S5.C.10 Maintenance and Operations Program

Summary of Program Component

This section of the SWMP contains requirements to regulate and conduct public and private operation and maintenance activities to prevent and reduce stormwater impacts.

Each City division is responsible for performing those tasks discussed under the compliance measures below that are applicable and necessary for Permit compliance.  These include:

• Implementing and enforcing maintenance standards for stormwater facilities

• Ensuring proper and timely maintenance of public and private stormwater facilities, including catch basins;

• Establishing Best Management Practices (BMPs) for reducing stormwater impacts associated with runoff from City property, parking lots, streets and highways owned or operated by the City;

• Implementing a training program for employees who have primary construction, operations, or maintenance job functions that may impact stormwater quality;

• Establishing BMPs for reducing stormwater impacts from heavy equipment maintenance or storage yards and material storage facilities owned or operated by the City; and

• Maintaining records of these activities.

The City maintenance standards are contained in the 2021 City of Tacoma SWMM.  The City Stormwater Detention and Treatment Facilities Operation and Maintenance Manual describes maintenance activities for public facilities and references the City standards.

When maintenance is required according to the standards, the City will schedule typical maintenance to be performed within one year for all treatment and flow control facilities; within six months for all catch basins; and within two years for maintenance requiring capital construction of less than $25,000.

Adopt Maintenance Standards Equivalent to Ecology’s 2019 SWMM for Western Washington

TMC 12.08D.150.D references the SWMM Minimum Requirements and MR #9 contains the requirement for an operation and maintenance manual including maintenance standards for proposed stormwater facilities as described in the SWMM which are (equivalent to Ecology’s 2019 SWMM for Western Washington standards.).  Chapter 12.08D of the TMC also provides City personnel authority to enter private property to inspect and regulate the operation and maintenance of private facilities.  The City requires owners of private stormwater facilities to submit an operation and maintenance manual to the City as part of the permit approval process to ensure that all current and future owners of the private stormwater facilities have operation and maintenance guidelines for regular inspection and maintenance of their permanent stormwater treatment and flow control facilities. 

Inspect Private Treatment and Flow Control Best Management Practices (BMPs)/Facilities

The City requires applicants installing private stormwater facilities to enter into a Covenant and Easement agreement.  The Covenant and Easement agreement between the property owner and the City is recorded to the title of the associated property prior to final permit approval.  The agreement affirms a commitment on the part of the property owner to perform inspection and maintenance of the private drainage system and allow City staff access to the facilities for confirmatory inspections.

The City has an established inspection program for private storm drainage facilities.  The ES/Environmental Compliance Section Inspectors provide education and training to owners of private stormwater facilities on operations and maintenance needs for their treatment and flow control facilities.  Inspection and enforcement records are tracked in the ES/Environmental Compliance Section spills and complaints database.  The City will provide inspection of each identified private treatment and flow control device regulated by the City.  The City has analyzed the data from annual facility inspections over 6 years.  Based on that analysis, a two-year inspection frequency is appropriate for the majority of private facilities.  This analysis and frequency determination is allowed per Permit section S5.C.10.b.ii.

Inspection Program Shall Achieve Inspection of 80 Percent of all Sites Requiring Inspection

The City has an established inspection program designed to inspect and require maintenance of private stormwater facilities regulated by the City.  The City tracks inspections in a databas.  The City will meet the inspection requirements described above in Section S5.C.10.b.ii., by achieving inspection of 80 percent of all known facilities requiring inspection on a yearly basis.

Catch Basin Cleaning Required where Identified by Inspection

The City has an established inspection program with the authority to inspect and require maintenance of private stormwater facilities, including catch basins, regulated by the City.  TMC 12.08A.090 requires that all privately owned drainage facilities including catch basins must be regularly inspected and maintained by the owner and provides authority to the City to access private property to inspect catch basins connected to the municipal storm drainage system.  City inspectors enforce required maintenance standards for cleaning private catch basins.  The Maintenance Standards identify conditions requiring catch basin maintenance including sediment depth, vegetation and debris accumulation, structural integrity, and safety concerns.  City inspectors also require catch basin cleaning where structures have been contaminated by pollutants from accidental spills or illicit discharges.

