possible, results of the demonstration projects will be incorporated into training, educational materials and regional BMPs.
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BMP Objectives:
1. Increase the understanding of storm water quality issues in the Truckee Meadows 2. Demonstrate to the public – homeowners, engineering community, and construction industry - on-site storm water treatment techniques 3. Support Low Impact Development practices through education and demonstration
Workshop and Training Seminars (EDU-08) The SWPCC sponsors or promotes educational and training workshops and seminars each year for both internal and external audiences. Internal audiences include local government officials, municipal development personnel, public works engineers and inspectors. Workshops and training seminars for this target audience are geared towards providing information about water quality related issues associated with urban runoff, the MS4 permit requirements, illicit discharges, 303(d) listings, sanitary sewer exfiltration, and the SWMP program goals. As new MS4 permit requirements are implemented, this venue allows for continued training of personnel who are responsible for ensuring compliance with storm water permit requirements. External audiences include developers, contractors, operators, and local engineers. Workshops and training seminars for this target audience is geared towards providing information on subjects like construction site erosion and sediment control, materials management and BMPs. External training and workshops are often jointly sponsored by industry groups and professional organizations with SWPCC support.
Workshop and training seminar announcements are provided through:
Posting notices on the TMstormwater.com website Publication in AGC, ASCE and BANN newsletters Flyers sent by the co-permittees through mailing lists or email
Training and workshops can include PowerPoint presentations, handouts of storm water related or permit literature, handouts of manuals such as Nevada Contractors Field Guide for Construction Site Best Management Practices, and open discussion forums.
BMP Objectives:
1. Provide effective dissemination of storm water related issues and MS4 permit requirements to government agency personnel and the development community 2. Improve awareness and compliance, through training, which will lead to improved water quality in the MS4 permit area
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3.2 Illicit Discharge Detection and Elimination (IDDE)
Described in this sub-section are the control measures to eliminate or reduce the illegal dumping of harmful substances into the storm drain system and other discharge of non-storm water associated with illicit connections. The motivation behind this element is to protect water quality through IDDE programs that encourage the collection of household wastes, minimize the threat from spills, encourage good housekeeping practices, and eliminate exfiltration of water from the sanitary sewer into the storm sewer.
3.2.1 Permit Requirements (IDDE)
Section IV.G of the permit contains the following requirements related to IDDE:
IV.G. Illicit Discharge and Detection IV.G.1 The updated SWMP shall include a description of a program, including a schedule, to detect and remove illicit discharges and improper disposal into the MS4. The program shall include: IV.G.1.a A description of a program, including inspections, to implement and enforce an ordinance, orders or similar means to prevent all types of illicit discharges to the MS4. Non-stormwater discharges, as defined in Part I.B.2.b, shall only be addressed where such discharges are identified by the Permittee as substantial contributors of pollutants to the Permittee’s MS4; IV.G.1.b A description of procedures to conduct on-going field screening activities during the life of this permit, including areas or locations that will be evaluated by such field screens; IV.G.1.c Field screening protocol to investigate dry weather flows that would indicate when an illicit discharge may be present, and when follow-up investigation will be required; IV.G.1.d A description of procedures to be followed to investigate portions of the MS4 that, based on the results of the field screen, or other appropriate information, indicate a reasonable potential of containing illicit discharges or other sources of non- stormwater; IV.G.1.e A description of procedures to prevent, contain, and respond to spills that may discharge into the MS4; IV.G.1.f A description of a program to facilitate public reporting of the presence of illicit discharges or water quality impacts associated with discharges from MS4s; IV.G.1.g A description of educational activities, public information activities, and other appropriate activities to facilitate the proper management and disposal of used oil and toxic materials; and IV.G.1.h An assessment of whether the procedures otherwise implemented in response to this section are sufficient to identify instances of exfiltration from the sanitary sewer to the storm sewers, and if not, a description of additional activities to be undertaken to control exfiltration.
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3.2.2 Practices (IDDE)
A large number of programmatic BMPs in place in the Truckee Meadows have an IDDE component to them. Five specific IDDE BMP Fact Sheets have been developed to document the practices unique to the IDDE program. Many of the outreach and education programs, storm drain labeling efforts, industrial outreach and inspection activities all relate to some extent to IDDE. Listed in Table 3-2 are the BMPs used in the Truckee Meadows to collectively satisfy the IDDE requirements of the permit. All of the IDDE permit requirements are paired with multiple BMPs. The five IDDE BMPs developed are briefly summarized below along with the BMP objectives. A full description of the BMPs, the joint responsibilities and the implementation schedule can be found in Section 6.
Table 3-2. Permit Requirements and Activities for Illicit Discharge and Detection Permit BMP Section Permit Requirement Number Title IV.G.1.a A description of a program, EDU-01 Public Outreach and Education - Typical of Events including inspections, to EDU-02 Public Outreach and Education Materials implement and enforce an EDU-03 Storm Drain Labeling Program ordinance, orders or similar EDU-05 Regional Program Website - TMStormwater.com means to prevent all types of EDU-06 Truckee River Watershed Map Tool illicit discharges to the MS4. EDU-08 Workshop and Training Seminars IDDE-01 Illicit Discharge Report and Response Database IDDE-02 Spill Control and Prevention IDDE-03 IDDE Corrective Action and Follow up Protocols IDDE-04 Sanitary and Storm Sewer Inspection Program IDDE-05 Household Hazardous Waste Program IND-01 Commercial and Industrial Stormwater Inspections IND-02 Commercial and Industrial Stormwater Outreach and Education IND-03 Housekeeping – Commercial/Industrial IND-04 Commercial/Industrial Facility Inventory IND-05 Industrial and Commercial Stormwater BMP Handbook MUNI-01 Storm Drain and Channel Maintenance MUNI-04 Pesticide, Herbicide and Fertilizer Application Management - Internal MUNI-05 Staff Training – Operations and Maintenance - Internal CONST-01 Construction Site Inspections GOV-01 Intergovernmental Coordination GOV-02 Municipal Codes and Ordinances GOV-03 Complaint Hotline GOV-05 Code Enforcement MS4-01 Outfall, Channel and Tributary Inspections and Assessments MS4-02 MS4 Mapping MS4-03 Monitoring - Dry Weather MS4-04 Monitoring - Wet Weather IV.G.1.b A description of procedures EDU-08 Workshop and Training Seminars to conduct on-going field IDDE-04 Sanitary and Storm Sewer Inspection Program screening activities during IND-01 Commercial and Industrial Stormwater Inspections the life of this permit, IND-03 Housekeeping – Commercial/Industrial including areas or locations MUNI-03 Maintenance of City and County Facilities that will be evaluated by CONST-01 Construction Site Inspections such field screens MS4-01 Outfall, Channel and Tributary Inspections and Assessments MS4-02 MS4 Mapping MS4-03 Monitoring - Dry Weather MS4-04 Monitoring - Wet Weather
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IV.G.1.c Field screening protocol to IDDE-03 IDDE Corrective Action and Follow up Protocols investigate dry weather IDDE-04 Sanitary and Storm Sewer Inspection Program flows that would indicate IND-01 Commercial and Industrial Stormwater Inspections when an illicit discharge may MS4-01 Outfall, Channel and Tributary Inspections and Assessments be present, and when MS4-02 MS4 Mapping follow-up investigation will MS4-03 Monitoring - Dry Weather be required IV.G.1.d A description of procedures GOV-01 Intergovernmental Coordination to be followed to investigate IDDE-03 IDDE Corrective Action and Follow up Protocols portions of the MS4 that, based on the results of the field screen, or other appropriate information, indicate a reasonable potential of containing illicit discharges or other sources of non-stormwater IV.G.1.e A description of procedures EDU-01 Public Outreach and Education - Typical of Events to prevent, contain, and EDU-08 Workshop and Training Seminars respond to spills that may IDDE-01 Illicit Discharge Report and Response Database discharge into the MS4 IDDE-02 Spill Control and Prevention IDDE-03 IDDE Corrective Action and Follow up Protocols IDDE-04 Sanitary and Storm Sewer Inspection Program IDDE-05 Household Hazardous Waste Program IND-01 Commercial and Industrial Stormwater Inspections IND-02 Commercial and Industrial Stormwater Outreach and Education IND-03 Housekeeping – Commercial/Industrial GOV-03 Complaint Hotline MS4-01 Outfall, Channel and Tributary Inspections and Assessments MS4-02 MS4 Mapping MS4-03 Monitoring - Dry Weather IV.G.1.f A description of a program EDU-01 Public Outreach and Education - Typical of Events to facilitate public reporting EDU-02 Public Outreach and Education Materials of the presence of illicit EDU-03 Storm Drain Labeling Program discharges or water quality EDU-05 Regional Program Website - TMStormwater.com impacts associated with GOV-03 Complaint Hotline discharges from MS4s IV.G.1.g A description of educational EDU-01 Public Outreach and Education - Typical of Events activities, public information EDU-02 Public Outreach and Education Materials activities, and other EDU-03 Storm Drain Labeling Program appropriate activities to EDU-04 Partnerships and Affiliations facilitate the proper EDU-05 Regional Program Website - TMStormwater.com management and disposal of GOV-03 Complaint Hotline used oil and toxic materials IDDE-05 Household Hazardous Waste Program IV.G.1.h An assessment of whether EDU-08 Workshop and Training Seminars the procedures otherwise IDDE-01 Illicit Discharge Report and Response Database implemented in response to IDDE-04 Sanitary and Storm Sewer Inspection Program this section are sufficient to MS4-01 Outfall, Channel and Tributary Inspections and Assessments identify instances of MS4-03 Monitoring - Dry Weather exfiltration from the sanitary MS4-06 Annual MS4 Effectiveness Assessment sewer to the storm sewers, and if not, a description of additional activities to be undertaken to control exfiltration.
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Illicit Discharge Report and Response Database (IDDE-01) As part of the regional program to detect and remove illicit discharges and prevent improper disposal, the co-permittees currently maintain separate databases relating to IDDE activities. These databases may be both electronic and paper, listing actions, activities and instances of illicit discharges within the MS4 permit area. An important component of each database is a schedule listing field screening activities, inspections and dry weather monitoring events. Any locations of known or potential IDDE “hot-spots” (areas having the potential to be substantial contributors of illicit pollutants to the MS4 permit area) and the frequency of inspection are listed in the file. When reports are received by the co-permittees, or there is an indication (from field staff or analytical results) that some form of illicit discharge may be present, immediate action taken, as well as the required follow-up, will be entered in to the databases for that agency.
Sparks (Environmental Control), Reno (Environmental Control), and Washoe County (Environmental Health) currently have individual databases for management and tracking of IDDE. Under agreement, these three agencies collaborate on IDDE responses, depending upon location and the nature of the material discharged. The co-permittees follow the Truckee Meadows Water Reclamation Facility (TMWRF) procedure for spill response. The feasibility of creating a unified illicit discharge reporting and response data base and protocol will be considered. This collective database may eventually be placed on an ftp site. Each jurisdiction will be able to access the file and make updates to scheduling, inspections and follow-up.
BMP Objectives: 1. Develop a consistent database and response system for agencies working on IDDE efforts within the MS4 permit area 2. Improve storm water runoff quality through the reduction of illicit discharges
Spill Control and Prevention (IDDE-02) Controlling spills and preventing the release of toxic and/or hazardous materials is critical to the health and safety of the population and aquatic resources within the MS4 permit area. Good spill prevention practices rely on the right equipment, materials, training and site design and containment. An existing written BMP for spill control and prevention can be found in the Truckee Meadows Structural Controls Design Manual (SC-24). Businesses and industries that store, transport and use larger quantities of hazardous materials are required by State and Federal law to prepare spill control and cleanup plans. Spill control is also a part of facility SWPPPs. The co- permittees have ordinances and codes intended to prevent and contain spills and require immediate notification of spills. Codes allow right-of-entry for regular inspections. A hotline is maintained for spill reporting (see GOV-03). Additional information pertaining to spill control and prevention can be found in the Industrial & Commercial Storm Water BMP Handbook (IND-05) and the LID manual (POST-03).
The co-permittees will reduce the likelihood of spills through ordinances, design review and planning, requirement of containment, inspections, BMPs and education and outreach (IND-02).
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The first responders to chemical spills are typically firefighters, police officers or Environmental Control officers. The local HazMat team is dispatched to all significant spill events within the Truckee Meadows. Once an assessment is made, City or County personnel may be called in to clean-up, oversee and monitor clean-up efforts. Industries or responsible parties may be required to utilize the services of a private spill response and clean-up company. Each of the co-permittees will conduct inspections and plan reviews for spill control within their own jurisdictions, enforcing their own ordinances and codes. The SWPCC will continue education/outreach programs and update the reference materials to ensure that the latest procedures to prevent, contain, and respond to spills, are provided.
BMP Objectives:
1. Maintain an effective spill control program to prevent the release of substances potentially harmful to the waters within the MS4 permit area 2. Maintain a spill reporting hotline and the ability to respond and mitigate spills
IDDE Corrective Action and Follow-Up Protocols (IDDE-03) The co-permittees have a strong commitment to reducing and eliminating illicit discharges. The co- permittees have an existing program to detect and remove illicit connections, discharges and mitigate improper disposal and reduce spills into the waters of the MS4 permit area. The IDDE program goal is to prevent, locate, and correct illicit discharges. When evidence of current or past illicit discharges is found (through monitoring and sampling, outfall, channel and sewer maintenance activities, hotline tips or routine site inspections, etc.), corrective action is taken to mitigate the discharge. Correction actions are instance and site specific, but typically involve education, clean-up and future mitigation measures. Follow-up is required to ensure that clean-up and mitigation efforts are adequate to protect the waters of the Truckee Meadows.
