Central Washington University
OP-23: Rainwater Management

Illicit Discharge Detection and Elimination- This element of the SWMP requires that CWU: Regulatory Requirements: (1) develop and adopt appropriate policies that prohibit nonstormwater (illicit) discharges and illegal dumping; (2) develop and implement an enforcement plan to ensure compliance with the illicit discharge policies; (3) develop a map of the MS4, showing the location of all known storm drain outfalls, labeling the receiving waters, and delineating the areas contributing runoff to each outfall; (4) conduct field inspections and visually inspect for illicit discharges at all known outfalls; (5) develop procedures for characterizing illicit discharges, spills, or illegal dumping, and procedures for tracing and removing sources of illicit discharges; (6) develop and implement a spill response plan that includes coordination with a qualified spill responder; (7) provide adequate training for relevant staff; (8) keep records of inspections and follow-up activities, staff training, and other related items. Construction Site Stormwater Runoff Control- This element of the SWMP requires that CWU: Regulatory Requirements: (1) comply with all City ordinances, rules, and regulations that govern construction phase stormwater pollution prevention measures; (2) obtain coverage under the General NPDES Permit for Stormwater Discharges Associated with Construction Activities for all applicable construction projects under the control of CWU; (3) coordinate with the City regarding construction projects owned and operated by other entities that have the potential to discharge into CWU’s storm sewer lines to ensure that the City achieves compliance with its own ordinances; (4) provide training to educate staff in erosion and sediment control best management practices (BMPs) and requirements; (5)coordinate with Ecology and the City to provide access for inspection of construction sites or other land disturbances during the active grading and/or construction period. Post-Construction Stormwater Management for New Development and Redevelopment- Regulatory Requirements: This element of the SWMP requires that CWU: (1) comply with all City ordinances, rules, and regulations that govern post-construction stormwater pollution prevention measures; (2) coordinate with the City regarding projects owned and operated by other entities that have the potential to discharge into CWU’s storm sewer lines to ensure that the City achieves compliance with its own ordinances. Pollution Prevention and Good Housekeeping for University Operations- Regulatory Requirements: CWU must develop and implement a municipal operation and maintenance (O&M) plan to minimize stormwater pollution from activities conducted by CWU. The O&M Plan shall include appropriate pollution prevention and good housekeeping (PP&GH) procedures for various CWU operations, activities, and/or facilities (e.g., maintenance associated with stormwater collection and conveyance system, municipal buildings, parks and open space, vehicle fleets, etc.). The O&M Plan shall include a schedule of inspections and record keeping requirements. CWU must obtain permit coverage for all facilities that are required to be covered under the General NPDES Permit for Stormwater Discharges Associated with Industrial Activities. In addition, CWU must develop and implement a formal training program for all staff whose job functions may impact stormwater quality. Compliance with Total Maximum Daily Load Allocations- Regulatory Requirements: Ecology conducted a review of all TMDLs approved by EPA at the time of the final permit issuance (January 17, 2007) to determine whether stormwater, including municipal stormwater sources, were identified in any of the TMDLs. Ecology did not identify any TMDLs with established load or waste load allocations for municipal stormwater discharges covered under the permit. Since Ecology has not identified any TMDLs with more specific requirements than those found in the NPDES Phase II Permit, compliance with the permit constitutes compliance with applicable TMDLs. However, CWU is encouraged to participate in the development of local TMDLs to ensure that stormwater impacts are responsibly addressed and to help control potential future costs.

Status of Existing Activities and Needs: Illicit Discharge Detection and Elimination- CWU has a fairly complete map of its MS4, including an inventory of existing storm system facilities and infrastructure. The location of known storm drain outfalls is included on the map; however, areas contributing runoff to each outfall need to be delineated. Source tracing and removal activities are limited and conducted on an as-needed basis. CWU needs to adopt and enforce a policy that specifically prohibits non-stormwater (illicit) discharges to its MS4. CWU also needs to comply with all relevant City ordinances, rules, and regulations that pertain to non-stormwater discharges. Construction Site Stormwater Runoff Control- CWU currently complies with all City ordinances, rules, and regulations regarding stormwater through the local building permit process. CWU does not have a formal process in place to ensure coordination with the City regarding the use of stormwater pollution prevention measures on construction projects that occur on campus property that are not specifically CWU projects. A formal Memorandum of Understanding (MOU) with the City, Ellensburg Water Company, and the Washington State Department of Transportation may be the preferred avenue for having formal documentation and notification of construction activities. CWU currently coordinates with Ecology and the City to provide access for inspection of construction sites. CWU needs to provide training to relevant staff to educate them on erosion and sediment control BMPs and requirements. CWU may want to begin incorporating the minimum technical requirements for stormwater management listed in Appendix 1 of the NPDES Phase II Permit for new development and redevelopment projects. The City is required to adopt Appendix 1 (or equivalent requirements) into their ordinances by Year 3 to control construction and post-construction stormwater runoff, at which time CWU will have to comply. Becoming familiar with the language and requirements now will ease the transition in Year 3. Post-Construction Stormwater Management for New Development and Redevelopment- CWU currently complies with the City’s existing ordinance and storm drainage standards which address post-construction stormwater management. However, the City’s ordinance and existing standards need to be updated to meet NPDES Phase II requirements. As discussed previously, the City is required to adopt Appendix 1 (or equivalent requirements) into their stormwater-related ordinances. CWU will need to incorporate these new/revised post-construction stormwater pollution prevention measures into planned future projects. Pollution Prevention and Good Housekeeping for University Operations- CWU has an informal street sweeping program in place for campus roads and parking lots. Facilities Management Department staff currently perform catch basin and other storm system maintenance on a limited basis. University fleet washing and maintenance is currently conducted in a contained building, which likely meets this component of the regulatory requirements. However, these and other existing activities and policies need to be documented in a formal O&M Manual. In addition, numerous other CWU operation and maintenance activities (e.g., parks and open space, University buildings, stormwater management facilities, etc.) need to be examined, and modified as needed, to protect water quality. A documented training program needs to be established. CWU may consider partnering with the City to have a regional decant facility constructed for the management of wastes generated as a result of stormwater maintenance activities (catch basin cleaning, etc.). Compliance with Total Maximum Daily Load Allocations- No information