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Home My WebLink AboutO-12318J-03-081 1/23/03 12318 ORDINANCE NO. AN EMERGENCY ORDINANCE OF THE MIAMI CITY COMMISSION, WITH ATTACHMENT(S), AMENDING ORDINANCE NO. 12279, AS AMENDED, THE ANNUAL APPROPRIATIONS ORDINANCE, TO INCREASE CERTAIN OPERATIONAL AND BUDGETARY APPROPRIATIONS FOR FISCAL YEAR ENDING SEPTEMBER 30, 2003, TO REFLECT AN INCREASE IN THE TABLE OF ORGANIZATION AND THE ADDITION OF CERTAIN SPECIAL REVENUE FUNDS; CONTAINING A REPEALER PROVISION, A SEVERABILITY CLAUSE, AND PROVIDING FOR AN EFFECTIVE DATE. WHEREAS, the City Commission adopted Ordinance No. 12279, as amended, the Annual Appropriation Ordinance, on September 26, 2002, establishing revenues and appropriations for Fiscal Year ending September 30, 2003; and WHEREAS, it is necessary to revise certain operational and budgetary appropriations (see Appropriation Adjustment Chart, attached and incorporated); and WHEREAS, the proposed changes will result in a net increase of ten positions in the City's adopted Table of Organization; and WHEREAS, two additional special revenue funds have been established to reflect the rollover of surpluses from the prior year as required by the Financial Integrity Ordinance; 12318 i 4 NOW, THEREFORE, BE IT ORDAINED BY THE COMMISSION OF THE CITY OF MIAMI, FLORIDA: Section 1. The recitals and findings contained in the Preamble to this Ordinance are adopted by reference and incorporated as if fully set forth in,this Section. Section 2. Ordinance No. 12279, adopted September 26, 2002, as amended, the Annual Appropriations Ordinance for Fiscal Year ending September 30, 2003, is further amended in the following particulars: 1/ "Ordinance No. 12279 Section 1. The following appropriations are made for the municipal operations of the General Fund for Fiscal Year ending September 30, 2003: GENERAL FUND Appropriations Departments, Boards, and Offices: Municipal Services Non -Departmental Accounts (NDA) TOTAL GENERAL FUND Reserves Based on Financial Integrity Principles: (Included in General Fund - NDA) Contingency Reserves Undesignated Reserves Total Reserves 24,S�a 26,863,688 o =7 -6S-2 59, 348, 379 38S,;97,99; $390,449,821 $5,000,000 $2,328,241 2,228,241 $7,328,241 7,228,241 �i Words and/or figures stricken through shall be deleted. Underscored words and/or figures shall be added. The remaining provisions are now in effect and remain unchanged. Asterisks indicate omitted and unchanged material. Page 2 of 5 12318 Section 2. The above appropriations for the General Fund are made based on the following sources of revenues for Fiscal Year ending September 30, 2003: GENERAL FUND Taxes Licenses and Permits Inter -governmental Revenues Charges for Services Fines and Forfeits Miscellaneous Revenues Non -revenues Internal Service Funds $165,831,576 8,405,200 1,147,597 92,584,618 3,960,000 15,554,000 21,948,905 27,090,732 45,876,098 TOTAL GENERAL FUND 385,'^—moi $390,449,821 Section 5. The following appropriations for made for the municipal operations of Special Revenue Funds for Fiscal Year ending September 30, 2003: SPECIAL REVENUE FUNDS City Clerk Services Community Development Convention Center Economic Development and Planning Services Fire Rescue Services Health Facilities Authority Law Enforcement Trust Fund 8,064,087 Local Option Gas Tax Neighborhood Enhancement Teams Other Special Revenue Funds Parks and Recreation Services Police Services Public Service Taxes Public Works Services IT Strategic Plan Implementation Public Facilities Stormwater Utility Appropriations $219,422 67,575,330 7,058,292 5,387,798 5,268,997 5,287,497 116,654 0 5,650,880 530,070 601,817 1,467,765 17,117,430 56,299,393 1,088,968 698,481 494,125 0 TOTAL SPECIAL REVENUE FUNDS $144,979,13Q $177,056,192 Section 6. The above appropriations for Special Revenue Funds are made based on the following sources of revenues for Fiscal Year ending September 30, 2003: SPECIAL REVENUE FUNDS Revenues All Sources $174,979,138 $177,056,192 TOTAL SPECIAL REVENUE FUNDS $17479,135 $177,056,192 Page 3 of 5 Section 3. All ordinances or parts of ordinances, insofar as they are in conflict with provisions of this Ordinance are repealed. Section 4. If any section, part of section, paragraph, clause, phrase or word of this Ordinance is declared invalid, the remaining provisions of this Ordinance shall not be affected. Section 5. This Ordinance is declared to be an emergency measure on the grounds of urgent public need for the preservation of peace, health, safety, and property of the City of Miami, and upon further grounds of the necessity to make the required and necessary payments to its employees and officers, payment of its debts, necessary and required purchases of goods and supplies and to generally carry on the functions and duties of municipal affairs. Section 6. The requirement of reading this Ordinance on two separate days is dispensed with by an affirmative vote of not less than four-fifths of the members of the Commission. Page 4 of 5 1,213 1 ` Section 7. This Ordinance shall become effective immediately upon its adoption and signature of the Mayor.2/ PASSED AND ADOPTED BY TITLE ONLY this January , 2003. ATTEST: PRISCILLA A. THOMPSON CITY CLERK APPROVED LO Y 399:tr:AS:BSS CTNESS: 23rd day of This Ordinance shall become effective as specified herein unless vetoed by the Mayor within ten days from the date it was passed and adopted. If the Mayor vetoes this Ordinance, it shall become effective immediately upon override of the veto by the City Commission or upon the effective date stated herein, whichever is later. Page 5 of 5 i� Recommended Headcount 1 Changes Change Transfers Explanation General Fund ' Revenues Fiscal Year 2002 Elected Officials Surplus - Commissioners; Sanchez (46,000), Regalado Fund Balance - Management Reserves 319,018 (52,122), Winton (22,540), Gonzalez (31,470), Teele (22,041) and Mayor Diaz (144,845). Fund Balance -Management Reserves 1,413,709 Fiscal Year 2002 Surplus - Parks (221,103), Public Facilities (494,125) and IT (698,481). Fund Balance - Management Reserves 2,000,0001 1 Funding for the Mayor's Poverty Initiative from Fiscal Year 2002 Surplus. Strategic Initiative Reserves 1,000,000 $500K in Efficiency Improvement Studies funding and $500K for Civic Center Project. AT&T settlement reserves 410,0001 AT&T Settlement Reserves Fund balance. Total Revenue 5,142,727 Expenses I Municipal Services (XX) 1 NPDES Stormwater Program 2,265,000 10.0 Funding for the City's NPDES Program. Non -Departmental Accounts (92) 1 $174,173 of Commissioners' surplus to be allocated, per Commission direction, at a future date. $100K from Budget Reserve for un -anticipated expenses in excess of what was originally Reserve for Emergencies 274,173 budgeted in the FY'03 Adopted Budget. Reserve for Emergencies 500,000 Civic Center Project Funding Budget Reserve (Undesignated Reserves) (100,000) Additional funds required to cover expenses anticipated to be paid during the fiscal year. Per Commission direction, $500K from FY'02 Surplus to be designated into a Parks Special Revenue Fund. Per direction from Mayor Diaz to allocate the Mayor's Office FY'02 surplus to Contribution to Special Revenue Fund same Parks Special Revenue Fund. Additionally, per Financial Integrity Ord., which allocates the (Parks and Recreation) 