Once an illicit discharge is reported, appropriate City or County staff will be dispatched to investigate. The investigation stage involves defining the issue, tracing the source, describing the event, when it occurred, possible sample collection, taking photographs, delineating the area affected and when possible, identifying the responsible party. Since three different jurisdictions are responsible, no standardized data sheet or step-wise procedure is followed. Certain types of discharges (e.g., toxins and volatiles) will have a higher priority of response and may involve other agencies (i.e., HazMat, NDEP, USFWS, etc.). To date, illicit discharge events have been minor in nature. Generally, corrective actions involve notification, mandating clean-up, education and voluntary compliance. Enforcement actions are taken only if voluntary compliance is not obtained. City and County staff are tasked with documentation of all investigations, follow-up actions and inspections to insure that the designated mitigation steps and prescribed clean-up steps are followed.
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BMP Objectives:
1. Mitigate known illicit discharges (through clean-up, education and enforcement) 2. Follow-up on known events to ensure the situation is rectified and the potential for future occurrences is minimized 3. Implement and enforce IDDE ordinances within Truckee Meadows
Sanitary and Storm Sewer Inspection Program (IDDE-04) Both sanitary and storm sewer systems are routinely inspected by the jurisdictions as part of their asset management and inflow and infiltration (I/I) programs. Crews inspect, monitor and maintain thousands of linear feet of collection systems each year. The MS4 permit specifically requires procedures and assessments related to exfiltration (i.e., water from the sanitary sewer entering the storm sewer system via cross connections, breakage, leaks or overflows) and a description of activities to control exfiltration. The co-permittees routinely model the sewer collection system and pumping (lift) requirements to minimize sanitary sewer overflows. Additional training will be provided (by the SWPCC or designee) to the inspection staff to recognize instances or likely circumstances of exfiltration and illicit discharges into the storm sewer system.
BMP Objectives:
1. Train staff to look for, recognize, report and remediate exfiltration and illicit discharges 2. Control and prevent wastewater from entering the storm water collection system 3. Minimize the potential for sewage to enter the waterways of the MS4 permit area
Household Hazardous Waste Program (IDDE-05) Many products found in homes contain chemicals potentially harmful to both people and the environment and can cause water quality degradation if disposed of improperly. Common hazardous household products include:
Cleaning products: oven cleaner, floor wax, furniture polish, drain cleaner, and spot remover Car care and maintenance: motor oil, battery acid, gasoline, car wax, engine cleaner, antifreeze, degreaser, radiator flush, and rust preventative Home improvement products: paints, preservatives, strippers, brush cleaners, and solvents Other products labeled toxic, flammable, corrosive, or containing lye, phenols, petroleum distillates, solvents, etc. Prescription drugs that may be disposed into the sanitary sewer system
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e-waste: circuit boards, monitors, computers, televisions, batteries
When residents need to dispose of the products listed above, the SWPCC assists with the facilitation of open collection days and educates the public on proper disposal methods (as an alternative to being dumped into the storm or sanitary sewer, gutters, waterways, vacant or desert lands, etc.).
The SWPCC participates in various local programs that aim to reduce non-point source pollution from the illegal dumping of household and hazardous waste. These efforts are provided by local agencies and non-profits, including Keep Truckee Meadows Beautiful, Washoe County District Health Department, and Green Up affiliates to offer primarily educational and public information activities serving to emphasize to the citizens that household hazardous wastes must be disposed of properly. The SWPCC has participated in the medical waste pickup program along with the Washoe County Health Department and has participated in the KTMB-managed Illegal Dumping Task Force. The SWPCC has offered trainings for staff who encounter unsafe substances during work activities, including Parks and Public Works staff. The curriculum included storm water, personal safety, and hazardous waste trainings, and was co-taught by City of Reno and Washoe County District Health staff.
BMP Objectives:
1. Support regional efforts to reduce household hazardous waste dumping by increasing awareness 2. Provide information about household hazardous waste disposal programs including materials accepted, locations, and hours of operation
3.3 Industrial Facility Monitoring and Control (IND)
Described in this sub-section are the practices used to improve storm water runoff water quality from commercial and industrial facilities. The co-permittees developed a guidance document, Industrial and Commercial Storm Water BMP Handbook, in February 2007. Within the MS4 permit area, commercial and industrial facilities have a greater likelihood of having larger quantities of potentially toxic and harmful chemicals on site. The motivation behind this programmatic element is to establish practices and controls to protect the waterways from harmful substances potentially in commercial and industrial runoff.
3.3.1 Permit Requirements (IND)
Section IV.H of the permit contains the following requirements:
IV.H. Industrial Facility Monitoring and Control IV.H.1 The updated SWMP shall include a description of a program to monitor and control pollutants in stormwater discharges to MS4s from municipal landfills, hazardous
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waste treatment, disposal and recovery facilities, industrial facilities that are subject to section 313 of title III of the Superfund Amendments and Reauthorization Act of 1986, and industrial facilities that the municipal permit applicant determines are contributing a substantial pollutant loading to the MS4. The program shall include the following components: IV.H.1.a Identify priorities and procedures for inspections and establishing and implementing control measures for such discharges; IV.H.1.b Each Permittee shall develop and maintain an inventory of the facilities identified in part IV.H.1. The inventory shall list the facilities by specific categories and list the minimum inspection frequency for each category of facilities; IV.H.1.c Each Permittee shall provide a list of the inventoried facilities to NDEP by October 1, 2010. Each year thereafter for the life of this permit, each Permittee shall provide to NDEP by October 1 of that year, an updated list of the facilities inventoried during that year; and IV.H.1.d Describe a Monitoring Program for stormwater discharges associated with the industrial facilities identified in this section, to be implemented during the term of the Permit in accordance with the monitoring programs defined in Part V.A.
3.3.2 Practices (IND)
Five specific IND BMP Fact Sheets have been prepared to document the practices used in the Truckee Meadows for commercial and industrial facilities. These controls include inspection, monitoring, housekeeping, facility inventories and a guidance document. Listed in Table 3-3 are the BMPs to collectively address the IND requirements of the permit. The five IND BMPs developed are briefly summarized below along with the BMP objectives. A full description of the BMPs, the joint responsibilities and the implementation schedule can be found in Section 6.
Commercial and Industrial Storm Water Inspections (IND-01) The co-permittees each have an existing commercial/industrial inspection program. Environmental Control (or equivalent department) reviews new and existing business license applications when the license is applied for or during the renewal process. This review allows Environmental Control (EC) to examine, inspect, and permit applicable facilities to ensure implementation of BMPs to reduce and prevent pollutants from industrial and commercial sites from entering the municipal separate storm sewer system.
The co-permittees individually conduct commercial and industrial site inspections within their own jurisdictions enforcing their own ordinances and codes. Inspections normally occur if a complaint is received, when a new or renewal business license application is submitted and thereafter during scheduled inspections of permitted commercial/industrial users. Deficiencies are addressed immediately through the applicant performing corrective actions, EC Permit modification, issuance of a Supplemental Inspection Form, Notice of Violation and/or Citation. Follow-up inspections are then conducted where appropriate to confirm correction of deficiencies.
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Table 3-3. Permit Requirement and Activities for Industrial Facility Monitoring and Control Permit BMP Section Permit Requirement Number Title IV.H.1 The updated SWMP shall EDU-08 Workshop and Training Seminars include a description of a IND-01 Commercial and Industrial Stormwater Inspections program to monitor and control IND-02 Commercial and Industrial Stormwater Outreach and Education pollutants in stormwater IND-03 Housekeeping – Commercial/Industrial discharges to MS4s from IND-04 Commercial/Industrial Facility Inventory municipal landfills, hazardous IND-05 Industrial and Commercial Stormwater BMP Handbook waste treatment, disposal and MS4-01 Outfall, Channel and Tributary Inspections and Assessments recovery facilities, industrial MS4-02 MS4 Mapping facilities that are subject to MS4-03 Monitoring - Dry Weather section 313 of title III of the MS4-04 Monitoring - Wet Weather Superfund Amendments and Reauthorization Act of 1986, and industrial facilities that the municipal permit applicant determines are contributing a substantial pollutant loading to the MS4. The program shall include the following components: IV.H.1.a “Identify priorities and EDU-08 Workshop and Training Seminars procedures for inspections and IND-01 Commercial and Industrial Stormwater Inspections establishing and implementing IND-02 Commercial and Industrial Stormwater Outreach and Education control measures for such IND-05 Industrial and Commercial Stormwater BMP Handbook discharges” MS4-01 Outfall, Channel and Tributary Inspections and Assessments IV.H.1.b “Each Permittee shall develop IND-04 Commercial/Industrial Facility Inventory and maintain an inventory of the facilities identified in part IV.H.1. The inventory shall list the facilities by specific categories and list the minimum inspection frequency for each category of facilities” IV.H.1.c “Each Permittee shall provide a IND-04 Commercial/Industrial Facility Inventory list of the inventoried facilities to NDEP by October 1, 2010. Each year thereafter for the life of this permit, each Permittee shall provide to NDEP by October 1 of that year, an updated list of the facilities inventoried during that year” IV.H.1.d “Describe a Monitoring Program IND-01 Commercial and Industrial Stormwater Inspections for stormwater discharges IND-04 Commercial/Industrial Facility Inventory associated with the industrial MS4-01 Outfall, Channel and Tributary Inspections and Assessments facilities identified in this MS4-02 MS4 Mapping section, to be implemented MS4-03 Monitoring - Dry Weather during the term of the Permit in MS4-04 Monitoring - Wet Weather accordance with the monitoring programs defined in Part V.A.”
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BMP Objectives:
1. Inspect commercial and industrial sites to verify proper site BMPs are in place 2. Create and issue Environmental Control Permits based on facility-specific commercial/industrial site needs 3. Enforce ordinances and document action
Commercial and Industrial Storm Water Outreach and Education (IND-02) At least once a year the SWPCC jointly sponsors a training session pertaining to commercial and industrial storm water best management practices. BMPs intended to improve water quality through source control measures, good housekeeping, spill control and illicit discharges, local codes and ordinances and the new permit are covered in the training sessions. Participants will be provided a copy of the Truckee Meadows Commercial and Industrial Storm Water BMP Manual. Target audiences are the owners, operators, facility site directors and their environmental control staff. Training sessions are typically co-sponsored by NDEP.
BMP Objectives:
1. Educate the commercial and industrial sector about storm water quality, BMPs and applicable codes and ordinances 2. Improve water quality through outreach and education
Housekeeping – Commercial/Industrial (IND-03) Good housekeeping is considered a source control measure that entails the proper handling, storage, maintenance, upkeep, stewardship, sweeping, washing and containment of materials to prevent the accidental discharge of contaminants into receiving water bodies. Good housekeeping is identified as a “minimum control measure” in the EPA Phase II Final Rule for the NPDES Stormwater Program (1999). The co-permittees have adopted codes and ordinances that require the use of good housekeeping practices in exterior areas such that storm water runoff would not contact pollutant sources.
Industrial and commercial BMPs associated with good housekeeping principles can be found in the Truckee Meadows Industrial and Commercial Storm Water BMP Handbook and the Truckee Meadows Structural Controls Design Manual. These practices pertain to the specific facilities listed in the 2010 Truckee Meadows MS4 permit (i.e., municipal landfills, hazardous waste treatment, disposal and recovery facilities, industrial facilities). Some of the good housekeeping BMPs described in these two documents apply to outdoor loading and unloading areas; vehicle parking/storage area maintenance; building, grounds and landscaping maintenance; building repair and construction; outdoor material storage, outdoor material loading/unloading; fueling areas;
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outdoor work, maintenance and wash areas; spill prevention, containment and cleanup; waste handling and disposal. The reader in encouraged to review the BMPs in the above listed documents for a full description of commercial/industrial housekeeping practices.
When City or County inspectors conduct routine inspections of commercial and industrial facilities, the review of housekeeping practices are a major task (IND-01). The use of the complaint hotline for the reporting of poor housekeeping is encouraged (GOV-03). The guidance manuals will be reviewed every five years.
BMP Objectives:
1. Reduce and control potential discharges of pollutants into the MS4 permit area through the widespread implementation of good housekeeping practices 2. Disseminate information pertaining to commercial/industrial housekeeping practices via the promotion and distribution of guidance manuals
Commercial/Industrial Facility Inventory (IND-04) The rationale for maintaining an inventory of certain commercial and industrial facilities within the MS4 permit area is to know what is located where and facilitate the early detection and elimination of discharges to the storm water collection system from higher risk locations. The co-permittees currently maintain an inventory of industries within the MS4 permit area; however, Section IV.H.1 of the MS4 Permit specifically requires a program to inventory, monitor and control pollution from four specific classes of industrial facilities. They are:
1. Industrial Facilities Subject to Section 313 of Title II of SARA - facilities that are subject to Section 313 of Title III of the Superfund Amendments and Reauthorization Act of 1986 (SARA) 2. Municipal Landfills 3. Hazardous Waste Treatment, Disposal and Recovery Facilities - facilities that are subject to the Resource Conservation and Recovery Act (RCRA) 4. Other Facilities Identified by Permittees - facilities that the municipal permit applicant determines are contributing a substantial pollutant loading to the municipal storm sewer system. This category of facilities is to be identified through inspections of facilities identified in illicit discharge and detection inspections, pretreatment inspections, storm water complaints, and agency referrals.