Inspection Schedule Established for Public Stormwater Facilities Owned or Operated by the City

ES has a program to annually inspect all City owned or operated stormwater treatment and flow control facilities and to provide necessary maintenance of these facilities.  The inspection program’s goal is to achieve at least 95 percent of required inspections.  The list of City-owned facilities and associated maintenance procedures are documented in the SWMM, the City Stormwater Detention and Treatment Facilities Operation and Maintenance Manual and in the Environmental Compliance database.  The Stormwater Detention and Treatment Facilities Operation and Maintenance Manual is updated periodically.

Perform Spot Checks of Treatment and Flow Control Facilities after Major Storm Events

ES implements a flooding emergency response plan to inspect certain public stormwater facilities and potential flooding locations during major storm events, also called a “code red” event.  The plan identifies potential flooding areas and assigns ES personnel to designated drainage basins within the City.  These personnel are responsible for inspecting the public storm system and calling the ES/Operations and Maintenance Division to perform emergency maintenance if necessary to alleviate flooding.  The flooding emergency response plan includes additional spot check inspections of potentially damaged treatment or flow control facilities during a “code red” flood response, which is triggered by a major storm event for Tacoma’s storm system.  For the purpose of this section, a major storm event is defined as the 24-hour storm with a 10-year or greater recurrence interval.  After the event occurs, additional spot checks of potentially damaged facilities will be conducted.  If spot checks show widespread damage or maintenance needs, additional stormwater treatment and flow control facilities that may have been affected will be inspected.  The flooding emergency response plan also documents the process for communicating inspection results to the ES/Operations and Maintenance Division or ES/Science and Engineering Division for follow-up with recommended maintenance or repair activities.  The plan is updated as necessary.

The ES/Operations and Maintenance Division inspects and maintains catch basins and inlets owned and operated by the City annually per Permit section S5.C.10.d.i..  A dedicated catch basin cleaning crew is assigned to inspect a minimum of 95 percent of all catch basins and inlets owned or operated by the City each year.  The data from the inspections is analyzed and additional inspection and cleaning is conducted as needed.  Additional inspections will be conducted by Environmental Services staff in conjunction with other field activities.  Catch basin and inlet inspections can be easily entered by City staff using the City’s asset management system.  The asset management system then schedules any follow up cleaning or other maintenance if needed per the inspection.

If the inspected basins are at least 60 percent full of sediment or when debris is within six inches of the bottom of the outlet pipe, cleaning will be scheduled within six months, however, ES/Operations and Maintenance Division typically cleans the catch basin or inlet directly after the inspection occurs.

Individual maintenance plans for more frequent inspection and cleaning have been developed for some catchments with especially heavy loads of sediment, prone to plugging by leaves or other debris or individual problem catch basins and inlets.  These maintenance plans are contained within the City’s SAP system and include specific guidelines for the type of maintenance and frequency needed and are developed as a result of observations during regular maintenance visits by staff.

The City owns and operates approved and permitted decant facilities.  Disposal of decant materials from catch basin maintenance activities is in accordance with the street waste disposal procedures described in the Permit, Appendix 6.

Practices, Policies and Procedures

ES/Operations and Maintenance Division crews maintaining City-owned treatment and flow control facilities, pipes and catch basins may reference the SWMM, the specific Operations and Maintenance plan for the facilities, and the City of Tacoma Stormwater Facilities – Operation and Maintenance Manual for guidelines for operation and maintenance of all City-owned stormwater facilities.  ES EPG also serves as a technical resource for this work.

Crews performing street, utility, and grounds maintenance activities follow the guidelines in the City of Tacoma Utility BMP Manual, City of Tacoma SWMM and RRMP ESA Guidelines.  This includes maintenance of parking lots, streets and highways that are owned or operated by the City, as well as for the maintenance activities listed in the Permit Section S5.C.10.e including pipe cleaning, cleaning of culverts, ditch maintenance, street cleaning, road repair and resurfacing, snow and ice control, utility installation, vegetation management, dust control, pavement striping maintenance, application of fertilizers, pesticides and herbicides, sediment and erosion control, landscape maintenance, vegetation disposal, trash and pet waste management, and building exterior cleaning and maintenance.