865,948 Parks Department's prior year surplus to a Parks Special revenue Fund. Contribution to Special Revenue Fund Per Financial Integrity Ord., which allocates the -IT Department's prior year surplus to an IT (Information Technology) 698,481 Special Revenue Fund. Contribution to Special Revenue Fund Per Financial Integrity Ord., which allocates the Public Facilities Department's prior year surplus (Public Facilities) 494,125 to a Public Facilities Special Revenue Fund. Contribution to Capital Projects Reducing capital funding from Stormwater revenues for the funding of the NPDES Stromwater (Stormwater Funds) (2,265,000) Program being initiated by the City. Contribution to Special Revenue Fund (Mayoral Poverty Initiative) 2,000,000 To appropriate funds for the Mayoral Poverty Initiative. Per previous Commission direction, Ord. 12306 passed 12-12-02, which allocates a additional funds for the renovations at City Hall. Additionally, $500K of Strategic Initiative Funds for Contribution to Capital Pro'ects 410,000 Efficiency Improvement Studies, replacing $500K erroneously allocated from FY'02 Surplus. Expense Total: 5,142,727 1 10.0 _ I I Revenues / Expenses - General Fund 1 10.0 1 I Special Revenue Funds'' Fund 104 - Fire Rescue Services 1 I Wellness & Fitness Grant 16,000 Rollover of FY 2002 Fund Balance Coral Gables Hospital 2,500 Rollover of FY 2002 Fund Balance Fund 104 Total: 1 18,500 1 Fund 106 - Parks and Recreation Services 1 865,948 1 1 Surplus Rollover per Financial Integrity Ordinance. Fund 106 Total: 865,948 CIO Fiscal Year 2003 Appropriation Adjustments Page 1 of 2 1/27/2003 10:41 AM Revised • op I Page 1 of 2 1/27/2003 10:41 AM Revised • op 00 Fiscal Year 2003 Appropriation Adjustments Page 2 of 2 1/27/2003 10:41 AM Revised • • Recommended Headcount Changes Change Transfers Explanation Fund XXX - Public Facilities 494,125 Surplus Rollover per Financial Integrity Ordinance. Fund XXX Total: 494,125 I Fund XXX - IT Strategic Plan Implementation 698,481 Surplus Rollover per Financial Integrity Ordinance. Fund XXX Total: 698,481 Total Special Revenue Funds: 2,077,054 Page 2 of 2 1/27/2003 10:41 AM Revised • • CITY OF MIAMI, FLORIDA 14 INTER -OFFICE MEMORANDUM TO: The Honorable Mayor and Members DATE: January 10, 2003 FILE: of the City Commission SUBJECT: Emergency Ordinance Amending FY2003 Appropriations Ordinance No. FROM: REFERENCES: 12279 ez City Manager ENCLOSURES: It is respectfully requested that amendments to the FY2003 Annual Appropriations Ordinance No. 12279, as amended, be approved. These proposed changes to the Appropriations Ordinance make revisions, with adjustments to departmental budgets, to the City of Miami's adopted table of organization, as identified on the attachment to the emergency ordinance. Some of these changes include the appropriation of ten (10) additional personnel in the Municipal Services Department for the NPDES Program. After reviewing the 2001-2002 City of Miami's NPDES permit program, the Florida Department of Environmental Protection agency (DEP) placed the City on Notice and issued a warning letter of non- compliance. This letter and the supporting report credits the City's state of non-compliance and violations of the permits requirements directly to the lack of dedicated resources by the City to the NPDES permit program. In response, City staff met with DEP staff to discuss the program deficiencies and to develop a strategy to return to a compliance status. This strategy includes a dedicated budget, for personnel, equipment, training, and consulting services and reflects a strong commitment to an effort to bring the City of Miami back into compliance. Additionally, various Special Revenue funds are revised and adjusted for fund balance rollovers as well as grant funds. As stipulated in the financial Integrity ordinance, amounts for all offices whose surpluses rollover, have been included in this ordinance, specifically: Information Technology Department, Parks and Recreation Department, Public Facilities and Elected Officials. CAG /jr 1-2318 Jeb Bush Governor 6 Department oto Environmental, Protection Twin Towers Office Building 2600 Blair Stone Road Tallahassee, Florida 32399-2400 11 October 2002 Carlos A. Gimenez, City Manager City of Miami 3500 Pan American Drive Miami, Florida 32133 Alejandro Vilarello, City Attorney City of Miami 444 S.W. 2nd Avenue, Suite 945 Miami, Florida 32133 Re: Warning Letter # NPDES-SW-13-00099 Potential Violations of Permit No.: FLS000002 City of Miami Municipal Separate Storm Sewer System (MS4) Permit Gentlemen: David B. Struhs Secretary The purpose of this letter is to advise you of possible violations of law for which the City of Miami may be responsible and to seek your cooperation in resolving these matters. At the direction of the Department, annual inspections of the City of Miami Municipal Separate Storm Sewer System (MS4) were performed in July 2001 and July 2002 by a representative of Science Applications International Corporation (SAIC). SAIC serves as contractor to the Department as to various aspects of the Florida National Pollutant Discharge Elimination System (NPDES) stormwater program. The July 2001 inspection revealed potential violations of the City's MS4 permit prompting the Department to issue Non Compliance Letter #: NSW- FLS000002-VS, dated 13 November 2001, to which the City responded 11 January 2002. In July 2002, SAIC performed its annual inspection of the City's MS4, on behalf of the Department, during which the inspector evaluated the status of certain of the issues identified during the 2001 annual inspection. The inspection of the City's MS4, a review of pertinent documents, and discussions with City personnel, suggest possible violations of Permit No.: FLS000002, and consequently, Chapter 403, Fla. Stat., and Department rules promulgated thereunder. "More Protection, Less Process" Printed on recrded paper. Carlos A. Gimenez, City Manager Alejandro Vilarelio, City Attorney 11 October 2002 Page 2 of 7 The City of Miami may be in violation of Permit No.: FLS000002 as follows: A. Program for Detection/Elimination of Illicit Discharges. Part II, Section A, entitled Storm Water Management Program (SWMP;� Requirements, at paragraph 7, entitled Illicit Discharges and Improper Dispos31, requires the permittee(s) to implement an ongoing program to detect and eliminate (or require the discharger to the MS4 to eliminate) illicit discharges and improper disposal into the storm sewer system. These non-stormwater discharges shall be effectively prohibited through the use of inspections, ordinances and enforcement. The SAIC inspector met with the accountant for the City's NPDES program who advised that no money was budgeted for salaries under the NPDES program because no staff was working on the program. The accountant further noted that the City operates under complaint driven engineering practices and that no additional hiring is planned for the NPDES program. The City's NPDES coordinator advised that no illicit discharge complaints were received by the City or transferred from Miami Dade County Environmental Resources Management (DERM) to the City for investigation. The City NPDES coordinator also stated that the City staff is overburdened and not capable of dedicated attention to the illicit