The co-permittees have reviewed the industrial operations within the MS4 permit area and have concluded there are no facilities that meet the above criteria and have such a letter on file with NDEP stating this. An inventory of industrial facilities is maintained by each jurisdiction. New industries that start-up within the MS4 permit area will be evaluated with respect to the permit-
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BMP Objectives:
1. Maintain an inventory of industries located within the MS4 permit area 2. Conduct reviews of permits and business licenses to identify operations that may fall into the permit referenced categories 3. In the event that such an operation starts up within the MS4 permit area, the location and type of permit-regulated industries will be incorporated into the inventory of industrial operations maintained by Environmental Control (or equivalent department) for each entity 4. In the event of listed facility start-up, use this inventory to focus inspection, IDDE and monitoring efforts
Industrial and Commercial Storm Water BMP Handbook (IND-05) In February 2007, the SWPCC released the Truckee Meadows Industrial and Commercial Storm Water Best Management Practices Handbook. The purpose of the handbook is to provide general information about typical storm water pollutant sources and controls for local industrial and commercial land uses. Summarized in the handbook are the applicable permit regulations, permissible non-storm water discharges and an overview of storm water BMPs for industrial and commercial sites. City, County and State’s legal authority to conduct inspections, require BMPs, and conduct enforcement actions (if necessary) is summarized in the handbook. Also included are a number of General Industry Category BMP Guide Sheets for the primary industrial and commercial business types in the Truckee Meadows. The Industrial and Commercial Storm Water BMP Handbook is an important component of the MS4 Storm Water Management Program.
BMP Objectives:
1. Promote, publicize and distribute the manual to commercial and industrial facilities within the MS4 permit area 2. Keep the information in the manual current
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3.4 Municipal Operations (MUNI)
Described in this sub-section are the control measures associated with municipal operations. The motivation behind this programmatic element is to establish practices and controls to reduce storm water pollution generated from municipal activities conducted in public right-of-ways, roadways, open spaces, and at publicly operated facilities
3.4.1 Permit Requirements (MUNI)
Section IV.E of the permit contains the following requirements:
IV.E. MS4 Maintenance Activities (Municipal Operations) IV.E.1 The updated SWMP shall include a description of BMPs expected to reduce pollutants from stormwater runoff from commercial and residential areas that are discharged into the MS4. This section shall also discuss the basis for the expected reduction of pollutant loads and a proposed schedule for implementing such controls. At a minimum, the description shall include: IV.E.1.a A description of maintenance activities and a maintenance schedule to reduce pollutants in discharges from MS4s; IV.E.1.b A description of practices for operating and maintaining public streets, roads and highways and procedures for reducing the impact on receiving waters of discharges from the MS4s; IV.E.1 .c A description of a program to evaluate, monitor and reduce pollutants in runoff from operating or closed municipal landfills or other treatment, storage or disposal facilities for municipal waste; IV.E.1.d A description of a program to evaluate and reduce pollutants in discharges from MS4s associated with the application of pesticides, herbicides, and fertilizers by each of the Permittees.
3.4.2 Practices (MUNI)
Five specific MUNI BMP Fact Sheets have been prepared to document the practices used in the Truckee Meadows related to municipal operations. Programmatic BMPs developed include storm drain maintenance, street sweeping, maintenance of City and County owned facilities, pesticide application and staff training. Listed in Table 3-4 are the BMPs to collectively address the MUNI requirements of the permit. The five MUNI BMPs developed are briefly summarized below along with the BMP objectives. A full description of the BMPs, the joint responsibilities and the implementation schedule can be found in Section 6.
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Table 3-4. Permit Requirements and Activities for Municipal Operations Permit BMP Section Permit Requirement Number Title IV.E.1.a “A description of maintenance MUNI-01 Storm Drain and Channel Maintenance activities and a maintenance MUNI-02 Street Sweeping schedule to reduce pollutants in MUNI-03 Maintenance of City and County Owned Facilities discharges from MS4s” MUNI-04 Pesticide, Herbicide and Fertilizer Application Management – Internal MUNI-05 Staff Training – Operations and Maintenance - Internal IV.E.1.b “A description of practices for MUNI-02 Street Sweeping operating and maintaining public streets, roads and highways and procedures for reducing the impact on receiving waters of discharges from the MS4s” IV.E.1.c “A description of a program to IND-01 Commercial and Industrial Stormwater Inspections evaluate, monitor and reduce IND-04 Commercial/Industrial Facility Inventory pollutants in runoff from operating or closed municipal landfills or other treatment, storage or disposal facilities for municipal waste” IV.E.1.d “A description of a program to MUNI-04 Pesticide, Herbicide and Fertilizer Application Management - evaluate and reduce pollutants Internal in discharges from MS4s associated with the application of pesticides, herbicides, and fertilizers by each of the Permittees”
Storm Drain and Channel Maintenance (MUNI-01) City and County maintenance programs are conducted to ensure that storm water infrastructure function effectively and as designed. Generally, most storm drains, inlets, culverts and major storm channels are inspected and cleaned at least annually by City or County personnel. Maintenance and cleaning are key components for a structural treatment device to retain its designed water quality benefit. Channels and conveyance ditches must be free of excess debris in order to retain hydraulic functionality. As crews are out working in the MS4 permit area, they are also looking for and reporting any evidence of illicit discharges.
The co-permittees have an existing storm drain and channel maintenance program in place. Actual maintenance activities and schedules vary by jurisdiction and budget. The co-permittees strive to keep drop inlets and screens clean. Typically drop inlets and screens are cleaned a minimum of once per year (generally in the fall) or as required by local factors. Storm sewers are flushed on an as needed basis. Inspections are typically informal, requiring staff to report observed structural deficiencies or evidence of illicit discharges.
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BMP Objectives:
1. Maintain the WQ and hydraulic performance of storm water infrastructure throughout the MS4 area through routine cleaning, maintenance and inspection 2. Reduce pollutants to the MEP by removing trash, debris and sediment in storm drains, channels and other significant storm water conveyance systems 3. Inspect the storm drain infrastructure for structural deficiencies and evidence of illicit discharges and report issues to Environmental Control
Street Sweeping (MUNI-02) Streets, roads, highways and parking lots accumulate significant amounts of contaminants that potentially contribute to the pollutant loading to surface waters. Studies have shown that the adverse impacts on water quality from sediment, debris, trash, road salt, and trace metals can be reduced by street sweeping. Street sweeping can also improve the aesthetics of municipal roadways, control dust and decrease the accumulation of pollutants in catch basins. The co- permittees have an existing street sweeping program which will be continued. As part of the existing program, area streets and parking lots are swept on a regular schedule. Sweeping and cleaning of State highways and freeways is the responsibility of NDOT, which has a separate statewide MS4 permit with street sweeping procedures and goals.
Each jurisdiction has its own existing street sweeping program including procedures and schedules. Typically, all streets within the MS4 permit area are swept on a monthly basis. Furthermore, major streets are swept within four days following a storm event in which sand and salt were applied, per the Washoe County Air Quality mandate. Material collected by street sweepers is taken to transfer stations, quantified, and then hauled to the municipal landfill.
BMP Objective:
1. Reduce the pollutants in storm water runoff from streets and highways to the MEP through an effective street sweeping program
Maintenance of City and County Owned Facilities (MUNI-03) The co-permittees own and operate a variety of facilities, including sidewalks, parks, maintenance yards, office complexes, parking lots and storage areas. Included in City and County owned facilities are storm water collection systems, storm water conveyance ditches, storm water infrastructure, structural storm water BMPs; manufactured (proprietary) treatment controls or public domain treatment controls such as detention ponds, tree box filters or vegetated swales. Facilities may be the responsibility of different departments within the jurisdiction such as public works or parks. Proper maintenance of co-permittee-owned facilities is important to maintain function, reduce contaminant sources and protect water quality to the MEP.
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The types of facilities and responsible parties are diverse, necessitating intra-departmental communication and coordination to track and provide sufficient maintenance. Maintenance activities may include inspections, mowing, sweeping, good housekeeping and cleaning. Some procedures are unique to the specific facilities and site conditions. Some facilities are cleaned on a regular schedule while others are on an as-needed basis. Maintenance is the responsibility of the individual jurisdictions. Structural storm water BMPs are cleaned and inspected each year at a minimum. Larger corporation and maintenance yards implement and maintain BMPs to minimize pollutants of concern from leaving the site. Facility SWPPPs, spill prevention plans and/or operating permits may impose conditions on the frequency of inspection, maintenance or practices.
BMP Objective:
1. Maintain City and County owned facilities or features using practices that reduce the contaminants in storm water runoff to the MEP
Pesticide, Herbicide and Fertilizer Application Management – Internal (MUNI-04) Pesticides, herbicides and fertilizers can be harmful to both people and the environment and may lead to water quality degradation if used or applied improperly. In response to Section IV.E.1.d of the 2010 Truckee Meadows MS4 Permit, the SWPCC will investigate standardizing a management program for co-permittee staff within the Truckee Meadows. Although each jurisdiction currently has programs in place to minimize the impacts of these products on water quality, it may be desirable to develop consistent standard operating procedures and require certifications to address the proper use and handling of these chemicals within the permit area. It is anticipated that the protocol will consist of the following components:
Environmental conditions required for application Product selection and label use Pollution prevention and runoff reduction Applicator training and documentation Product storage, cleanup and waste disposal
The co-permittees will maintain their respective programs pertaining to the safe and efficient use and application of fertilizers, pesticides and herbicides. In the coming years, the co-permittees will assess existing practices, available or applicable certification programs, and refine recording procedures. Depending on resources and the results of the assessment, the co-permittees may develop a set of standard operating procedures (SOPs) for the use and application of pesticide, herbicide and fertilizer by staff within the MS4 permit area.
For pesticide and herbicide application, the Nevada Department of Agriculture currently has a certification and training program for applicators. The Nevada Landscape Association (NLA) provides annual training and certification in irrigation, turf maintenance, and ornamental plant maintenance. It is possible that these training and certification programs may serve the purpose
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required in this BMP. If not, a co-permittee based training and SOP program may need to be developed. Program development for internal staff may require two or more years. In the event that the application of fertilizers, pesticides and herbicides is contracted out, this BMP will be re- visited.
BMP Objectives:
1. Reduce the potential for pesticides, herbicides, and fertilizers to enter waterways through consistent management by training and providing clear procedures 2. Improve pesticide, herbicide and fertilizer application safety and target efficiency
Staff Training – Operations and Maintenance – Internal (MUNI-05) Operations and Maintenance (O&M) staff (or similar field personnel) from the co-permittee agencies are responsible for cleaning inlets, catch basins, storm sewers, culverts, bar screens, and detention basins. They are also responsible for mowing and cleaning grassy swales, maintaining flood channels, repairing side slopes, vacuuming pervious concrete, and numerous other actions vital to the functionality of most structural storm water BMPs. Co-permittee agencies organize periodic informal training sessions for City and County staff to ensure that maintenance of storm water features is performed correctly.
The co-permittees have an existing program for the education and training of municipal operations staff with respect to the maintenance of storm water BMPs and other storm water issues that staff may encounter. Where necessary, additional training will be provided (by the SWPCC or designee) to inform staff about the new permit, City/County ordinances and reporting. Training will include subjects like IDDE, sanitary sewer infiltration, exfiltration and cross-connection, and evidence of non-storm water discharges into the storm water conveyance system. In the event that these services are contracted out in the future, this BMP will be modified to include contractor training (internal and external training).
BMP Objectives:
1. Ensure that maintenance personnel understand the proper techniques, schedules and requirements for maintaining storm water BMPs 2. Educate staff on storm water protection measures and requirements
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3.5 Post Construction for New Development and Significant Redevelopment (POST)
Described in this sub-section is the Truckee Meadows approach to reduce the discharge of pollutants associated with runoff from new development and redevelopment projects after construction is complete. Post construction storm water quality relies heavily on structural controls and Low Impact Development (LID) treatment approaches. The Truckee Meadows has had guidance documents for both in place since 2007. The design of the control measures is verified through the plan review and land development approval process. Through field inspections, the proper construction, operation and maintenance of the control measures is ensured. The requirements of the post construction program for new development and significant redevelopment (NDSR) is the largest section in the new permit. The approach to accomplishing these permit requirements is presented here.
3.5.1 Permit Requirements (POST)
Section IV.F of the permit contains the following requirements:
IV.F. Post-Construction Stormwater Management Program for New Development and Significant Redevelopment Projects IV.F.1 The Permittees shall develop a post-construction stormwater management program for new development and significant redevelopment (“NDSR”) projects that is suited for the unique hydrologic, hydrogeologic and regional conditions of the Truckee Meadows. The program shall focus on planning procedures consistent with the goals identified in Part IV.F.2. IV.F.2 The post-construction stormwater management program shall have the following goals: IV.F.2.a To prevent stormwater discharges to the MEP from post-construction projects that cause or contribute to downstream violations of water quality standards; and IV.F.2.b To promote the improvement of ambient water quality by reducing the discharge of pollutants in stormwater. IV.F.3 The post-construction stormwater management program shall address at a minimum the following elements: IV.F.3.a Describe how the Permittees will review and enhance the SWMP post- construction stormwater management program requirements in a manner appropriate for the unique hydrologic, hydrogeologic and regional conditions and needs of the Truckee Meadows. The review shall address the following elements: IV.F.3.a.i Describe how the Permittees will develop, implement and enforce a program to address post-construction urban runoff from NDSR projects that disturb areas ~1 acre, including projects <1 acre that are part of a larger common plan of development or sale, that discharge into the MS4 by ensuring that NDSR projects are complying to the MEP with the requirements of this program;
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IV.F.3.a.ii Describe how the Permittees will promote the use of low-impact development (LID) measures that will remain in effect after construction is complete and are effective and appropriate for the Truckee Meadows and its environment. The program will outline the selected LID measures found effective and appropriate for the Truckee Meadows along with a summary and schedule for implementation in the MS4; IV.F.3.a.iii Describe how the Permittees will develop any additional structural and non-structural BMPs that will remain in effect after construction is complete and are effective and appropriate for the Truckee Meadows and its environment. The program will outline the selected BMP measures found effective and appropriate for the Truckee Meadows along with a summary and schedule for implementation in the MS4; IV.F.3.a.iv Describe procedures to assure that future regional flood management projects assess the impacts on the water quality of receiving water bodies; IV.F.3.a.v Describe how the Permittees will develop and implement an ordinance or other regulatory mechanism to address post-construction stormwater management from NDSR projects; IV.F.3.a.vi Describe how the Permittees will provide verification of maintenance provisions for post-construction structural BMPs located on private property; IV.F.3.a.vii Describe how the Permittees will develop and implement an inventory and tracking system for post-construction structural stormwater BMPs. The inventory and tracking system shall use at a minimum the following items: project name, project location, project acreage, BMP type and description, inspection date and summary, and any corrective actions undertaken; IV.F.3.a.viii Describe how the Permittees will inspect and enforce the proper installation and long- term maintenance of post-construction structural stormwater BMPs; and IV.F.3.a.ix Describe how the Permittees will update its MS4 maps to show areas of NDSR, including any new stormwater major infrastructure that was constructed to serve these areas. IV.F.3.b All NDSR projects submitted to the permitting authority subsequent to program implementation as identified in IV.F.2 that fall into one of the following categories shall be subject to one or more of the SWMP design standards developed in accordance with Part IV.F.4: IV.F.3.b.i Residential subdivisions five (5) acres or greater in size; IV.F.3.b.ii Single-family residences subject to local ordinances governing hillside development; IV.F.3.b.iii 100,000 square foot commercial and industrial developments; IV.F.3.b.iv Automotive repair shops (with Standard Industrial Classification (“SIC”) codes 5013, 7532, 7533, 7534, 7537, 7538, and 7539); IV.F.3.b.v Retail gasoline outlets disturbing greater than one (1) acre; IV.F.3.b.vi Restaurants disturbing greater than one (1) acre; IV.F.3.b.vii Parking lots greater than one (1) acre potentially exposed to urban runoff; and IV.F.3.b.viii Any other NDSR projects the Permittees deem necessary to be included in this part.
