FOR PHASE I PROPERTIES

Updated March 2011

Port of Seattle
Stormwater Management Program
for Phase I Properties
Table of Contents
Introduction .......................................................................................................................................... 1
Port Overview .................................................................................................................................. 1
Permit Overview.............................................................................................................................. 2
Key Implementation Dates ............................................................................................................ 2
SWMP Organization ....................................................................................................................... 4
Public Education Program (S6.E.1) .................................................................................................. 5
Public Involvement and Participation (S6.E.2) ............................................................................... 7
Illicit Discharge Detection and Elimination (S6.E.3) ..................................................................... 8
Construction Site Runoff Control (S6.E.4) .................................................................................... 12
Post-Construction Stormwater Management for New Development and
Redevelopment (S6.E.5) ................................................................................................................... 15
Operation and Maintenance Program (S6.E.6) ............................................................................. 17
Source Control in Existing Developed Areas (S6.E.7)................................................................. 20
Total Maximum Daily Load Requirements (S7)............................................................................ 23
Monitoring (S8) .................................................................................................................................. 24
Reporting (S9)..................................................................................................................................... 30
Conclusion .......................................................................................................................................... 32

Port of Seattle
Stormwater Management Program
for Phase I Properties
Updated March 2011
Introduction
The Port of Seattle Seaport and Real Estate properties in the City of the Seattle (the Port)
division of the Port of Seattle have produced this Stormwater Management Program
(SWMP) to demonstrate compliance with the requirements of the National Pollutant
Discharge Elimination System (NPDES) Phase I Municipal Stormwater Permit, issued January
17, 2007 and updated June 17, 2009 by the Washington State Department of Ecology
(Ecology). The Port's SWMP provides an overview of the Port's activities related to
stormwater management on properties covered by the Phase I Municipal Stormwater Permit
(Phase I Properties). The SWMP was first submitted to Ecology in March 2008, along with
the Port's first Phase I Municipal Stormwater Permit Annual Report. Annual updates to the
SWMP accompany each subsequent year's Annual Report.
Port Overview
Within the City of Seattle, the Port owns, operates, and maintains approximately 1,200 acres
of marine terminals, marinas, parks, and shoreline public access areas, and manages aquatic
areas adjacent to port facilities. The Port's water-dependent facilities and activities are a
substantial base of economic activity and employment within the City of Seattle, the port
district, and the State of Washington.
The Port is a publicly owned and operated municipal corporation authorized by state law to
plan, construct, operate, and maintain harbor improvements within the port district.
Specifically, the Port provides marine services and cargo and passenger terminals for large
vessels, serving diverse marine transportation businesses. The Port also provides facilities for
all elements of the fishing industry, other water-dependent and water-related commercial and
industrial uses, and recreational boats, including improvements at Fishermen's Terminal, the
Maritime Industrial Center, Harbor Island Marina, Shilshole Bay Marina and Bell Harbor
Marina.
The Port implements significant environmental restoration, cleanup, and habitat
enhancement as part of its capital improvement programs and ongoing operations and
management of Port facilities. The Port has also created 20 public shoreline access points
where residents and visitors can get a first hand look at the City's maritime environment and
economy.
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Introduction
Continued

Permit Overview
The NPDES program is a requirement of the Federal Clean Water Act. The Environmental
Protection Agency (EPA) has delegated NPDES administration authority in Washington
State to the Department of Ecology (Ecology). On January 17, 2007, Ecology issued the
Phase I Municipal Stormwater Permit which addresses discharges from Large and Medium
Municipal Separate Storm Sewer Systems (MS4s). An updated permit was issued June 17,
2009. The Port of Seattle (excluding Seattle-Tacoma International Airport) has been
designated as a Secondary Permittee with coverage under the Phase I Municipal Stormwater
Permit.
The Phase I Municipal Stormwater Permit authorizes the discharge of stormwater from the MS4
to surface waters and ground waters of the state. To do so, the Port must develop and
implement a Stormwater Management Program (SWMP) for the Phase I Properties that is
designed to protect water quality and reduce the discharge of pollutants from the MS4 to the
maximum extent practicable, as defined by the Phase I Municipal Stormwater Permit.
The Phase I Municipal Stormwater Permit requires the Port to prepare written documentation of
the SWMP for Phase I Properties. The written SWMP is to be updated as significant
portions of the program are implemented (i.e. annually). In addition, the Port is required to
submit Annual Reports by March 31 of each year to document the progress toward
implementing the SWMP components on Phase I Properties over the prior calendar year.
Key Implementation Dates
The Phase I Municipal Stormwater Permit was issued on January 17, 2007, became effective
February 16, 2007 and expires February 15, 2012. An updated permit was issued June 17,
2009 with an effective dated of July 17, 2009. The Port's official effective date is March 9,
2007 - the date on which the Port submitted a Notice of Intent for Phase I Properties to
comply with the Phase I Municipal Stormwater Permit. Ecology is expected to revise and reissue
another multi-year permit in 2012.
The Phase I Municipal Stormwater Permit includes phased deadlines for many of the program
components over the first several years of the permit term. Table 1 shows a general overview
of the deadlines and implementation dates for program activities. All deadlines and required
implementation dates for the Phase I Properties are based on the March 9, 2007 effective
date.