discharge/investigation, program. A City interoffice memorandum, dated 13 September 2002, confirmed a newspaper article stating that the City's stormwater utility revenues, which are placed in the City's general fund, are to be redirected to the City's capital improvement program. While ten illicit discharge investigations were noted in the Year 5 annual report, the NPDES coordinator stated that none of the City's inspectors has received any training in the detection of illicit discharges. The NPDES coordinator was unaware of any memorandum of understanding between the City and Miami Dade County whereby illicit discharge investigations would be addressed by the county within the City's jurisdiction. Accordingly, the City may be in violation of Part II, Section A, paragraph 7, of Permit No. FLS000002 and consequently, in violation of Chapter 403, Fla. Stat., pursuant to Section 403.161(1)(b), Fla. Stat., for which civil penalties may be assessed under Section 403.141, Fla. Stat. Carlos A. Gimenez, City Manager Alejandro Vilarello, City Attorney 11 October 2002 Page 3 of 7 B. Industrial High Risk Runoff Program. Part II, Section A, entitled Storm Water Management Program (SWMP) Requirements, at paragraph 8, entitled Industrial and High Risk Runoff, requires the permittee(s) to develop and implement a program to identify and control pollutants to the maximum extent practicable (MEP), consistent with State water policy, in stormwater discharges from any municipal landfills, hazardous waste treatment, storage, disposal and recovery facilities, facilities that are subject to EPCRA Title III, Section 313, and any other industrial or commercial discharge which the permittee(s) determine is contributing a substantial pollutant loading to the MS4. To fulfill its obligation under Part 11, Section A, paragraph 8, Permit FLS000002 required the permittee(s), at subparagraph a., to identify priority sites and implement a schedule of inspections to address, at a minimum, the eleven (11) classes of industrial activities set forth in 40 C.F.R. 122.26(b)(14). Additionally, to fulfill its obligation under Part ll, Section A, paragraph 8, Permit FLS000002 required the permittee(s), at subparagraph b., to develop and implement a monitoring program for facilities identified. Potential deficiencies under this program element are nearly identical to those stated for the illicit discharge element. It appears that no money is budgeted for salaries under the NPDES program and no staff are working on the program. Once again, the City interoffice memorandum, dated 13 September 2002, confirmed a newspaper article stating that the City's stormwater utility revenues, which are placed in the City's general fund, are to.be redirected to the City's capital improvement program. While 22 industrial site visits were suppose to have been conducted, the NPDES coordinator stated that none of the City's inspectors has received any training and did not know what to look for at industrial sites. The NPDES coordinator was unaware of any memorandum of understanding between the City and Miami Dade County whereby industrial high risk inspections would be addressed by the county within the City's jurisdiction. Accordingly, the City may be in violation of Part 11, Section A, paragraph 8, of Permit No. FLS000002 and consequently in violation of Chapter 403, Fla. Stat., pursuant to Section 403.161(1)(b), Fla. Stat., for which civil penalties may be assessed under Section 403.141, Fla. Stat. I Carlos A. Gimenez, City Manager Alejandro Vilarello, City Attorney 11 October 2002 i Page 4 of 7 C Construction Site Runoff Program. i Part II, Section A, entitled Storm Water Management Program (SWMP1 Requirements, at paragraph 9, entitled Construction Site Runoff, requires the permittee(s) to develop and implement a program to reduce the discharge of pollutants from construction sites to the maximum extent practicable (MEP) that is consistent with State Water Policy. To fulfill its obligation under Part 11, Section A, paragraph 9, Permit FLS000002 required the permittee(s), at subparagraph a., to require the use and maintenance of structural and non-structural best management practices to reduce pollutants discharged to the MS4 during the time of construction. Additionally, to fulfill its obligation under Part 11, Section A, paragraph 9, Permit FLS000002 required the permittee(s), at subparagraph b., to develop and implement a program for inspecting construction sites and for enforcing the requirement for control measures. Further, to fulfill its obligation under Part 11, Section A, paragraph 9, Pemnit FLS000002 required the permittee(s), at subparagraph c., to conduct appropriate education and training for construction site operators and those associated with the implementation of proper sediment and erosion control measures at construction sites. It is our understanding that none of the foregoing have been implemented and indeed the City of Miami does not have a Construction Site Runoff program as required by Part Il, Section A, paragraph 9, subparagLaphs a through c, of Permit No. FLS000002, which may be a violation of Chapter 403, Fla. Stat., pursuant to Section 403.161(1)(b), Fla. Stat., for which civil penalties may be assessed under Section 403.141, Fla. Stat. The absence of a Construction Site Runoff program, as required by Part Il, Section A, paragraph 9, of Permit No. FSLO60008, may have contributed to the sedimentation of receiving waters within the City of Miami into which the City of Miami MS4 discharges. Carlos A. Gimenez, City Manager Alejandro Vilarello, City Attorney 11 October 2002 Page 5 of 7 D. Funding Source For Permit Implementation. Part 11, Paragraph F, entitled Storm Water Management Program Resources, states: Each permittee shall provide adequate finances to implement their activities under the Storm Water Management Program. Each permittee shall also have a source of funding for implementing all other requirements included within this NPDES storm water permit. The City has a stormwater utility but appears not to use this dedicated funding source to assure compliance with its MS4 permit and proper implementation of the City's Storm Water Management Program. As noted hereinabove, The City's accountant for the NPDES program advised that no money was budgeted for salaries under the NPDES program because no staff was working on the program and that the City operates under complaint driven engineering practices and that no additional hiring is planned for the NPDES program. And again, the City interoffice memorandum, dated 13 September 2002, confirmed the newspaper article stating that the City's stormwater utility revenues are to be redirected to the City's capital improvement program. The failure to fund its obligations under its MS4 permit may have resulted in a violation of Part ll, Paragraph F, Storm Water Management Program Resources, which may be a violation of Chapter 403, Fla. Stat., pursuant to Section 403.161(1)(b), Fla. Stat., for which civil penalties may be assessed under Section 403.141, Fla. Stat. E Effective Prohibition of Non-Stormwater Discharges. Part I, Section D, of Permit No.: FLS000002, entitled Limitations on Coverage, sets forth the effective prohibition on non-storrimwater, discharge provision as required by Section 403(p)(3)(B)(ii) of the federal Clean Water Act. Elements of the Stormwater Management Program are specifically included to address non-stormwater discharges into the MS4 and include, but are not limited to, Part II, Section A, paragraph 7, Illicit Discharges and Improper Disposal; Part ll, Section A, paragraph 8, Industrial and High Risk Runoff; and, Part 11, Section A, paragraph 9, Construction Site Runoff. 