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IV.F.4 Design Standards. The post-construction stormwater management program shall describe how NDSR projects specified in the previous section will implement the design standards outlined in this section. Subject to Section IV.F.4.e, the design standards program shall address at minimum the following criteria: IV.F.4.a Peak-Urban Runoff Discharge Rates. Describe how the Permittees will develop design standards for peak-urban runoff from NDSR projects that will provide protection against downstream erosion; IV.F.4.b Site Design BMPs. Describe how the post-construction stormwater management program will develop and implement site design BMPs in the site layout during the design and approval process to meet the goals of this program identified in Part IV.F.2; IV.F.4.c Source Control BMPs. The post-construction stormwater management program shall describe how source control BMPs will be implemented. The design standards program shall include the following source-control BMPs that are consistent with the goals of this program: IV.F.4.c.i Slopes and channel design or protection to minimize erosion; IV.F.4.c.ii Outdoor material storage areas designed to minimize the risk of stormwater runoff contacting and carrying away pollutants to the MS4; and IV.F.4.c.iii Trash storage areas designed to minimize the risk of stormwater runoff contacting and carrying away pollutants to the MS4. IV.F.4.d Structural Treatment Control BMPs. The post-construction stormwater management program shall describe why a treatment control BMP is selected, how it will be developed and implemented. “Treatment control BMPs” and “treat” refer to any onsite or offsite process that provides for infiltration or detention of stormwater or that removes pollutants through any physical, chemical, or biological process. The design standards program shall describe in sufficient detail how the Permittees will size treatment control BMPs using accepted hydrologic engineering quantitative methods and the following design criteria: IV.F.4.d.i Volumetric Treatment Control BMP design criteria. The post-construction stormwater management program shall describe how the Permittees will design volume-based BMPs to treat stormwater discharges from projects listed in Part IV.F.3.b. The Permittees shall use one of the following conditions to develop the volumetric treatment control BMP design criteria: IV.F.4.d.i.1 Historical rainfall records for the Truckee Meadows to determine the maximized capture stormwater volume for the area for the 24-hour event using the formula recommended in Urban Runoff Quality Management, Water Environment Federation Manual of Practice No. 23/ASCE Manual of Practice No. 87 (1998); or IV.F.4.d.i.2 The volume of annual runoff based on unit basin storage water quality volume, to achieve at least 80% of volume treatment by the method recommended in hydrology manuals, textbooks or similar technical publications; or IV.F.4.d.i.3 An alternative treatment design criteria, appropriate for the unique hydrologic, hydrogeologic and regional conditions of the Truckee Meadows. Any alternative design criteria shall be submitted to NDEP with sufficient technical data to establish the appropriateness of the alternative treatment design criteria.
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IV.F.4.d.ii Flow-Based BMP design criteria. The post-construction stormwater management program shall describe how the Permittees will design flow-based BMPs to treat stormwater discharges from projects listed in Part IV.F.3.b. The Permittees shall use one of the following conditions to develop flow-based BMP design criteria: IV.F.4.d.ii.1 Historical rainfall data for the Truckee Meadows to determine the maximum flow rate of runoff from rainfall per hour, for each hour of a storm event; or IV.F.4.d.ii.2 The maximum flow rate of runoff produced by the 80th percentile hourly rainfall intensity (for each hour of the storm event), as determined from the local historical rainfall record; or IV.F.4.d.ii.3 The maximum flow rate of runoff for each hour of a storm event, as determined from the local historical rainfall record that achieves approximately the same reduction in pollutant loads and flows as achieved by mitigation of the 80th percentile hourly rainfall intensity; or IV.F.4.d.ii.4 An alternative treatment design criteria, appropriate for the unique hydrologic, hydrogeologic and regional conditions of the Truckee Meadows. Any alternative design criteria shall be submitted to NDEP with sufficient technical data to establish the appropriateness of the alternative treatment design criteria. IV.F.4.e If the Permittees will not use some or all of the design standards described in this section, the Permittees shall provide justification using documentation and engineering analyses, and propose reasonable alternatives that are appropriate for the unique hydrologic, hydrogeologic and regional conditions in the Truckee Meadows. IV.F.5 Effect of the Post-Construction Stormwater Management Program on Water Quality Standards and Drinking Water Supply IV.F.5.a The Permittees shall provide a written evaluation in the Annual Report whether the criteria developed as part of the post-construction stormwater management program will tend to cause or contribute to elevated levels of pollutants of concern in surface waters within the Truckee Meadows, including an exceedance of the water quality standards for pollutants of concern in identified streams and tributaries, and shall submit the evaluation to NDEP as part of the post-construction stormwater management program; and IV.F.5.b The Permittees shall provide a written evaluation in the Annual Report whether the criteria developed as part of the post-construction stormwater management program will tend to reduce or degrade the contribution of stormwater to the water supplies provided by the Truckee River. IV.F.5.c If any criteria developed under the post-construction stormwater management program in accordance with the provisions of this permit would have a reasonable potential of causing or contributing to any water quality or water quantity impairment, or violates Nevada law, they shall be rescinded, and the Permittees shall determine whether alternate criteria can be implemented without causing water quality or water quantity impairments or violating Nevada law.
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3.5.2 Practices (POST)
Requiring structural controls and low impact development techniques is the general approach used in the Truckee Meadows for post construction storm water quality management. Structural treatment controls can be so-called public domain treatment controls (non-proprietary) or manufactured (proprietary) treatment controls. Public domain treatment controls are those that can be designed by an engineer and have been implemented and tested by numerous communities throughout the nation. Manufactured proprietary treatment controls are patented devices that have been engineered and constructed by private companies. Low impact development is considered a public domain treatment control. LID is a general methodology for accommodating storm water runoff within new development and redevelopment that mimics natural hydrologic functions within a site. Rather than conventional hardpiping from impervious surfaces, use of features such as vegetated swales, bioretention systems and permeable pavements are used.
Structural treatment controls and LID practices can reduce the negative impacts of urban runoff. In the Truckee Meadows, these BMPs are incorporated into the plan development process. Developers and planners consider them during both the conceptual project planning and permitting process. These BMPs are addressed in tentative subdivision maps, preliminary site plans, grading permits, and special use permits for both private and public works projects. Proper design, installation and inspection during construction and long-term maintenance are essential. Engineers, landscape architects and agency staff involved in the design and review of structural treatment controls and LID practices are familiar with the proper design, sizing and installation of these facilities.
LID features:
Utilizes natural biological, physical and chemical treatment processes for treatment Promotes percolation and water table recharge Slows runoff flows and reduces runoff volumes Reduces pollutant loads gathered from impervious surface sheet flow
Five different POST BMP Fact Sheets have been prepared to document the practices used in the Truckee Meadows related to post construction for NDSR projects. Programmatic BMPs developed include the land development process, two guidance documents and design worksheets. Listed in Table 3-5 are the BMPs that collectively address the POST requirements of the permit. The POST BMPs developed are briefly summarized below along with the BMP objectives. A full description of the BMPs, the joint responsibilities and the implementation schedule can be found in Section 6. A discussion of two other post construction permit requirements not shown in Table 3-5 is included at the end of this sub-section.
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Table 3-5. Permit Requirements and Activities for Post Construction for New Development and Significant Redevelopment Permit BMP Section Permit Requirement Number Title IV.F.2.a “To prevent stormwater EDU-01 Public Outreach and Education - Typical of Events discharges to the MEP from EDU-02 Public Outreach and Education Materials post-construction projects that EDU-08 Workshop and Training Seminars cause or contribute to POST-01 Land Development downstream violations of water POST-02 Truckee Meadows Structural Controls Design Manual quality standards” POST-03 Truckee Meadows Low Impact Development Handbook POST-04 Truckee Meadows Standard Design Guidance Worksheets POST-05 Future Regional Flood Projects GOV-02 Municipal Codes and Ordinances GOV-06 Plan Review MS4-02 Storm Drain Mapping IV.F.2.b “To promote the improvement EDU-01 Public Outreach and Education - Typical of Events of ambient water quality by EDU-03 Storm Drain Labeling Program reducing the discharge of IDDE-01 Illicit Discharge Report and Response Database pollutants in stormwater” IND-01 Commercial and Industrial Stormwater Inspections IND-03 Housekeeping – Commercial/Industrial
MUNI-01 Storm Drain and Channel Maintenance MUNI-02 Street Sweeping POST-03 Truckee Meadows Low Impact Development Handbook GOV-02 Municipal Codes and Ordinances MS4-05 Identification of New Storm Water BMPs MS4-08 Impaired Waters
IV.F.3.a Describe how the Permittees EDU-01 Public Outreach and Education - Typical of Events will review and enhance the IDDE-01 Illicit Discharge Report and Response Database SWMP post-construction IND-01 Commercial and Industrial Stormwater Inspections stormwater management IND-03 Housekeeping – Commercial/Industrial program requirements in a MUNI-01 Storm Drain and Channel Maintenance manner appropriate for the POST-02 Truckee Meadows Structural Controls Design Manual unique hydrologic, POST-03 Truckee Meadows Low Impact Development Handbook hydrogeologic and regional GOV-01 Intergovernmental Coordination conditions and needs of the GOV-02 Municipal Codes and Ordinances Truckee Meadows. The review GOV-06 Plan Review shall address the following elements” IV.F.3.a.i Describe how the Permittee’s IND-01 Commercial and Industrial Stormwater Inspections will develop, implement and MUNI-01 Storm Drain and Channel Maintenance enforce a program to address MUNI-03 Maintenance of City and County Owned Facilities post-construction urban runoff POST-01 Land Development from NDSR projects that disturb POST-04 Truckee Meadows Standard Design Guidance Worksheets areas ~1 acre, including GOV-02 Municipal Codes and Ordinances projects <1 acre that are part of GOV-05 Code Enforcement a larger common plan of GOV-06 Plan Review development or sale, that MS4-07 Annual MS4 Effectiveness Assessment discharge into the MS4 by ensuring that NDSR projects are complying to the MEP with the requirements of this program”
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Table 3-5. Permit Requirements and Activities for Post Construction for New Development and Significant Redevelopment – Continued Permit BMP Section Permit Requirement Number Title IV.F.3.a.ii Describe how the Permittees EDU-01 Public Outreach and Education - Typical of Events will promote the use of low- EDU-07 Demonstration Projects - Typical impact development (“LID”) EDU-08 Workshop and Training Seminars measures that will remain in POST-01 Land Development effect after construction is POST-02 Truckee Meadows Structural Controls Design Manual complete and are effective and POST-03 Truckee Meadows Low Impact Development Handbook appropriate for the Truckee POST-05 Truckee Meadows Standard Design Guidance Worksheets Meadows and its environment. GOV-02 Municipal Codes and Ordinances The program will outline the GOV-06 Plan Review selected LID measures found MS4-05 Identification of New Storm Water BMPs effective and appropriate for the Truckee Meadows along with a summary and schedule for implementation in the MS4” IV.F.3.a.iii Describe how the Permittees EDU-07 Demonstration Projects - Typical will develop any additional IND-05 Industrial and Commercial Stormwater BMP Handbook structural and non-structural POST-02 Truckee Meadows Structural Controls Design Manual BMPs that will remain in effect POST-03 Truckee Meadows Low Impact Development Handbook after construction is complete MS4-05 Identification of New Storm Water BMPs and are effective and MS4-06 Annual MS4 Effectiveness Assessment appropriate for the Truckee Meadows and its environment. The program will outline the selected BMP measures found effective and appropriate for the Truckee Meadows along with a summary and schedule for implementation in the MS4” IV.F.3.a.iv Describe procedures to assure POST-05 Future Regional Flood Projects that future regional flood (See Section 3.5.2) management projects assess the impacts on the water quality of receiving water bodies IV.F.3.a.v Describe how the Permittees GOV-01 Intergovernmental Coordination will develop and implement an GOV-02 Municipal Codes and Ordinances ordinance or other regulatory MS4-06 Annual MS4 Effectiveness Assessment mechanism to address post- construction stormwater management from NDSR projects IV.F.3.a.vi Describe how the Permittees POST-01 Land Development will provide verification of GOV-5 Plan Review maintenance provisions for GOV-02 Municipal Codes and Ordinances post-construction structural IND-04 Commercial and Industrial Stormwater Inspections BMPs located on private GOV-05 Code Enforcement property MUNI-03 Maintenance of City and County Owned Facilities
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Table 3-5. Permit Requirements and Activities for Post Construction for New Development and Significant Redevelopment – Continued Permit BMP Section Permit Requirement Number Title IV.F.3.a.vii Describe how the Permittees POST-01 Land Development will develop and implement an MS4-02 Storm Drain Mapping inventory and tracking system IND-04 Commercial/Industrial Facility Inventory for post-construction structural GOV-06 Plan Review stormwater BMPs. The IND-01 Commercial and Industrial Stormwater Inspections inventory and tracking system CONST-01 Construction Site Inspections shall use at a minimum the following items: project name, project location, project acreage, BMP type and description, inspection date and summary, and any corrective actions undertaken IV.F.3.a.viii Describe how the Permittees CONST-01 Construction Site Inspections will inspect and enforce the IND-01 Commercial and Industrial Stormwater Inspections proper installation and long- MUNI-01 Storm Drain and Channel Maintenance term maintenance of post- MUNI-03 Maintenance of City and County Owned Facilities construction structural POST-04 Truckee Meadows Standard Design Guidance Worksheets stormwater BMPs GOV-02 Municipal Codes and Ordinances GOV-05 Code Enforcement IV.F.3.a.ix Describe how the Permittees MS4-02 MS4 Mapping will update their MS4 maps to show areas of NDSR, including any new stormwater major infrastructure that was constructed to serve these areas
Land Development (POST-01) The co-permittees have an established Land Development Program and associated development codes, ordinances and articles. Through these programs and ordinances, the co-permittees review plans, conduct inspections, and collaborate with state and local agencies, health department staff and the public to ensure that development occurs in a manner that minimizes environmental contamination and provides for sustainable development. Development projects that disturb areas ≥1 acre, including projects <1 acre that are part of a larger common plan of development are reviewed.