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Introduction
Continued

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Introduction
Continued
SWMP Organization
The Port intends to achieve compliance with the Phase I Municipal Stormwater Permit by
implementing a suite of Best Management Practices (BMPs) on Phase I Properties over the
next three to five years. A stormwater BMP is defined as any program, technology, process,
siting criterion, operating method, measure, or device that controls, removes, or reduces
pollution.
The current and proposed BMPs are grouped into the following program components
organized according to the requirements in the Phase I Municipal Stormwater Permit:
S6.E.1 - Education Program (Section 1)
S6.E.2 - Public Involvement and Participation (Section 2)
S6.E.3 - Illicit Discharge Detection and Elimination (Section 3)
S6.E.4 - Construction Site Runoff Control (Section 4)
S6.E.5 - Post Construction Stormwater Management for New Development and
Redevelopment (Section 5)
S6.E.6 - Operation and Maintenance Program (Section 6)
S6.E.7 - Source Control in Existing Developed Areas (Section 7)
S7 - Total Maximum Daily Load Requirements (Section 8)
S8 - Monitoring (Section 9)
S9 - Reporting (Section 10)
A detailed listing of the requirements and the proposed implementation plan relating to each
program component are presented in the tables included in the remaining sections of this
SWMP.
This updated SWMP documents BMPs implemented as of February 2011 and outlines a
draft plan to meet permit deadlines and maintain compliance throughout the permit term.
Note that this SWMP update (2011) does not include any changes to the proposed BMPs or
implementation schedule of any program components. This update serves to document the
progress to date in implementing the scheduled activities.

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Section 1-Public Education Program (S6.E.1)
Public Education Program (S6.E.1)
This section describes the permit requirements, programs, and planned activities related to
Public Education.
Current activities in this area include:
Brochure distributed to Seaport tenants and posted on Port of Seattle website.
Stormwater management information posted on Port of Seattle website.
Video shown to employees who attended HAZWOPER Training.
Email distribution of Seaport Stormwater News Bulletin.
Developed and published stormwater-related website specific to Seaport issues. Website
includes Phase I Municipal Stormwater Permit information and a resource pages for tenants
and the public to learn more about stormwater.
(http://www.dev.portseattle.org/community/environment-water/seaport/stormwater.shtml)

Website update to expand educational information presented.
Utilized a grant from Ecology to hire an education consultant to develop and implement
tenant education program that is in addition to the Permit requirements. Activities
performed by the education consultant include:
o Prepared education outreach strategy.
o Conducted site visits with tenants to educate them on their stormwater
responsibilities, provides SWPPP templates for completion, and assists
tenants in developing appropriate SWPPP documents.
o Conducted stormwater understanding surveys to measure current tenant
understanding of stormwater issues and responsibilities.
o Published summary of work and results of stormwater understanding surveys
for use in the Port's Targeted Stormwater Management Program
Effectiveness Monitoring (S8.E).
The following table outlines the implementation plan to achieve the goals and objectives of
the Public Education program and meet the compliance deadlines in the Phase I Municipal
Stormwater Permit.

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Section 1-Public Education Program (S6.E.1)
Continued

Permit Element
S6.E.1

Education Program

Purpose: Educate Port community about impacts to stormwater and importance of stormwater as an
environmental resource. Reduce or eliminate behaviors and practices that cause or contribute adverse
stormwater impacts.
Applicability: Applies to Seaport tenants and Port employees.
Permit Requirement

Action Plan

Schedule Notes

S6.E.1.a Education Program
Develop an education program
aimed at tenants and Port
employees. Make educational
materials available to tenants
and Port employees whose job
duties could impact
stormwater.

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Develop educational materials
and conduct outreach activities
Distribute educational materials
Post distributed information on
the Seaport website

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Due Date: September 2008
Status: Program developed;
Implementation is ongoing.