12318- Carlos A. Gimene2 Alejandro Vilarello, 11 October 2002 Page 6 of 7 • City Manager City Attorney To the extent the City of Miami may implementation of these required elements Program, or reduced or terminated initial ei effectively prohibit the introduction of non -s which may in turn be a violation of Part I, S and Chapter 403, Fla. Stat., pursuant to Se which civil penalties may be assessed und( F. The Maximum have deferred the development and of its Stormwater Management forts, the City may have failed to tormwater discharges into its MS4 ection D, of Permit No.: FLS000002 ction 403.161(1)(b), Fla. Stat., for. ;r Section 403.141, Fla. Stat. Part II of Permit No.: FLS000002, entitled Storm Water Pollution Prevention & Management Program, states that the Stormwater Management Program (SWMP) shall achieve the effective prohibition" and "MEP" standards of Section 402(p)(3)(B) of the federal Clean, Water Act. Section 402(p)(3)(B) of the Clean Water Act requires that MS4 permits include "controls to reduced the discharge of pollutants to the maximum extent practicable, including management practices, control techniques and system, design and engineering methods, and such other provision as the Administrator or the State determines appropriate for the control of such pollutants." Elements of the Stormwater Management Program are specifically included to address the "effective prohibition" standard and reduce pollutants to the maximum extent practicable, the MEP standard, and include, but are not limited to, Part II, Section A, paragraph 7, Illicit Discharges and Improper Disposal; Part II, Section A, paragraph 8, Industrial and High Risk Runoff; and, Part II, Section A, paragraph 9, Construction Site Runoff. To the extent the City of Miami may have deferred the development and implementation of these elements of its Stormwater Management Program, or reduced or terminated initial efforts, the City may have thereby failed to reduce pollutants to the maximum extent practicable as required by Permit No.: FLS000002 which may in tum be a violation of Chapter 403, Fla. Stat., pursuant to Section 403.161(1)(b), Fla. Stat., for which civil penalties may be assessed under Section 403.141, Fla. Stat. G. 1 Based upon the July 2002 inspection' progress has been made toward correcting Non-compliance Letter. In fact, the internal it nnnonm that no significant identified in the of September 23187 Carlos A. Gimenez, City Manager Alejandro Vilarello, City Attorney 11 October 2002 Page 7 of 7 13, 2002, confirming the redirection of stormwater utility revenues, presents the appearance that the City intends to abandon the corrective measures promised in its 11 January 2002 response to the non-compliance letter as well as the City's minimal duties and obligations under its MS4 permit. All issues as set out in last year's Non-compliance letter appear to remain outstanding including the City's failure to maintain structural controls and to properly address stormwater issues at the City's fleet maintenance facility. Failure to comply with a permit issued by the Department may have civil, criminal and administrative ramifications pursuant to Sections 403.121, 403.131, 403.141, and 403.161, Fla. Stat. You are requested to contact Michael Bateman, NPDES Stormwater Program Administrator, at 850-921-9870 within fifteen (15) days of receipt of this Warning Letter to arrange a meeting to discuss this matter. The Department is interested in reviewing any facts you may have that will assist in determining whether any violations have occurred. You may bring anyone with you to the meeting that you feel could help resolve this matter. Please be advised that this Warning Letter is part of an agency investigation, preliminary to agency action in accordance with Section 120.57(5), Florida Statutes. We look forward to your cooperation in completing the investigation and resolution of this matter. Sincerely, Mimi Drew, Director Division of Water Resource Management Copy to: w� Eric Livingston, Chief, Bureau of Watershed Management J. Michael Bateman, P.E., NPDES Stormwater Administrator Winston K. Borkowski, NPDES Stormwater Program Attorney Geoffrey Rabinowitz, Compliance & Enforcement Manager Arthur Collins, U.S. Environmental Protection Agency �� .. Vit:_ .w � �•• i..: _ ..est•-av�,'::;n... ...< ,— <; �of ?_ r Submitted to. The State of Florida Department of Environmental Protection November 21, 2002 _.. S -- zz Submitted to. The State of Florida Department of Environmental Protection November 21, 2002 ST -ha of 'ffliami# CARLOS A. GIMENEZ CITY MANAGER November 21, 2002 Ms. Mimi Drew, Director Division of Water Resource Management Department of Environmental Protection Twin Towers Office Building 2600 Blair Stone Road Tallahassee, Florida 32399 P.O. BOX 330708 MIAMI. FLORIDA 33233-0708 (305)416-1025 FAX (305) 400-5043 Qaplr RE: Warning Letter #NPDES-SW-13-00099, Permit #FLS000002 City of Miami Municipal Separate Storm Sewer System (MS4) Permit Dear Ms. Drew: This letter is to serve as the cover for our formal reply to the above subject Warning Letter. Please be advised that I, along with the City Attorney, the Assistant City Manager for Operations, and the Director of our Public Works Department met in Tallahassee with Mr. Michael Bateman and his staff on November 6, 2002, to discuss the deficiencies and develop a plan to resolve those deficiencies. We found this meeting to be productive and helpful in getting us back on track. Your staff was concise in their analysis and constructive in their suggestions rather than punitive in nature. We are thankful for their support and attitude. Please note that the text of our response is formatted to follow the draft MS4 Stormwater Inspection Report provided to us at the Tallahassee meeting of November 6th. This response, which includes a dedicated budget for personnel, equipment, training, and consulting services, reflects the strong commitment of the City of Miami to bring our NPDES Storm Water Program into compliance. In fact, you will find that the -City annually supplements the storm water funding out of our General Fund in excess of $4 million. I am confident that the implementation of this program, which is immediate, will place the City of Miami in a more favorable light come the next site visit and will result in a cleaner environment — the ultimate goal of the NPDES Storm Water Program. Again, thanks to you and your staff for all the support. Sincerelv. CAG/FKR/sg c: Alejandro Vilarello, City Attorney Frank K. Rollason, Assistant City Manager, Operations Albert Dominguez, Acting Director, Department of Public Works 12318 STORMWATER INSPECTION REP T — YEAR 5 (SUMMARY) TABLE OF CONTENTS Page # APPROVED NPDES FUNDING FOR FY'03 ............................... ............................ ...............1 STRUCTURAL CONTROLS — MARGINAL.................................................................................3 Required Program Compliance..............................................................................................3 Actions Taken Toward Compliance for Year 5......................................................................... 3 Proposed Compliance Improvements Beginning Year 7 ........................................................... 3 CONSTRUCTION SITE CONTROLS — UNSATISFACTORY.......................................................4 RequiredProgram Compliance..............................................................................................4 Actions Taken Toward Compliance for Year 5.........................................................................4 Proposed Compliance Improvements Beginning Year 7 ........................................................... 5 MUNICIPAL WASTE FACILITIES — UNSATISFACTORY........................................................... 6 Required Program Compliance..............................................................................................6 Actions Taken Toward Compliance for Year 5.........................................................................6 Proposed Compliance Improvements Beginning Year 7 ...........................................................6 ILLICIT DISCHARGE CONTROLS — MARGINAL.......................................................................7 RequiredProgram Compliance..............................................................................................7 Actions Taken Toward Compliance for Year 5......................................................................... 8 Proposed Compliance Improvements Beginning Year 7 ...........................................................9 HIGH RISK AND INDUSTRIAL FACILITY CONTROLS — UNSATISFACTORY ..........................10 Required Program Compliance..............................................................................................10 Actions Taken Toward Compliance for Year 5.........................................................................10 Proposed Compliance Improvements Beginning Year 7...........................................................11 PEST, HERB, AND FERTILIZER APPLICATION — SATISFACTORY..........................:..............12 RequiredProgram Compliance..............................................................................................12 Actions Taken Toward Compliance for Year 5.........................................................................12 Proposed Compliance Improvements Beginning Year 7...........................................................12 MONITORING RECORDS — SATISFACTORY.............................................................................12 RequiredProgram Compliance..............................................................................................12 Actions Taken Toward Compliance for Year 5.........................................................................12 Proposed Compliance Improvements Beginning Year 7...........................................................12 ROADWAYS— SATISFACTORY................................................................................................ 13 RequiredProgram Compliance..............................................................................................13 Actions Taken Toward Compliance for Year 5.........................................................................13 Proposed Compliance Improvements Beginning Year 7...........................................................14 Exhibit # 1: Department of Public Works Bulleting Nos. 25 (4 pages) and 26 (1 page) and Engineering Specifications Misc. 35-89-6 (4 pages) ...................... 15 Exhibit #2: Violation of Permit Notice and Dewatering Permit (2 pages) .................................... 24 Exhibit # 3: Qualified Stormwater Management Inspector (5 pages)............. .............................27 12318 MS4 STORMWATER INSPECTION REPORT — YEAR 5 (SUMMARY) TABLE OF CONTENTS (CONTINUED) Page # Exhibit # 4: "Red Stamp" and Additional "Red Stamp................................................................ 32 Exhibit # 5: Section 400-6 Discharge of Construction Excavation Waste Water (2 pages)......... 34 Exhibit # 6: Erosion and Sediment Control Inspection Form ...................................................... 36 Exhibit # 7: GSA Waste Disposal Records Year 5......................................................................37 Exhibit# 8: Industrial Inspection Form (2 pages)........................................................................38 Exhibit # 9: Section 4.9 — Narrative Report for Spill Response (2 pages)...................................40 Exhibit # 10: Pamphlets and Brochures......................................................................................42 Exhibit # 11: High Risk / Industrial Facilities.............................................................................. 43 Exhibit # 12: Top 9 Critical Industrial Sites..................................................................................44 Exhibit # 13: Industrial Sites with Overflow Discharge to the MS4..............................................45 12318 • Approved NPDES Funding for FY 103 Salaries (including overhead and fringes) Recurring Professional Engineer III $ 112,000 Professional Engineer II $ 100,000 Engineer I $ 80,000 Engineer Technician III (4) $ 256,000 GIS Technician $ 96,000 Senior Accountant $ 80,000 Typist Clerk III $ 40.000 Total S 764,000 Expenses Training, travel and per diem $ 15,000 Office supplies and printing $ 8,500 Chemical testing equipment and kits $ 2,500 Communication $ 2,500 Books, Publications, Memberships $ 1,500 Total $ 30,000 Capital Outlay t Non -Recurring Office Equipment $ 30,000 Field equipment (Radios, Sewer inspect. cameras, Laptops, etc.) $ 28,000 Vehicles (4) $ 65,000 Total $ 123,000 Consultant Services Professional Services Services Include: Laboratory testing, Sampling, and technical Total S 350,000 Contractual Services System cleaning contract Canal and water front cleaning Total Sub -Total Program Total $ 750,000 4. $ 330,000 $1,105,000 $2,249,000 S 123,000 S2,388,000 12318 t City of Miami Stormwater Utility Trust Fund FY `03 Revenues: $ 8,962,242 Expenditures: Stormwater-related Costs in Fire, Solid Waste and Public Works NPDES Permit Program Capital Projects Total $ 2 FY 2003 FY 2003 General Fd. Allocation Full Cost Subsidy 4,125,000 8,517,220 (4,392,220) 2,388,000 2,388,000 - 2,449,242 2,449,242 - 8,962,242 13,354,462 (4,392,220) 12318 TER INSPECTION REPO— YEAR 5 STRUCTURAL CONTROLS -MARGINAL Required Program Compliance: • Storm Water Treatment Ponds: None within the City of Miami. • 4 Pump Stations: • Inspection frequency Semi-annually. • Maintenance frequency as -needed basis. • Exf+ltration Trench: • Inspection frequency Semi-annually. • Maintenance frequency as needed basis. • Pollution Control Boxes: • Inspection frequency annually. • Maintenance frequency as needed. Actions Taken Toward Compliance for Year 5: • Storm Water Treatment Ponds: None within the City of Miami. • 4 Pump Stations: • Inspection frequency Weekly by Condo Electric, Inc. • Maintenance frequency Weekly by Condo Electric, Inc. • Exfiltration Trench: • Inspections were performed during