Developers are required to provide a description of the permanent erosion control measures and structural treatment controls that will be installed to control pollutants in storm water discharges in the Storm Water Pollution Prevention Plans (SWPPPs). Ordinances and the Public Works Design Manuals required Global Positioning System (GPS) coordinates to be supplied when the plans are signed off by the Engineer of Record. The intent is to document each BMP and enter its location and owner into a database so that a reminder email (to the owner and EC) can be sent noting that the control is due for inspection/maintenance. Proposed structural treatment controls and LID
Truckee Meadows Storm Water Management Program 3-33 Section 3 – Program Elements practices presented in project plans, drainage and hydrology are all reviewed under the existing program.
BMP Objectives:
1. Review land development project plans for new or significant redevelopment that disturb areas greater than one acre (or <1 acre if part of a larger common development) to ensure that storm water runoff is treated or mitigated to the MEP 2. Maintain development codes that address storm water runoff considerations in the Truckee Meadows 3. Develop and maintain a tracking system for post-construction BMPs
The database for tracking post-construction BMPs is under development. The database will be refined in the coming years by the co-permittees (see Fact Sheet POST-01 in Section 6) to better track post-construction BMPs within the MS4 permit area.
Truckee Meadows Structural Controls Design Manual (POST-02) In 2003 the SWPCC began development of the Truckee Meadows Structural Controls Design Manual. The manual has been updated several times since, with the most recent revision being in April 2007 with a 2008 Errata page. The primary purpose of the manual is to provide general guidance for selecting and implementing source control and structural treatment control BMPs to reduce the pollutants in runoff from areas of new development and redevelopment. In the process of developing the Structural Controls Manual, there were numerous committee meetings, workshops and analysis conducted to customize the Post-Construction Program to the unique hydrologic, hydrogeologic and regional conditions for the Truckee Meadows. The manual sets forth water quality design criteria for flow and volume based structural controls.
The precipitation frequency analysis of data obtained from the Reno-Tahoe International Airport was used to define the frequency of individual storm events. This location has the greatest period of rainfall data for the Truckee Meadows. The manual is intended to assist local users with the siting, design, operation and long-term maintenance of structural controls for improving the quality of storm water discharges. The intended users of the manual include developers, planners, design engineers, contractors, subcontractors, construction staff and co-permittee staff involved in public and private site development and redevelopment projects. The source and structural treatment controls presented in the manual were carefully selected to provide a wide variety of appropriate measures and devices for use in the soils and climate of the Truckee Meadows. The Structural Controls Design Manual is an important component of the SWMP.
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BMP Objectives:
1. Promote, publicize and distribute the manual to developers, planners and design engineers within the Truckee Meadows MS4 permit area 2. Keep the information in the manual up to date
Truckee Meadows Low Impact Development Handbook (POST-03) In August 2007, the SWPCC released the Truckee Meadows Low Impact Development (LID) Handbook. The purpose of the LID Handbook is to provide regional planning policies, procedures and guidance on site design techniques for improving the quality and reducing the quantity of storm water runoff from new development and significant redevelopment, to predevelopment conditions, to the MEP. The LID Handbook was primarily developed to assist planners, developers, architects, landscape professionals, City and County community development and public works staff and others with the selection and design of features and practices that mimic natural hydrologic functions. These include filtration of runoff through vegetation, soils and organic matter, evapotranspiration by vegetation, biodegradation of pollutants by soil bacteria, infiltration and groundwater recharge. The LID Handbook complements the Truckee Meadows Structural Controls Design Manual in providing designers with a full array of options. The LID Handbook and encouraging LID practices in the Truckee Meadows is an important component of the SWMP.
BMP Objectives:
1. Promote, publicize and distribute the LID Handbook to planners, developers, architects, and landscape professionals active in the Truckee Meadows
2. Keep the information in the handbook up to date
Truckee Meadows Standard Design Guidance Worksheets (POST-04) The 2007 edition of the Truckee Meadows Structural Controls Design Manual included a series of Design Guidance Worksheets for structural treatment controls and LID practices. The worksheets utilize Excel spreadsheets with write-protected design criteria from the manual to provide a tool to assist with the consistent design and review of proposed structural treatment controls and LID practices for use in the Truckee Meadows. The Design Guidance Worksheets are intended for use by designers and submitted to agency staff to expedite the plan review process. The treatment controls and calculations included in the Design Guidance Worksheets were carefully selected to provide a wide variety of locally appropriate measures and devices for use in the soils and climate of the Truckee Meadows.
BMP Objectives:
1. Promote, publicize and distribute the Design Guidance Worksheets to developers, planners and design engineers within the Truckee Meadows MS4 permit area
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2. Keep the information in the worksheets current
3.5.3 Future Regional Flood Projects (POST)
Permit Section IV.F.3.a.iv requires a description of procedures to assure that future regional flood management projects assess the impacts on the water quality of receiving water bodies. Programmatic principles for storm water and flood control water quality enhancement and protection of water resources in the Truckee Meadows include reducing or maintaining runoff to predevelopment conditions via LID practices; controlling the sources of pollutants; and treating storm water runoff (via structural and non-structural BMPs) prior to discharging to a storm drain system or to receiving waters. Collectively all of the various program components are considered by the USEPA to treat storm water runoff to the maximum extent practicable (MEP).
Existing Program Components: Where desirable and feasible, water quality improvements are incorporated into larger flood control facilities. Section 2.7, Regional Treatment Controls, and Section 3.2 Water Quality Design Criteria, Structural Controls Design Manual, April 2007 Update, recognize that proposed and existing flood management projects, such as detention basins, can be modified to improve the quality of storm water discharges with the addition of water quality outlet structures, vegetated swales and storm water ponds and wetlands. Design Matrix 3, Storm Water Management Capability, Appendix A – Structural Control Design and Selection Matrix, identifies various treatment control groups and their appropriateness in meeting water quality, recharge, channel protection and flood control objectives. Furthermore, Section 500 of the Truckee Meadows Regional Drainage Manual specifies technical submittal requirements for proposed improvements, which include water quality structural controls, detention and channel requirements for water quality enhancement.
Overall, the existing Truckee Meadows Storm Water Program provides procedures and guidance, which assess regional flood management projects and their impacts on water quality. This existing program can be enhanced by the implementation of a more formalized process to periodically review future regional flood management projects, advancements in best management practices and current regional water quality objectives.
Annual Assessment: The issue of whether adequate procedures are in place associated with the Post-Construction Storm Water Management Program to assure that future regional flood management projects assess the impacts on the water quality of receiving water bodies will be examined annually as described below.
1. Hold one annual meeting with flood management staff from the Cities of Reno and Sparks, Washoe County and the Truckee River Flood Management Authority (TRFMA) to review planned regional flood management projects and current regional water quality objectives. Annual meetings will be held between the SWPCC and the TRFMA to discuss
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flood management and water quality related issues to encourage a more proactive, comprehensive, regional assessment of planned flood management practices and projects related to water quality. 2. Annually discuss advancements in flood management water quality best management practices. Due to the dynamic nature of urban storm drainage and flood management, amendments and revisions will be required periodically to the Truckee Meadows Regional Drainage Manual and the SWMP, as technology advances and experience are gained.
A BMP Fact Sheet (POST-05) outlining the annual program to assess regional flood control projects and related water quality objectives, including rationale, objectives, measurable goals and a schedule of implementation, is included in Section 6 of this document.
3.5.4 Design Standards (POST)
Section IV.F.4 of the permit requires the co-permittees to describe the development and implementation of design standards for peak-urban runoff from NDSR projects. In 2003, the SWPCC reviewed performance standards and water quality design criteria that could be used in regulating new development and significant redevelopment specifically for the Truckee Meadows. Consideration was given to other communities’ performance standards and methodologies for sizing structural treatment controls. Technical Memorandum SC3.0 dated 28 August 2003 (prepared by Kennedy/Jenks Consultants) details the alternatives and recommendations accepted by the SWPCC. This outlines the decisions for selecting the sizing for flow-based and volume based structural treatment controls for inclusion into the Structural Controls Manual. Most of the Low Impact Development treatment controls are either flow-based and/or volume based. These design approaches capture and treat storm water generated by the small, more frequent storms.
For volume based BMP design standards, the Urban Runoff Quality Management, the WEF Manual of Practice No. 23, and the ASCE Manual and Report on Engineering Practice No. 87 were reviewed, but considered suitable for only planning level estimates. For more specific design, the Water Quality volume (WQv) method was selected. It utilizes local precipitation data and a runoff coefficient that is based on the amount of impervious area within the drainage area for the proposed treatment control. The local long-term hourly precipitation data for the Reno-Tahoe International Airport was graphed to determine at what frequency runoff producing events occur. For the Truckee Meadows it was concluded that the 90th percentile event would be used. This equates to approximately 0.6 inches.
For flow based Structural Treatment Controls, the Rational Method has been determined to be most applicable, utilizing the peak discharge from the 2-year, 6-hour storm event of the contributing area directly connected to the treatment control measure. These design procedures are explicitly lined out in the Structural Controls Manual. Considerations in the selection of the appropriate Structural Treatment Control are:
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What are the anticipated pollutants generated by the land use? (See table 2-3 of the Truckee Meadows Structural Controls Manual) What kind of treatment control will address those pollutants? (See Appendix A - Design Matrix of the Truckee Meadows Structural Controls Manual) What are the percolation rates of the soils on the site? (A general Indication of soil types can be obtained from Appendices A and B in the Low Impact Development Manual) Are there areas that can be considered "self treating" or "zero discharge" if left undisturbed? 3.6 Construction Site Discharge (CONST)
Described in this sub-section are the practices associated with the Truckee Meadows construction site discharge program. The motivation behind this programmatic element is to control pollutants associated with construction activities by requiring site operators to implement adequate water quality control measures and by enforcing the implementation of the requirements through inspections.
3.6.1 Permit Requirements (CONST)
Section IV.I of the permit contains the following requirements:
IV.I. Construction Site BMP Program IV.I.1 The updated SWMP shall include a description of a program to implement and maintain structural and non-structural BMPs to reduce pollutants in stormwater runoff from construction sites to the MS4, which shall include: IV.I.1.a A description of procedures for notifying developers and operators of properties of one (1) acre or more (and less than one acre if part of a larger plan of development) of requirements applicable to stormwater runoff; IV.I.1.b A description of nonstructural and structural BMPs to be utilized for construction sites; IV.I.1.c A description of appropriate educational and training measures for construction site operators; and IV.I.1.d A description of a procedure to check for coverage under NDEP’s General Construction Permit for Construction Activity prior to Permit issuance. IV.J. Inspection of Construction Sites IV.J.1 Each Permittee shall conduct construction site inspections for compliance with its local ordinances (grading, stormwater, etc.) and permits (construction, grading, etc.); IV.J.2 Each Permittee shall inspect at least monthly, all construction sites within its jurisdiction meeting the following criteria: IV.J.2.a All sites disturbing 100 acres or more in size at one time;
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IV.J.2.b All sites disturbing one (1) acre or more that are tributary to a CWA section 303(d) water body segment impaired for sediment or turbidity; and IV.J.2.c Sites determined by the permittees as a significant threat to water quality. In evaluating threat to water quality, the following factors shall be considered: IV.J.2.c.i Soil erosion potential; IV.J.2.c.ii Site Slope; IV.J.2.c.iii Project size and type; IV.J.2.c.iv Sensitivity of receiving water bodies; IV.J.2.c.v Proximity to receiving water bodies; IV.J.2.c.vi Proximity to water bodies 303(d) listed for turbidity and sediment; IV.J.2.c.vii Non-stormwater discharges; IV.J.2.c.viii Past record of non-compliance by the construction site operators; and IV.J.2.c.ix Any other relevant factors. IV.J.2.d All other construction sites of > one (1) acre not listed in Part IV.J.2 shall be inspected at least two (2) times for the duration of ground disturbance activities; IV.J.3 Based upon site inspection findings, each Permittee shall implement all follow-up actions (i.e., re-inspection or enforcement) necessary to comply with this Permit; IV.J.4 Inspections of construction sites shall include, but not be limited to: IV.J.4.a Assessment of compliance with Permittee ordinances and permits related to urban runoff, including the implementation and maintenance of designated minimum BMPs; IV.J.4.b Assessment of BMP effectiveness; IV.J.4.c Visual observations for non-stormwater discharges and potential illicit connections; IV.J.4.d Education and outreach on stormwater pollution prevention, as needed; and IV.J.4.e Creation of a written or electronic inspection report. IV.J.5 The Permittees shall track the number of inspections for the inventoried construction sites throughout the reporting period to verify that the sites are inspected at the minimum frequencies required. This information shall be included in the Annual Report.