Supervisors are verifying proper practices by using a City developed tablet app.  Data from this app is maintained in a database and is analyzed regularly to help determine if additional training is required.

The Public Works Department, Street Operations and Tacoma Public Utilities - Grounds Maintenance Section collaborated with the Tacoma Public Schools and Metro Parks Tacoma to write the 2011 Management Guidelines for Public Landscapes Including Integrated Pest Management.  This document outlines strategies and methods for pest control used by the guideline partners. 

The City sponsors two to three Ecology Washington Conservation Corps (WCC) crews.  These crews maintain and restore the City’s open space areas, mitigation and habitat restoration projects near shorelines, streams and wetlands.  All WCC crews are trained in proper operations to ensure their work does not create impacts to stormwater or receiving water bodies.

Additional Practices

The City’s street sweeping program removes sediment and associated contaminants from the street surfaces before they enter the MS4.  The street sweeping program is one of the BMPs the City uses to reduce stormwater impacts from roadways.  The program provides street sweeping services on a scheduled rotation for major arterials, 12 business districts, and residential areas.  Street sweeping services are also provided as needed in response to emergency calls, special events, and customer requests.  More information is available on the City website at cityoftacoma.org/street sweeping.

The ES/Operations and Maintenance Division provides storm pipe cleaning services throughout the City prioritized based on pipe inspections, receiving water, spill response or other source control observations in the stormwater collection system.  The allocation of maintenance resources within the stormwater utility is prioritized by the asset management program, which includes impacts to receiving waters as key criteria.  Special pipe cleaning projects are prioritized in specific subbasins each year.

SWPPPs have been developed by the Tacoma Public Utilities, ES/Environmental Compliance Section and ES/Environmental Programs Group staff for the list of City-owned heavy equipment maintenance or storage yard and material storage facilities that meet the following criteria:

1. Not required to have coverage under the General NPDES Permit for Stormwater Discharges Associated with Industrial Activities or another NPDES permit that covers stormwater discharges associated with the activity; and

2. Include heavy equipment maintenance and storage areas and/or material storage areas.

The list of facilities includes the following locations: 

• Sewer Transmission and Maintenance Dock Street Yard (201 Puyallup Avenue)

• Sewer Transmission Cleveland Way Decant Facility (2101 Cleveland Way)

• Tacoma Fire Vehicle Maintenance Shop (3401 B South Orchard Street)

• Tacoma Power Southwest Substation Training Facility and Pole Yard (4102 South 74th Street)

• Tacoma Power Utility Center (3628 South 35th Street)

• Tacoma Water Distribution Operations Center (3506 South 35th Street)

• Traffic Signal and Street Lighting Shop (3401 A South Orchard Street)

• Street Operations Upper Yard (2335 Jefferson Avenue)

• Northeast Tacoma Storage Yard (100 Block Norpoint Way NE)

• Fleet Operations Maintenance Facility (3639 South Pine Street)

•  Tacoma Power LaGrande Hydro-Project (Nisqually project headquarters), (46506 Mountain Highway East (SR 7 East – Eatonville)

• Tacoma Power South Service Center (Loveland), (3022 224th Street East)

• Wilco in Gig Harbor (Potlach Trail Line), (3408 Hunt Street NW)

• Tacoma Rail (2601 Sr 509 North Frontage Road)

• McMillin Reservoir (13004 Reservoir Riad East)

• Tacoma Water Headworks – King County (37007 SE Green River)

SWPPPs for these facilities have been developed and implemented to cover operational BMPs and a visual inspection program to evaluate BMP effectiveness.  Annual business inspections by Environmental Compliance Inspectors identify issues that are out of compliance with the SWPPP.  SWPPP training will also be provided on an annual basis to employees staffing these facilities.