the pollution control box site visits. • Maintenance by Public Works included cleaning of 86,713 linear feet of pipe, and 114 drainage wells. • Maintenance by a private contract, funded by FEMA included cleaning of 168,188 lin. ft. of pipe citywide. • Pollution Control Boxes: • Inspections were performed at 957 complaint locations. • Maintenance included the cleaning of Fairlawn Outfall and West End Outfall pipes. • Inspection included the TV survey Wagner Creek Culvert for illicit connections. • Maintenance by Public Works included cleaning of 2,674 inlets and 304 manholes. • Maintenance by private contract funded by FEMA included the cleaning of 2,110 structures citywide. Proposed Compliance Improvements Beginning Year 7: • 4 Pump Stations: • Inspection frequency Weekly by private contractor. • Maintenance frequency Weekly by private contractor. • Exfltration Trench: • Inspection frequency semi-annually, performed by four (4) trained field inspectors assigned to each quadrant of the City based on a prescribed schedule in addition to complaints. A summary of inspections will be included in annual reports. • Maintenance frequency as needed basis, summarized in annual reports. Pollution Control Boxes: • Inspection frequency annually, performed by four (4) trained field inspectors assigned to each quadrant of the City based on a prescribed schedule in addition to complaints. A summary of inspections will be included in annual reports. • Maintenance frequency as needed summarized in annual reports. 3 TER INSPECTION REPQM — YEAR 5 CONSTRUCTION SITE CONTROLS -.UNSATISFACTORY Required Program Compliance: Construction site runoff — site planning &structural and non-structural Controls: • Provide Code Regulations related.to erosion and sediment controls. Construction site runoff — inspection and enforcement: • Enforcement frequency as -needed based on demonstrated lack of prevention control. • Maintain internal log of inspections performed. • Provide proper training of personnel in sediment and erosion control. Construction Site runoff — site operator training: • Implement "Red Stamp" program. • Develop procedures to notify building permit applicants of NPDES regulations for construction site runoff. Include summary of procedures in annual reports. • Implement procedures to notify building permit applicants of NPDES regulations for construction site runoff. Actions Taken Toward Compliance for Year 5: Construction site runoff — site planning & structural and non-structural Controls: • Code Regulations and Engineering Standard were authorized and implemented in Year 2; however, a copy was not included in the Year 5 report. Attached is a full copy of all regulation and standards. (Exhibit # 1) • A "stop work" order is the primary enforcement tool for compliance. Monetary penalties are enforced for speck code violations. • Construction site runoff — inspection and enforcement: • Inspection and enforcement was conducted by Public Works Line and Grade and Code Enforcement staff during routine set back inspections and in response to identified problem construction sites and complaints. • Internal log of "Violation of Permit Notices" and "Dewatering into Right of Way" permits were performed by each inspector. Seven (7) Notices and 7 permits were issued in Year 5. Samples of each are attached for your review. (Exhibit # 2) • Five DEP Qualified Erosion and Sediment control inspectors have been trained. Certificates attached. (Exhibit # 3) • Two Engineers have received DEP Certified training as official trainers. • Construction Site runoff — site operator training: • Implemented "Red Stamp" program. Sample "red stamp" attached. (Exhibit # 4) • Procedures have been developed to notify building permit applicants of NPDES regulations for construction site runoff. • Implemented .procedures to notify building permit applicants of NPDES regulations for construction site runoff. • Implemented erosion control methods on all construction projects. Attached is a copy of Section 400-6 of the City's Standard Contract Documents and Specifications. (Exhibit # 5) 4 �e�� MSTORMWATER INSPECTION REPO — YEAR 5 (SUMMARY) CONSTRUCTION SITE CONTROLS — UNSATISFACTORY (Continued) Proposed Compliance Improvements Beginning Year 7: The City Code Regulations, Engineering Standards and notification stamps are all in place. The procedure to notify all contractors has been established. The following improvements will enhance notification, inspection and enforcement of erosion and sediment control of construction site runoff: • All appropriate Building and Zoning Inspectors, Public Works Line and Grade Inspectors, Capital Improvements Construction Inspectors, and appropriate Code Enforcement Inspectors assigned to the City's NET Service Center will be trained and qualified, in accordance with DEP regulations, in erosion and sediment control inspection and enforcement. Training will be accomplished within 1 year. • Attach erosion and sediment control plan details and bulletin requirements to each and every set of site construction plans. • Include erosion and sediment control requirements in Division 2, Special Provisions, of the City of Miami Construction Specification Book and include details in Division 5, Engineering Standards on all City of Miami Construction projects. • Notice of Intent — NOI for 1 acre and more will be required after March 2002 by plans reviewers and construction inspectors. • Appropriate inspectors will maintain a log, by completion of inspection report, or erosion and sediment control site inspections. (Exhibit # 6) • Inspections will be conducted at City Construction projects during each site visit inspections. • Inspection of building sites will be conducted at time of line and grade inspection, as needed during routine building inspections and in response to complaints. • All inspections and enforcement action will be documented in the annual reports. � 5 12318 TER INSPECTION REPOJ&— YEAR 5 MUNICIPAL WASTE FACILITIES - UNSATISFACTORY Required Program Compliance: • Municipal Waste Facilities: • Provide maintenance records for exfiltration system annually. Actions Taken Toward Compliance for Year 5: Municipal Waste Facilities: • The exfiltration drainage system and the pollution control structures protecting the exfiltration trench are services regularly by IPC/Magnum Environmental Services. IPC/Magnum performed inspections and cleaning of the pollutant control structures as shown on the attached maintenance record for this facility. (Exhibit # 7) Based on their inspection report, the pollution control structures functioned properly by protecting the exfiltration trench and no maintenance of the trench itself was required during the fifth year of the permit. This service fully complied with the requirements of the City's NPDES permit. • In addition, the City's General Services Administration properly maintained the City's fleet by collecting and disposing / recycling the following items further protecting the ground and surface waters: • 1,315 gal. Used coolant. • 3,340 gal. Oily water. • 3,550 gal. Sludge. • 2,900 lbs. Used oil filter. Proposed Compliance Improvements Beginning Year 7: • A more detailed report and inspection records from the City's maintenance contractor will be included in the City's annual reports. • A