3.6.2 Practices (CONST)
Three different CONST BMP Fact Sheets have been prepared to document the practices used in the Truckee Meadows related to the control and regulation of construction site discharges. BMPs developed include site inspections, BMP training and construction site guidance documents. Listed in Table 3-6 are the BMPs to collectively address the CONST requirements of the permit. The BMPs developed are briefly summarized below along with the objectives. A full description of the BMPs, the joint responsibilities and the implementation schedule can be found in Section 6.
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Table 3-6. Permit Requirements and Activities for Construction Site Discharges Permit BMP Section Permit Requirement Number Title IV.I.1.a A description of procedures for EDU-01 Public Outreach and Education - Typical of Events notifying developers and EDU-04 Partnerships and Affiliations operators of properties of one EDU-05 Regional Program Website - TMStormwater.com (1) acre or more (and less than EDU-08 Workshop and Training Seminars one acre if part of a larger plan IND-02 Commercial and Industrial Storm Water Outreach of development) of POST-01 Land Development requirements applicable to POST-02 Truckee Meadows Structural Controls Design Manual stormwater runoff POST-03 Truckee Meadows Low Impact Development Handbook POST-05 Truckee Meadows Standard Design Guidance Worksheets GOV-02 Municipal Codes and Ordinances GOV-06 Plan Review CONST-01 Construction Site Inspections CONST-02 Construction Site BMP Training CONST-03 Construction Site BMP Handbooks
IV.I.1.b A description of nonstructural IND-05 Industrial and Commercial Storm Water BMP Handbook and structural BMPs to be POST-02 Truckee Meadows Structural Controls Design Manual utilized for construction sites POST-03 Truckee Meadows Low Impact Development Handbook POST-05 Truckee Meadows Standard Design Guidance Worksheets CONST-02 Construction Site BMP Training CONST-03 Construction Site BMP Handbooks
IV.I.1.c A description of appropriate EDU-08 Workshop and Training Seminars educational and training CONST-02 Construction Site BMP Training measures for construction site CONST-03 Construction Site BMP Handbooks operators
IV.I.1.d A description of a procedure to GOV-06 Plan Review check for coverage under NDEP’s General Construction Permit for Construction Activity prior to Permit issuance IV.J.1 Each Permittee shall conduct CONST-01 Construction Site Inspections construction site inspections for compliance with its local ordinances (grading, stormwater, etc.) and permits (construction, grading, etc.); IV.J.2 Each Permittee shall inspect at CONST-01 Construction Site Inspections least monthly, all construction sites within its jurisdiction meeting the following criteria…. IV.J.5 The Permittees shall track the CONST-01 Construction Site Inspections number of inspections for the inventoried construction sites throughout the reporting period to verify that the sites are inspected at the minimum frequencies required. This information shall be included in the Annual Report.
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Construction Site Inspections (CONST-01) The co-permittees each have an existing construction inspection program for the implementation of BMPs to control runoff, prevent erosion and improve storm water quality from construction sites throughout the MS4 permit area. The co-permittees individually conduct the inspections within their own jurisdictions enforcing their own ordinances and codes. Inspections normally occur during grading, site improvement (on-site and off-site) and building inspections. Inspectors review and approve SWPPPs in the field, direct modifications to plans where deficiencies exist, and confirm adequacy of the modifications. Inspectors enforce requirements progressively through verbal warnings, Notices of Violation, Notices of Citation, and Stop Work Orders. Noted deficiencies are recorded and re-inspected for compliance.
Field inspectors are required to maintain a written database of inspections performed, corrective actions taken, and Notices of Violation/Citations/Stop Work Orders issued. The co-permittees are required to track the number of inspections for the inventoried construction sites throughout the reporting period to verify that the sites are inspected at the minimum frequencies required. This information will be included in the Annual Report.
BMP Objectives:
1. To inspect construction sites to verify BMPs are properly installed and maintained 2. To enforce Ordinances and Codes 3. To document action taken
Construction Site BMP Training (CONST-02) Twice each year at minimum, the SWPCC hosts or jointly sponsors a training session for storm water BMP compliance for construction sites. Typical workshop content includes subjects like regulatory requirements and consequences, BMP selection and installation, the permitting process, inspections, guidance documents and resources, and the preparation of Storm Water Pollution Prevention Plans (SWPPP). Some training sessions have a field component. Target audiences are contractors, builders and engineers, from the community, industry, academia, and municipal realms. Often there is overlap between the audiences.
The co-permittees have an existing Construction Site BMP Storm Water Training Program. Training sessions are typically co-sponsored by the Association of General Contractors (AGC), Builders Association of Northern Nevada (BANN), and/or the University of Nevada Cooperative Extension. The number and diversity of workshops offered each year are a function of the economy, interest and local building activity.
BMP Objectives:
1. Educate construction sector about storm water quality, BMPs, applicable codes/ordinances
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2. Improve water quality through building awareness of non-point sources of pollution 3. Share local resources, both online and physical, for contractors to use in storm water protection
Construction Site BMP Handbooks (CONST-03) There are two important construction site BMP handbooks developed for use in the Truckee Meadows. In 2003, the Truckee Meadows Construction Site BMP Handbook was issued, and later updated in June 2008. In June 2008, the Nevada Contractors Field Guide for Construction Site BMPs was released as a joint effort between several agencies. Both of these handbooks assist contractors and designers with the requirements of NDEP’s General Construction Permit. The intended users of the handbooks include the owners/operators of construction sites, developers, design engineers, contractors and plan review and construction site inspection staff. Both handbooks present a series of BMP fact sheets for Planning, Runoff Control, Erosion Control, Sediment Control, Drainage Way Protection, and General Site and Materials Management.
BMP Objectives:
1. Promote, publicize and distribute the manuals to construction site contractors, developers, planners and design engineers within the Truckee Meadows MS4 permit area 2. Keep the information in the manual updated with revisions every five years 3.7 Intergovernmental Coordination (GOV)
Cooperation between the co-permittees is essential to administer the MS4 permit and the SWMP. Governmental and municipal requirements like codes, ordinances and enforcement are required by the permit and critical to protecting waters of the MS4 permit area. The general requirements of the permit, the boundaries of the MS4 permit area, authorized discharges, sharing responsibilities, the duty to comply, record keeping and the Annual Report to NDEP must be cooperatively addressed for a successful SWMP. These requirements and other BMPs with joint responsibility fall under Intergovernmental Coordination (GOV). The approach to accomplishing these permit requirements is presented in this sub-section.
3.7.1 Permit Requirements (GOV)
Permit requirements listed here are from multiple sections of the permit. Those sections include requirements from:
I. PERMIT AREA AND COVERAGE UNDER THIS PERMIT I.A. Permit Area I.A.1 This permit authorizes stormwater discharges into receiving waters of the United States within the Cities of Reno and Sparks, and Washoe County (“Permittees”) that
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are located within the Truckee Meadows. The permitted area includes the limits of the urbanized area within the Truckee Meadows Service Area as established by the Truckee Meadows Regional Planning Agency. This area includes areas which are, or could reasonably be, urbanized within the time covered by the permit. I.B. Permit Coverage I.B.1 This Permit authorizes discharges of stormwater from the Permittees’ municipal separate storm sewer systems (“MS4s”), as defined in 40 Code of Federal Regulations (“CFR”) § 122.26. The Permittees are authorized to discharge stormwater in accordance with the terms and conditions of this Permit. I.B.2 The following are types of authorized discharges: I.B.2.a Authorized discharges. This Permit authorizes stormwater discharges and the non- stormwater discharges identified in Part I.B.2.b to waters of the United States from the Permittees’ MS4. This Permit does not allow discharges listed in Part I.B.3. I.B.2.a.i This Permit authorizes the Permittees to accept, pass through and discharge stormwater and non-stormwater currently covered or required to be covered under another National Pollutant Discharge Elimination System (“NPDES”) permit. The permittees shall implement on those discharges into their MS4s the measures required by this Permit. I.B.2.a.ii This permit does not authorize any non-Permittees to discharge into the MS4 any stormwater or non-stormwater that requires a separate NPDES permit. Those non- Permittees must obtain their own NPDES permits to cover discharges through the Permittees’ MS4s into waters of the United States. I.B.2.b Non-stormwater discharges. The Permittees are authorized to accept, pass through and discharge, without requiring Best Management Practices (“BMPs”) or other measures, the following non-stormwater sources provided that the Nevada Division of Environmental Protection (“NDEP”) has not determined these sources to be substantial contributors of pollutants to the Permittees’ MS4: I.B.3 Non-Authorized Discharges I.B.3.a This permit does not authorize the following: I.B.3.a.i Discharges that do not comply with the Nevada’s anti-degradation policy for water quality standards; and I.B.3.a.ii Any discharge that causes or contributes to an in-stream exceedance of water quality standards. IV. STORMWATER MANAGEMENT PROGRAM IV.A. General Requirements IV.A.1 The Permittees shall continue to implement and enforce their Stormwater Management Program (“SWMP”) designed to reduce the discharge of pollutants from the Permittees’ MS4 to the maximum extent practicable (“MEP”) to protect water quality, and to satisfy the appropriate water quality requirements of the Clean Water Act (“CWA”); IV.A.2 The Permittees may partner with other MS4s in the region to develop and implement the SWMP. The description of the Permittees’ SWMP must clearly describe which Permittee is responsible for implementing each of the BMPs identified in the SWMP.
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IV.A.3 The Permittees shall review, revise as necessary and submit an updated SWMP to NDEP for its review and approval within eighteen (18) months of the effective date of this permit and shall implement the revised SWMP no later than two (2) years after receiving NDEP’s approval; IV.K. Sharing Responsibility IV.K.1 The Permittees may either share responsibility or assign responsibility to one or more Permittees, and may implement BMPs individually, as a group, or through consultants. The SWMP shall include a description of how responsibility to implement BMPs is being shared or assigned. IV.M. Responsibility for Stormwater Management Program Implementation IV.M.1 The Permittees must implement the SWMP on all new areas added to the Permittees portion of the MS4 (or for which the Permittees become responsible for implementation of stormwater quality controls) not later than one (1) year from addition of the new areas; and IV.M.2 Information on all new annexed areas and any resulting updates required to the SWMP must be included in the Annual Report. V.B. Recordkeeping V.B.1 The Permittees must retain records of all monitoring information, including: all calibration and maintenance records and all original strip chart recordings for continuous monitoring instrumentation, copies of all reports required by this permit, a copy of the NPDES permit, and records of all data used to complete the application for this permit, for a period of at least three (3) years from the termination date of this permit. This period may be extended at the direction of NDEP at any time. V.B.2 The Permittees must submit the records to NDEP only when specifically asked to do so. The Permittees must retain a copy of the SWMP required by this permit (including a copy of the permit language) at a location accessible to NDEP. The Permittees must make the records, including a copy of the SWMP, available to the public if requested to do so in writing. V.B.3 For public requests of records, the Permittees may impose a reasonable fee for personnel time and copying expenses. V.C. Annual Report V.C.1 Permittees shall submit an Annual Report to NDEP by January 15 of each year of the permit term. Each Annual Report shall cover the previous fiscal year (July 1st through June 30th). For example, the Annual Report submitted January 15, 2011, will cover the period July 1, 2009, through June 30, 2010. V.C.2 Each year, Permittees shall review the SWMP defined under Part IV of this permit, and report to NDEP on the status of the program, whether Permittees have identified any modifications, and the plans for implementing those modifications. VI. STANDARD PERMIT CONDITIONS VI.A. Duty to Comply VI.A .1 The Permittees must comply with all applicable conditions of this permit. Any permit noncompliance constitutes a violation of CWA and is grounds for enforcement action;
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permit termination; revocation and reissuance; modification; or for denial of a permit renewal application. Each Permittee is responsible for its own compliance with this permit, but not for any noncompliance of another Permittee. No Permittee shall be held liable for the violation of this Permit by another Permittee. VI.B. Annual Fee VI.B.1 The Permittees shall remit an annual review and services fee in accordance with Nevada Administrative Code (“NAC”) 445A .232 starting July 1, 2010, and every year thereafter until the Permit is terminated. VI.C. Continuation of the Expired Permit VI.C.1 If this Permit is not reissued or replaced prior to the expiration date, it will be administratively continued in accordance with the Administrative Procedures Act and remain in force and effect. Permittees granted permit coverage prior to the expiration date will automatically remain covered by the continued permit until the earlier of: VI.C.1.a Reissuance or replacement of this Permit; or VI.C.1.b Issuance of another individual permit for the Permittees’ discharges. VI.D. Need to Halt or Reduce Activity Not a Defense VI.D.1 It shall not be a defense for the Permittees in an enforcement action that it would have been necessary to halt or reduce the permitted activity under the Permittees’ control in order to maintain compliance with the conditions of this Permit. VI.E. Duty to Mitigate VI.E.1 The Permittees must take all reasonable steps to minimize or prevent any discharge in violation of this permit that has a reasonable likelihood of adversely affecting human health or the environment. VI.F. Duty to Provide Information VI.F.1 The Permittees must furnish to NDEP any information that is requested by NDEP and needed to determine compliance with this permit or other information. VI.G. Other Information VI.G.1 If the Permittees become aware that the Permittees have failed to submit any relevant facts in the Permittees SWMP or Annual Report or submitted incorrect information in the SWMP or Annual Report or in any other report to NDEP, the Permittees must promptly submit such facts or information. VI.H. Signatory Requirements VI.H.1 All applications, reports, certifications, or information submitted to NDEP, or that this Permit requires be maintained by the Permittees shall be signed and certified as follows: VI.H.1.a Applications. All applications shall be signed by either a principal executive officer or ranking elected official. VI.H.1.b Reports and other information. All reports required by the permit and other information requested by NDEP or authorized representative of NDEP shall be
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signed by a person described above from the lead agency or by a duly authorized representative of that person. A person is a duly authorized representative only if: VI.H.1.b.i Signed authorization. The authorization is made in writing by a person described above and submitted to NDEP. VI.H.1.b.ii Authorization with specified responsibility. The authorization specifies either an individual or a position having responsibility for the overall operation of the regulated facility or activity, such as the position of manager, operator, superintendent, or position of equivalent responsibility for environmental matter for the regulated entity. VI.H.1.c Changes to authorization. If an authorization is no longer accurate because a different operator has the responsibility for the overall operation of the MS4, a new authorization satisfying the requirement of Part VI.H.1.b must be submitted to NDEP prior to or together with any reports, information, or applications to be signed by an authorized representative. VI.I. Property Rights VI.I.1 The issuance of this Permit does not convey any property rights of any sort, or any exclusive privilege, nor does it authorize any injury to private property nor any invasion of personal rights, nor any infringement of Federal, State or local laws or regulations. VI.J. Proper Operation and Maintenance VI.J.1 The Permittees must at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the Permittees to achieve compliance with the conditions of this Permit. VI.K. Inspection and Entry VI.K.1 The Permittees shall allow NDEP or an authorized representative (including an authorized contractor acting as a representative of NDEP) upon the presentation of credentials and other documents as may be required by law, to do any of the following: VI.K.1.a Enter the Permittees’ premises where a regulated facility or activity is located or conducted or where records must be kept under the conditions of this Permit; VI.K.1.b Have access to and copy at reasonable times, any records that must be kept under the conditions of this permit; VI.K.1.c Inspect at reasonable times any facilities or equipment (including monitoring and control equipment) practices, or operations regulated or required under this Permit; and VI.K.1.d Sample or monitor at reasonable times, for the purposes of assuring permit compliance or as otherwise authorized by the CWA, any substances or parameters at any location. VI.L. Permit Actions VI.L.1 This Permit may be modified, revoked and reissued, or terminated for cause. The Permittees filing of a request for a permit modification, revocation and reissuance, or termination, or a notification of planned changes or anticipated noncompliance does not stay any permit condition.