City NPDES inspector will verify the contractors maintenance report monthly. TER INSPECTION REPOt41 YEAR 5 (SUMMARY) ILLICIT DISCHARGE CONTROLS -MARGINAL Required Program Compliance:, • Illicit discharges and improper disposal — inspections, ordinances and enforcement measures: • Enforce City Ordinance 6145 and County Code section 24-11(3) controlling illegal discharges to surface waters and storm sewers. • Illicit discharges and improper disposal — Field screening. • Conduct field screening of MS4 for illicit discharges and improper disposal and maintain a log record. • Collect inventory information of outfalls, including updates to MS4. • Illicit discharges and improper disposal — Investigations of Suspected illicit and/or improper disposal: • Implement investigative procedures to identify, report, and terminate sources of illicit connections. • Provide training of appropriate staff in identifying and reporting illicit discharges and illicit connections. • Illicit discharges and improper disposal — Spill prevention and response: • Provide training of appropriate personnel in spill prevention and response and in techniques to mitigate pollutant discharges from spills to the MS4 and surface waters. • Illicit discharges and improper disposal — Public notification: • Implement public awareness and reporting annually. • Maintain citizen complaint log for illicit discharges annually. • Illicit discharges and improper disposal — Oil, toxics and household hazardous waste control: • Update City/County negotiations on additional oil & haz. waste collection site. • Implement outreach program. • Actively promote and support a voluntary stenciling program. • Illicit discharges and improper disposal — limitation of sanitary sewer seepage: • Implement program to limit sanitary sewer seepage to MS4. • Advise appropriate utility owner of any wastewater contamination during field screening or routine inspections. MWATER INSPECTION REPOFA&k- YEAR 5 ILLICIT DISCHARGE CONTROLS - MARGINAL (Continued) Actions Taken Toward Compliance for Year 5: • Illicit discharges and improper disposal — inspections, ordinances and enforcement measures: • All City inspectors are authorized to enforce City and County Code Regulations. • Illicit discharges and improper disposal — Field screening annually: • An inventory and field screening of all 262 outfalls was completed in Years 2 and 4 by Consulting Engineering and Science (CES). From this information, 9 sites were identified for follow-up investigations; however, no dry weather flow was detected during subsequent visits.. Collection and analysis will resume once dry weather flow resumes. • Illicit discharges and improper disposal — Investigations of Suspected illicit and/or improper disposal: • No complaints of violations were received in Year 5 from citizens or City inspectors that prompted an investigation and formal report. As a follow-up verification, 22 spot investigations of industrial sites were conducted at the close of Year 5 that did not reveal violations. Sample attached. (Exhibit # 8) • Initial training of staff to identify illicit discharges was informal. Formal training is currently underway via videotape and power point lessons. • Illicit discharges and improper disposal — Spill prevention and response: • Fire and Rescue Department Haz-Mat team conducts monthly training and multi agency drills. Complete analysis in fifth year report attached. (Exhibit # 9) • Illicit discharges and improper disposal — Public notification: • Complete analysis in fifth year report. Program includes broadcasting Hotline numbers on City Cable Channel 9. • Complaints are logged on the City's Complaint Tracking System database. • Illicit discharges and improper disposal — Oil, toxics & household hazardous waste control: • The City continues to use exiting County collection sites for residential disposal needs. • Outreach program for oil and hazardous Waste Control distributed to the public includes those materials shown on the enclosed attachment. (Exhibit # 10) • Stenciling of drainage inlets was completed in the critical Wagner Creek drainage basin area. • Illicit discharges and improper disposal — limitation of sanitary sewer seepage: • City Code prohibits discharge to sanitary sewers from any sources other than wastewater. • Advise appropriate utility owner of any wastewater contamination during field screening or routine inspections. • City Code and County Code prohibits septic tank permits to be issued where sanitary sewer service is available. • Coordinate with County on discovery of illegal connections between sanitary sewer system and storm water sewer system. • Complete d a $1'A'9,500 project to disconnect several sanitary/ storm sewer cross connections discovered by smoke testing. • Continue cooperation with Miami -Dade Water and Sewer Department and Miami - Dade Department of Environmental Resources Management to control sanitary sewer seepage into the drainage systems. Permits and information gathering was expedited for sanitary sewer upgrading project. MTORMWATER INSPECTION REPO- YEAR 5 (SUMMARY) ILLICIT DISCHARGE CONTROLS — MARGINAL (Continued) Proposed Additional Compliance Beginning Year 7: • Continued dry weather sampling and testing of high priority outfalls identified during initial dry weather screening. • Coordinate consultants' work with City NPDES field inspectors. • Continue formal training and certification of appropriate City inspectors for illicit discharge identification and enforcement utilizing videotape and power point presentations and video lessons. • Implement a routine schedule of illicit detection investigations by four NPDES City inspectors assigned to the quadrants of the City. • Enter into consultant agreement for sampling and testing of identified illicit discharge locations. • All investigations, sampling, testing and eventual enforcement will be logged and summarized in annual report. • Within the next year, the City will enter into a formal agreement with Miami -Dade County for the disposal of oil and hazardous household waste. • Stenciling program will continue to the next highest ranking critical drainage basin. • Continue cooperation with Miami- Dade County in identifying and disconnecting illegal connections to the sanitary sewer system. .g - STORMWATER INSPECTION REP — YEAR 5 I (SUMMARY) HIGH RISK AND INDUSTRIAL FACILITY CONTROLS - UNSATISFACTORY Required Program compliance: Industrial and high risk runoff — identification of priorities and procedures for inspections: • Develop inventory of existing high risk facilities discharging to MS4 frequency annually. • Prioritized identified high risk facilities. • Develop procedures for inspection of identified high risk facilities and include summary of procedures and inspection schedule frequency annually. • Begin inspections of high risk facilities and log results. • Maintain list of industrial sources discharging to MS4 and update annually. Industrial and high risk runoff — Monitoring: • Provide description of Monitoring program for the high risk facilities discharging into MS4. • Implement Monitoring Program. Actions Taken Toward Compflance for Year 5: Industrial and high risk runoff — identification of priorities and procedures for inspections: • A complete inventory of high risk/ industrial facilities