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VI.M. Deadlines for Reapplication to Continue Permit Coverage VI.M.1 The Permittees shall submit written correspondence to NDEP requesting continued permit coverage not later than 180 days before this Permit expires. VI.N. Permit Transfers VI.N.1 This Permit is not transferable to any person except after written notice to NDEP and approval by NDEP. NDEP may require modification or revocation and reissuance of the permit to change the name of the Permittee and incorporate such other requirements as may be necessary under the CWA. VI.O. Anticipated Noncompliance VI.O.1 The Permittees shall give 24-hour notice to NDEP of any planned changes in the permitted MS4 or activity which may result in non-compliance with this Permit. VI.P. State Environmental Laws VI.P.1 Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the Permittees from any responsibilities, liabilities, or penalties established pursuant to any applicable State law or regulation under authority preserved by section 510 of the CWA. VI.P.2 No condition of this permit releases the Permittees from any responsibility or requirements under other environmental statutes or regulations. VI.Q. Severability VI.Q.1 The provisions of this permit are severable, and if any provision of this Permit or the application of any provision of this Permit due to any circumstance, is held invalid, the application of such provision to other circumstances, and the remainder of this Permit shall not be affected thereby. VI.R. Procedures for Modification or Revocation VI.R.1 Permit modification or revocation will be conducted according to 40 CFR §122.62, 122.63, 122.64 and 124.5. VI.S. Availability of Reports VI.S.1 Except for data determined to be confidential under Nevada Revised Statutes (“NRS”) 445A.665, all reports and plans submitted in accordance with the terms of this permit shall be available for public inspection at NDEP’s office in Carson City. As required by the CWA, effluent data shall not be considered confidential. Knowingly making any false statement on any such report may result in the imposition of criminal penalties as provided for in NRS 445A.710. VI.T. Furnishing False Information and Tampering with Monitoring Devices VI.T.1 Any person who knowingly makes any false statement, representation, or certification in any application, record, report, plan or other document submitted or required to be maintained by the provisions of NRS 445A.300 to 445A.730, inclusive, or by any permit, rule, regulation or order issued pursuant thereto, or who falsifies, tampers with or knowingly renders inaccurate any monitoring device or method required to be maintained under the provisions of NRS 445A.300 to 445A.730, inclusive, or by any permit, rule, regulation or order issued pursuant thereto, is guilty of a gross
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misdemeanor and shall be punished by a fine of not more than $25,000 or by imprisonment. This penalty is in addition to any other penalties, civil or criminal, pursuant to NRS 445A.300 to 445A.730, inclusive. VI.U. Penalty for Violation of Permit Conditions VI.U.1.a NRS 445A .675 provides that any person who violates a permit condition is subject to administrative and judicial sanctions as outlined in NRS 445A.690 through 445A.710. VI.V. Permit Modification, Suspension or Revocation VI.V.1 After notice and opportunity for a hearing, this permit may be modified, suspended, or revoked in whole or in part during its term for cause including, but not limited to, the following: VI.V.1.a Violation of any terms or conditions of this permit; VI.V.1.b Obtaining this permit by misrepresentation or failure to disclose fully all relevant facts; VI.V.1.c A change in any condition that requires either a temporary or permanent reduction or elimination of the authorized discharge; or VI.V.1.d To impose specific requirements for BMPs or annual reporting requirements in accordance with 40 CFR § 122.62 or §122.63. VI.V.2 Any Permittee may request that NDEP reopen and modify this permit. III. ADEQUATE LEGAL AUTHORITY III.A. Ordinance III.A.1 Each of the Permittees shall have an ordinance in place that authorizes or enables each Permittee to: III.A.1.a Prohibit illicit discharges and illicit connections to the Permittees’ MS4s; III.A.1.b Mitigate the discharge from spills, dumping or disposal of materials other than stormwater to any of the Permittees’ MS4s; III.A.1.c Require compliance with any condition contained in ordinances, permits, contracts or orders; III.A.1.d Require structural and non-structural BMPs for erosion and sediment controls at construction sites; III.A.1.e Inspect construction sites disturbing ~ one (1) acre or < one (1) acre if part of a common plan of development to ensure compliance with each Permittee’s ordinance and take appropriate enforcement action as necessary; III.A.1.f Inspect industrial sites that are part of each jurisdiction’s inventory of industrial sites to ensure compliance with each Permittee’s ordinance, and take appropriate enforcement action as necessary; III.A.1.g Establish civil, administrative and criminal penalties for violations of the ordinance; and III.A.1.h Carry out all inspection, surveillance, and monitoring procedures necessary to determine compliance and non-compliance with the prohibition of illicit discharges to the Permittees’ MS4s.
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IV.G. Illicit Discharge and Detection IV.G.1.f A description of a program to facilitate public reporting of the presence of illicit discharges or water quality impacts associated with discharges from MS4s
3.7.2 Practices (GOV)
Six different GOV BMP Fact Sheets have been prepared that fall under the category of Intergovernmental Coordination (GOV). The fundamental BMP is outlined in Fact Sheet GOV-01, Intergovernmental Coordination, which outlines the plan to maintain cooperation between the three co-permittees. Other programmatic BMPs that fall under joint co-permittee governmental responsibility include municipal codes and ordinances, complaint hotline, code enforcement, plan review and the Truckee Meadows Regional Drainage Manual. The six GOV BMPs developed are briefly summarized below along with the objectives. A full description of the BMPs, the joint responsibilities and the implementation schedule can be found in Section 6.
Intergovernmental Coordination (GOV-01) In 1990, the three co-permittees (City of Reno, City of Sparks and Washoe County) entered into an Interlocal Agreement (National Pollutant Discharge Elimination System Storm Water Permit Implementation Agreement, July 24, 1990) that defined policy on member's roles, procedures, responsibilities, duties and requirements to effectively and jointly administer the MS4 Permit. In 2004, the agreement was amended and restated (First Amended Agreement Regarding National Pollutant Discharge Elimination Storm Water Permit Implementation, June 22, 2004) and remains in effect to date. NDOT and the three co-permittees also share an Interlocal Agreement (2001), which currently facilitates coordination on storm water pollution prevention activities.
The Cities of Reno and Sparks and Washoe County have signed a Memorandum of Understanding (MOU) under Nevada Division of Environmental Protection and 10 other agencies and groups, to participate in a coordinated watershed monitoring effort in the Truckee River system (Memorandum of Understanding for the Development and Maintenance of a Truckee River Coordinated Monitoring Program, July 7, 2009). Collectively, these agreements and MOUs define goals and responsibilities that support the effective management of storm water in the Truckee Meadows.
BMP Objectives:
1. Maintain the Interlocal Agreement (2004) defining roles and responsibilities to jointly administer the requirements of the MS4 Permit 2. Support each other in improving storm water quality in the Truckee Meadows within the Truckee Meadows Service Area (TMSA), specified by the Truckee Meadows Regional Plan 3. Coordinate the SWPCC activities and permit through at least bimonthly meetings, with a goal of meeting monthly
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4. Participate in coordinated environmental monitoring and assessment of the Truckee River watershed, collaborating in the creation of the Truckee River Coordinated Monitoring Program (CMP) document, and providing information on the CMP to the public through posting on www.truckeeriverinfo.org.
Municipal Codes and Ordinances (GOV-02) A review of the applicability of the storm water ordinances (codes and articles) for the three jurisdictions can be found in Section 2.4 of this document. All three jurisdictions (City of Reno, City of Sparks and Washoe County) are working towards enacting the storm water ordinances needed to implement the provisions of the 2010 MS4 Permit for storm water and non-storm water discharges within the MS4 permit area. These ordinances provide the authority to require BMPs, conduct inspections, regulate illicit discharges, and enforce the components of the SWMP. The co- permittees regulate development on hillsides through zoning, land use guidelines and development codes and ordinances.
The adequacy of these ordinances are reviewed and discussed in committee. The reviews consider the adequacy of definitions, requirements, maintenance, hillside development, and enforcement capabilities. Any issues noted will be addressed with legal counsel and ordinances will be revised as necessary. The City of Sparks and Washoe County will consider adding language to better address post-construction storm water management activities.
BMP Objectives:
1. Maintain adequate legal authority to enforce the provisions of the MS4 Permit 2. Through ordinance requirements, maintain and improve the quality of storm water discharges in the Truckee Meadows
Complaint Hotline (GOV-03) The SWPCC promotes the hotline number for Reno Direct “334-INFO” to facilitate public reporting of the presence of illicit discharges or water quality impacts associated with discharges from the MS4 Permit area. The City of Reno created Reno Direct, a non-emergency call center, to assist the public with City government service requests and general information. Operating hours are between 6:00 am and 6:00 pm, Monday through Friday. An automated voice messaging system is maintained during non-business hours, and reports are followed up on as quickly as possible. The Reno Direct number is listed on the TMStormwater.com website as the hotline to report spills and dumping.
Refrigerator magnets promoting this hotline are distributed by the SWPCC during public outreach events, encouraging the public to be the eyes and ears of the watershed. This message of asking
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the public to report questionable activities supports stewardship and a connection to the Truckee River.
NDEP and each jurisdiction also maintain published phone numbers for spill reporting. They are:
Nevada Division of Environmental Protection: (888) 331-6337 City of Reno, Environmental Control Department: (775) 334-2168 City of Sparks, Environmental Control Department: (775) 861-4152 Washoe County Health Department: (775) 861-4152
BMP Objectives:
1. To provide the public an easy way to report illicit discharges or other storm water related concerns 2. To alert agencies of potential threats to the MS4 Permit area or sewage conveyance systems
Truckee Meadows Regional Drainage Manual (GOV-04) The Truckee Meadows Regional Drainage Manual was updated in April of 2009. The purpose of this manual is to ensure consistency in analysis, planning and design of projects with flood control and drainage components within the Jurisdictional Entities (Reno, Sparks and Washoe County). This manual is a single reference for policies and criteria relating to drainage design and hydrology for the Truckee Meadows. Guidelines, rationale and rainfall/runoff calculations, and capture volumes are described in the manual. This reference manual assists staff with the regulation of future development, floodplain and storm water management within the region.
The Drainage Manual was prepared using current state-of-the-art technology and procedures. Due to the dynamic nature of urban storm drainage, amendments and revisions will be required periodically, as technology advances the state-of-the-art and experience is gained from the use of this Manual. It is envisioned that updates will occur at a minimum of every three years from the published date. The Drainage Manual is available for download from the Washoe County website: http://www.washoecounty.us/repository/files/7/tmrdm_final_043009.pdf.