in the City was completed in Year 1 of the NPDES permit. Attached is a comprehensive list. (Exhibit # 11) • Based on the dry weather screening results completed in Year 4, the most critical industrial sites were identified. The top 9 critical sites are identified on the attached list. (Exhibit # 12) • Training of staff for high risk / industrial facility inspection has been informal. Subsequent to Year 5, formal training is being conducted. The illicit detection program and the high risk/ industrial facilities control program are linked and investigative procedures are complementary to both. A procedure to jointly inspect high risk/ industrial sites, in accordance with DERM inspection criteria, was developed based on dry weather screening results and complaints. This procedure is described in detail in Year 1 of the City's annual report and was implemented during subsequent reporting years. As reported in the illicit section, dry weather flow was not detected at the critical site locations and no complaints were received by the Public Works Department. As a result, no formal inspection reports were completed in Year 5. Follow up verification of 22 industrial sites was conducted at the close of Year 5, and no violations were identified. Sample of one inspection report us enclosed. (Exhibit # 8) • The list of industrial sites with overflow discharge to the MS4 remains unchanged. Attached is a copy of the list. (Exhibit # 13) Industrial and high risk runoff — Monitoring: • No formal monitoring was conducted in Year 5. 10 MTORMWATER INSPECTION REPC4— YEAR 5 (SUMMARY) HIGH RISK AND INDUSTRIAL FACILITY CONTROLS — UNSATISFACTORY (Continued) Proposed Compliance Improvements Beginning Year 7: • Appropriate staff will be formally trained in high risk and industrial facility including four (4) technicians positions exclusively assigned to NPDES inspections in the City's quadrants within the next year. • Each industrial site located within a discharge basin will be inspected annually. Follow-up investigation as required. • Each industrial site with an overflow discharge will be investigated semi-annually with follow- up inspections if violations are identified. • The City will retain an environmental consultant to develop a program for the monitoring of the critical industrial sites identified on the attached list (Exhibit # 12) within year 7. If necessary, the consultant will include in the program testing in accordance with Part 11.8.b on page 22 of the City's NPDES permit. • The City and consultant will implement the monitoring program develop by the consultant within Year 7 and subsequent years. TER INSPECTION REP— YEAR 5 (SUMMARY) PEST, HERB, AND FERTILIZER APPLICATION - SA71SFACTORY Required Program Compliance: • Pesticide, Herbicide, Fertilizer: • Evidence of certification and licensing. • implement program for reduction, proper application, mixing and storage. • Attendance of vendor sponsored seminars. • Maintenance of safety data sheets for materials and storage. • Develop outreach program for reduction of fertilizers as needed. • Implement public outreach education program frequency by -annually. Actions Taken Toward Compliance for Year 5: • Two (2) Register Pesticide Applicators in the Parks Department. Certificates are included in the fifth year report. • One (1) Register Pesticide Applicator in Melreese Golf Course. Certificates are included in the fifth year report. • Applied pesticides, herbicides, and fertilizers complying with MEP discharge. -Data sheets are included in the fifth year report. • Registered user attends monthly vendor sponsored meetings. • Continue reliance on slow release fertilizers, pesticides and herbicides. • Educational videos utilizing City Cable Channel 9. Proposed Compliance Improvements Beginning Year 7: • Continue with the Stenciling "do not pollute" program. • Update Public information brochures to refer City of Miami web and contact numbers. • Maintain Current Certification and Licensing. MONITORING RECORDS -,SATISFACTORY Required program compliance: • Monitor and record all 262+ outfalls every two years — CONSULTANT • Implement a GIS record of the storm sewer system with all the existing and proposed structures. Actions Taken Toward Compliance for Year 5: • Recording and screening of all 262 outfalls ahs been completed. • Priority outfalls for additional sampling and testing have been identified. Proposed Compliance Improvements Beginning Year 7: • Enter into consultant agreement to continue dry weathering screening of outfalls and sampling and testing of high priority sites. • Implement a GIS record of the storm sewer system with all existing structures and systems. _12 - STORMWATER INSPECTION REPO%IL— YEAR 5 ROADWAYS - SATISFACTORY Required Program Compliance: Roadway Maintenance: • Structural control maintenance. • Litter control program description: 1. enforcement 2. solid waste pickups 3. street sweeping 4. pressure cleaning 5. litter container service 6. blower service 7. vactor truck 8. education • Street sweeping program frequency annually. • Reevaluate routs for street sweeping and load reduction. • Implement road repair practices frequency as -needed. • Implement program to reduce pollutants in storm water runoff from municipal facilities frequency as needed. Actions Taken Toward Compliance for Year 5: • Roadway Maintenance: Litter control program: • Structural Control Program addressed under "Structural_ Controls" topic (page 3) • Solid Waste purchased 800 litter containers. • Enforcement of 8,211 inspections, 3,154 Warning notices, 850 sanitation code enforcement civil violations. • Solid Waste pickups: frequency twice per week household garbage collection and once a week collection of large trash/bulky waste, collection of recyclable materials: 178,853 tons of debris. • Street sweeping: seven nights per week along arterial roads and main commercial corridors including weekly sweeping of produce area at Upper Wagner Creek: 30 miles/day with 7 sweepers: 2,000 tons a year. • Purchased 2 pressure cleaning machines. • 1,300 litter containers emptied seven nights per week. • Blower service for cleaning streets and sidewalks citywide. • Vactor truck cleaning addressed under "Structural Controls" topic (page 3) • Citywide education by distributing flyers, brochures, broadcasts public service at Channel 9. • Street sweeping program implemented. -' • Street sweeping routes prioritized as reported above. • Implement road repair practices frequency as -needed. • Implemented program to reduce pollutants in storm water runoff from municipal facilities: 1,315 gal. used coolant and 3,340 gal. of oily water disposed properly. �13 . II YEAR 5 ROADWAYS — SA77SFACTORY (Continued) Proposed Compliance Improvements Beginning Year 7: • Continue to implement SWMP, and the standard road repair practices to reduce pollutants. • Training and educating of additional inspectors/ engineers and personnel (BMP and Erosion Control) • Daily Spill kits on all trucks and coordination with the Haz-Mat team (Fire - Rescue). • Daily Litter Control Enforcement (Container Service). • Weekly Solid Waste Pick—up Program. • Annual Street Sweeping for NPDES routing — CONTRACT specifically for NPDES program. • Annual Pressure Cleaning Program — CONTRACT specifically for NPDES program. .14 1 - 9.231