BMP Objectives:
1. Promote, publicize and provide the Internet link to the manual to developers, planners and design engineers within the Truckee Meadows MS4 permit area 2. Provide assistance in keeping the information in the manual current and up to date
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Code Enforcement (GOV-05) The ability and resources to enforce the Storm Water Management Program through the associated codes and ordinances is critical to program success and ultimately reducing the discharge of pollutants within the MS4 permit area to the MEP. The co-permittees all have a Code Enforcement Division (or Department) charged with enforcing municipal codes, articles and ordinances. Storm water compliance is also enforced by storm water inspectors assigned to Community Development, Public Works or other divisions/departments within each jurisdiction. Typically code enforcement actions use public education as the primary measure to gain voluntary compliance with code and steers abatement measures through coordinated and cooperative measures. However, administrative penalties may be assessed to those who fail to comply with the municipal code.
Reported violations are turned over to the storm water program managers, storm water inspectors, or code enforcement officers in each jurisdiction. The first option is voluntary compliance. However, code enforcement officers, along with the City or County Building and Legal Departments/Divisions have the ability to issue stop work, and/or cease-and-desist orders, and ultimately levy fines.
BMP Objective:
1. Entities are to enforce applicable storm water codes and ordinances in the MS4 permit area in a timely and effective manner to reduce the discharge of pollutants to the MEP.
Plan Review (GOV-06) Plan review is the first opportunity that the co-permittees have to ensure that the waterways of the MS4 permit area are protected from the potential harmful effects of storm water runoff. Improvement drawings for construction and grading must be approved by the Building and Safety Division (or equivalent jurisdictional department) before issuance of permits. This applies to all incorporated and unincorporated areas in the permit area. Considerations during plan review include the location, type, slope, depth to groundwater, proximity of listed waters, soil permeability and sensitivity to groundwater recharge, percent impermeable surfaces, and the total size of soil disturbance. The Building and Safety Division (or equivalent jurisdictional department) requires that plans be prepared under the supervision of and signed by an engineer of suitable training and registration within the State of Nevada. The co-permittees have existing plan review procedures in place. Some education may be required to implement components in the 2010 MS4 Permit.
BMP Objectives:
1. Review building and development plans with respect to storm water constraints and the protection of waterways within the MS4 permit area 2. Maintain guidance documents so that developers and designers understand storm water considerations and constraints within the Truckee Meadows
Truckee Meadows Storm Water Management Program 3-52 Section 4 – Management, Reporting and Assessment
Storm water quality management programs typically consist of activities, such as outreach and education, plan review, spill control prevention, inspections, waste collection programs, training, enforcement and monitoring. Performance of these activities must be assessed, managed and documented. A program, policy, or BMP that is not accomplishing its goal and objectives needs to be evaluated, reported and possibly redirected. In this section, aspects of management, reporting and program assessment are addressed. Aspects of SWMP management discussed in this section include coordination of stakeholders, BMP priorities during this permit cycle, and staff resources. Reporting requirements for the Annual Report to NDEP are summarized in a series of tables. The new permit requires several different assessments be made every year. These assessments include SWMP and BMP effectiveness assessments, determining the impacts of the program on impaired (TMDL and 303(d) listed) waters, and assessing the effect of the SWMP on drinking water quality and supplies. 4.1 Coordination and Stakeholders
The area known as the Truckee Meadows consists of the Cities of Reno and Sparks and the adjacent urbanized areas in the southern portion of Washoe County. The boundaries of this SWMP are the limits of the urbanized area within the Truckee Meadows Service Area (TMSA) as established by the Truckee Meadows Regional Planning Agency.
Based on the 2004 Interlocal Agreement (see Section 1.1.2), the Truckee Meadows Storm Water Permit Coordinating Committee (SWPCC) is responsible for the development, administration and implementation of this SWMP. The agreement establishes the SWPCC with two representatives per entity (i.e., City of Reno, City of Sparks and Washoe County). At the first meeting of each fiscal year, the committee elects one member to be the chairman. The City of Reno is responsible to provide the coordinator (Storm Water Permit Coordinator). The primary objective of the SWPCC is satisfying the NPDES MS4 Permit requirements. Typically, the committee meets once a month, on the third Thursday of the month. Meetings are conducted and noticed according to Nevada Open Meeting Laws.
Since the Nevada Department of Transportation (NDOT) owns and operates many miles of roadways within the permit area, NDOT is an important partner in reducing the pollution attributable to storm water runoff to the MEP within the permit area. The co-permittees have a 2001 Interlocal Agreement in place with NDOT that facilitates coordination on storm water pollution prevention activities.
In BMP EDU-04 (Partnerships and Affiliations) the SWPCC acknowledges and formalizes the importance of working collaboratively with our partners. The main objective of this BMP is for the SWPCC to maintain existing relationships with partners and look for shared opportunities to
Truckee Meadows Storm Water Management Program 4-1 Section 4 – Program Management, Assessment and Reporting continue education efforts and reduce pollution within the MS4 permit area to the MEP. A list of current partners is included below. As can be seen in the listing, our partners include several stakeholder- type groups and organizations like the Association of General Contractors, the Builders Association of Northern Nevada, the Truckee River Yacht Club and the Nevada Land Conservancy.
Examples of our current partners and affiliations are:
University of Nevada, Reno (UNR) UNR Cooperative Extension (UNCE) U.S. Fish and Wildlife Service (USFWS) Nevada Department of Wildlife (NDOW) Nonpoint Education for Municipal Officials (NEMO) Nevada Desert Research Institute (DRI) Association of General Contractors (AGC) Builders Association of Northern Nevada (BANN) Nevada Department of Transportation (NDOT) Nevada Division of Environmental Protection (NDEP) Keep Truckee Meadows Beautiful (KTMB) Washoe County School District (WCSD) The Nature Conservancy (TNC) Truckee River Flood Management Authority (TRFMA) Sierra Nevada Concrete Association American Society of Civil Engineers (ASCE) Truckee River Watershed Council Truckee River Yacht Club Washoe County Environmental Health, Air Quality branch Nevada Land Conservancy Nevada Water Resources Association (NWRA) American Public Works Association (APWA)
One of the most important stakeholders is the general public. Described in the BMPs developed for Outreach and Education are many of the committee’s efforts to engage this sector.
4.2 Priorities for Implementing BMPs
The new permit requires that the permittees describe new priorities for implementing structural and non-structural BMPs for each of the minimum control elements. Also required is the identification of measurable goals for the new BMPs, including the months and years in which the co-permittees will undertake required actions.
Truckee Meadows Storm Water Management Program 4-2 4-2 Section 4 – Program Management, Assessment and Reporting
BMP fact sheets were developed to address these requirements and are presented in Section 6 of this document. Most of the 45 BMP Fact Sheets developed document existing practices; however, several new (priority) practices have been identified. Most BMPs have multiple measurable goals. Also in each of the fact sheets is a table showing implementation status for each component of the BMP. Summarized in this sub-section are the month and year that the BMP components are to be initiated.
4.2.1 Permit Requirements for BMP Implementation
Section IV.A of the permit (Stormwater Management Program-General Requirements), contains the following provisions:
IV.A.13 The updated SWMP shall describe any new priorities for implementing structural and non-structural BMPs for each of the following elements: Public Outreach and Education; Illicit Discharge and Detection; Industrial Facility Monitoring and Control; Municipal Operations (MS4 maintenance activities and good housekeeping practices); Post-Construction Stormwater Management Program for New Development and Significant Redevelopment; a Construction Site BMP Program and Intergovernmental Coordination. IV.A.6 The updated SWMP shall identify the measurable goals for the new BMPs as appropriate, including the months and years in which the Permittees will undertake required actions.
4.2.2 BMP Implementation and Priorities
Summarized in Table 4-1 are the tasks scheduled for future (FY2011/12 through FY2014/15) implementation for both the new and enhanced BMPs. Also shown in Table 4-1 is the recommended year and month for implementation of each of the new or enhanced BMP components. Priorities are shown chronologically in Table 4-2. BMP components with the most recent date reflect a programmatic higher priority.
As an example, all of the Truckee Meadows storm water manuals and guidance documents are scheduled for updates every five years. The need for manual updates and a potential schedule can be consolidated into one meeting next April 2012. Some of the tasks were assigned dates to facilitate committee efficiency by reviewing multiple components during a single committee meeting (e.g., consideration of handbook and manual updates).
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Table 4-1. Task and Implementation Schedule for New and Enhanced BMP Components
BMP FY FY FY FY FY BMP # BMP Title Status Task or Item 2010/11 2011/12 2012/13 2013/14 2014/15 Construction Site BMP Meet the schedule for review and possible update of the Feb., CONST-03 Existing X Handbooks handbooks 2012 Public Outreach and Promote watershed tools for teachers to use in the March, EDU-01 Education – Typical Existing X X X classroom and place a link on the web 2012 Events Create bill inserts once per year on storm water pollution Feb., X X X prevention 2012 Public Outreach and Digitize handouts and upload to www.tmstormwater.com Feb., EDU-02 Existing X X X Educational Materials website 2012 Work with Nevada Discovery Museum to provide Feb., X X X educational materials for visitors 2012 Regional Program Upgrade website to manage added public viewing from QR June, X X X Website coding 2012 EDU-05 Existing www.tmstormwater. Develop a Household Hazardous Waste page within March, X X com www.tmstormwater.com 2013 Post presentation on www.tmstormwater.com from March, teacher trainings on using the Truckee River Watershed Truckee River 2012 EDU-06 Existing Map Tool Watershed Map Tool Hand out educational postcards on the Watershed Map June, X X X Tool at community events 2012 City of Sparks and Washoe County to consider adding Municipal Codes and Feb., GOV-02 Existing ordinances and articles to better address post-construction X Ordinances 2014 storm water management activities Investigate the feasibility of developing a single IDDE Oct.,
Illicit Discharge Report database for use by the three co-permittees 2012 IDDE-01 Enhanced and Response Database Oct., If feasible, develop the database and methodology 2013 Create a website link to provide information about what Household Hazardous types of household materials are hazardous, community Mar., IDDE-05 Existing X X Waste Program collection events, and companies that provide disposal 2013 services in the Truckee Meadows Industrial and Feb., IND-05 Commercial Storm Existing Develop a schedule for possible handbook update 2012 Water BMP Handbook
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Table 4-1. Task and Implementation Schedule for New and Enhanced BMP Components, Continued
BMP FY FY FY FY FY BMP # BMP Title Status Task or Item 2010/11 2011/12 2012/13 2013/14 2014/15 Evaluate the feasibility of a more detailed map of storm May,
water runoff related features 2012 MS4-02 MS4 Mapping Enhanced Expand mapping to include privately and publicly May,
maintained structural controls 2013 Identification of New Review the BMPs used by other MS4 permit holders and April, MS4-05 New X X X Storm Water BMPs record any new BMPs for possible inclusion 2012 Review the CASQA guidance materials and develop the June, methodology and approach tailored for use in the Truckee 2012 Meadows Review the existing BMPs and measurable goals and June, determine their ability to adequately support the X X X Annual Effectiveness 2012 MS4-06 New assessment of outcome levels Assessment Perform a preliminary effectiveness assessment and Dec., identify any improvements required in the program or 2012 methodologies Perform an annual effectiveness assessment and develop Dec., X any new plan for improved program implementation 2013 Hold one annual meeting with staff from the TMWA and Jan., X X X WCDWR to discuss SW impacts on drinking water quality 2012 Consider the merits of water quality sampling to assist in Sep., X X X SWMP Effect on assessing the SWMP effects on drinking water 2012 MS4-07 New Drinking Water Quality Discuss the utility of developing a GIS tool to identify Sep., X relative risk of surface and groundwater to drinking waters 2012 Sep., If merited, develop the GIS based tool X 2013 Evaluate existing data to determine if SW runoff contributes June, to the 303(d) listing of water bodies within the MS4 permit X X X 2012 area. Continue activity each year as required MS4-08 Impaired Waters New If required, develop a listing of BMPs that may assist in June, mitigating the effects of storm water runoff on the 303(d) 2015 constituents
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Table 4-1. Task and Implementation Schedule for New and Enhanced BMP Components, Continued
BMP FY FY FY FY FY BMP # BMP Title Status Task or Item 2010/11 2011/12 2012/13 2013/14 2014/15 Storm Drain and Consider the need and usefulness of SWPCC review of field Dec., MUNI-01 Existing Channel Maintenance maintenance activities, protocols and data needs 2013 Maintenance of City and Identify department responsible for maintenance of various Feb., MUNI-03 Existing County Owned Facilities facilities; develop consistent reporting format 2013 Assess existing practices, evaluate staff certification levels June, and application and recording procedures between X X X 2012 departments and co-permittees Develop consistent reporting format intra-departmentally June, Pesticide, Herbicide and X X MUNI-04 Fertilizer Application New and between co-permittees 2013 Management - Internal Obtain NV certifications for co-permittee applicators and June,
evaluate NV program for training 2014 Long term development of pesticide, herbicide and fertilizer June,
application SOPs for each co-permittee 2015 Define the approach and timeline for developing a database Dec., POST-01 Land Development Existing of post-construction BMPs and controls 2012 TM Structural Controls Feb., POST-02 Existing Develop a schedule for possible manual update Design Manual 2012 Feb., POST-03 TM LID Handbook Existing Develop a schedule for possible handbook update 2012 TM Standard Design Feb., POST-04 Existing Develop a schedule for possible updates Guidance Worksheets 2012 Hold one annual meeting with staff and the TRFMA to April, discuss future regional flood control projects and potential X X X Future Regional Flood 2012 POST-05 New WQ issues Projects Consider the need for developing a check list or guidance May, X X X manual section to address WQ and flood projects. 2012
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Table 4-2. BMP Component Implementation Schedule by Required Date
Implementation BMP BMP Title Task or Item Date SWMP Effect on Drinking Hold one annual meeting with staff from the TMWA and MS4-07 Jan., 20