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Section 2-Public Involvement and Participation (S6.E.2)
Public Involvement and Participation (S6.E.2)
This section describes the permit requirements, programs, and planned activities related to
Public Involvement and Participation.
Current activities in this area include:
Posted SWMP and Annual report on the Seaport's new stormwater website.
(http://www.dev.portseattle.org/community/environment-water/seaport/stormwatermunicipalpermits.shtml)

The following table outlines the implementation plan to achieve the goals and objectives of
the Public Involvement and Participation program and meet the compliance deadlines in the
Phase I Municipal Stormwater Permit.
Permit Element
S6.E.2

Public Involvement and Participation

Purpose: Solicit public review of the SWMP for Phase I Properties.
Applicability: Applies to Seaport tenants and general public.
Permit Requirement

Action Plan

Schedule Notes

S6.E.2.a Publish Notice

Publish a public notice in the
local newspaper. Solicit
public review of the SWMP.

Publish public notice to solicit
SWMP input in the newspaper
Request SWMP input via the
Port's Website
Send request for comment
notice to Port tenants and
surrounding properties
Collect and review comments
on SWMP

Due Date: September 2011
Status: Public notice and
public review of SWMP
planned for 2011.

Post SWMP on Port website

Due date: September 2011
Status: Completed.

S6.E.2.B Post SWMP on Website
Make the SWMP available to
the public. Post the SWMP
on the Port's Website.

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Section 3-Illicit Discharge Detection and Elimination (S6.E.3)
Illicit Discharge Detection and Elimination (S6.E.3)
This section describes the permit requirements, programs, and planned activities related to
Illicit Discharge Detection and Elimination (IDDE).
Current activities in this area include:
Field work to collect required mapping data.
Office work to download collected data and create associated maps and reports.
Developed and adopted an appropriate IDDE policy.
Implementation of the City's relevant ordinances, rules and regulations that govern
IDDE.
Identified potential mechanisms to enforce the IDDE policy.
Developed a spill response plan.
Prepared IDDE Program Guidance Manual to document IDDE policies, enforcement
mechanisms, field inspection procedures, and the spill response plan.
Ongoing outfall inspections as weather and tides allow.
Follow-up on suspected illicit discharge problem areas to determine if outflows are from
receding tidal water, groundwater, or a legitimate illicit discharge.
Worked through procedures to clean up and remove identified illicit discharges.
Developed a Maximo database to track maintenance related activities.
The following table outlines the implementation plan to achieve the goals and objectives of
the IDDE program and meet the compliance deadlines in the Phase I Municipal Stormwater
Permit.
Permit Element
S6.E.3

Illicit Discharge Detection and Elimination

Purpose: Detect, remove, and prevent illicit connections and illicit discharges, including spills into
the MS4.
Applicability: Applies to all areas of the MS4 on Phase I Properties owned or operated by the
Port.
Permit Requirement

Action Plan

Schedule Notes

S6.E.3 IDDE Program
Include a program in the
SWMP to detect, remove,
and prevent illicit
connections and illicit
discharges, including spills,
into the MS4 owned or
operated by the Port.
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Prepare written documentation
of the IDDE Program to
document IDDE policies,
enforcement mechanisms,
field inspection procedures,
and spill response plan.
Implement the activities and
BMPs listed in S6.E.3.a
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Section 3-Illicit Discharge Detection and Elimination (S6.E.3)
Continued
through S6.E.f.f.
S6.E.3.a Compliance with Local Jurisdiction
Comply with all ordinances,
rules, and regulations from
the local jurisdiction that
govern non-stormwater
discharges.

Verify that Port activities on
Phase I Properties comply
with City of Seattle
ordinances, rules, and
regulations.

Due Date: Ongoing
Status: Completed

S6.E.3.b IDDE Policy and Enforcement

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Develop and adopt
appropriate policies
prohibiting illicit discharges
and illegal dumping. These
policies shall address, at a
minimum: illicit connections,
non-stormwater discharges
as defined in S6.E.3.b.i
through S6.E.3.b.v, and
spilling, dumping, or
otherwise improperly
disposing of hazardous
materials, pet waste, and
litter.

Review City of Seattle policy
and Phase I Permit
requirements as background
for Port policy.
Prepare draft policy for review
with legal council.
Finalize policy and present to
commission for adoption.

Due Date: March 2008
Status: Completed

Identify possible
enforcement mechanisms to
ensure compliance with illicit
discharge policies.

Identify and discuss
enforcement mechanisms with
legal council.
Enforcement mechanisms include
sending reminder notices to
tenants and referring violations to
the City of Seattle or Department
of Ecology or an internal Port
entity.

Due Date: March 2008
Status: Completed

Develop and implement and
enforcement plan using
these mechanisms to ensure
compliance with illicit
discharge policies.

Outline enforcement
mechanisms for inclusion in
IDDE plan.

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Due Date: September 2008
Status: Completed

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Section 3-Illicit Discharge Detection and Elimination (S6.E.3)
Continued
S6.E.3.c Data Collection
Include an ongoing program for gathering, maintaining, and using adequate information to
conduct planning, priority setting, and program evaluation for Phase I Properties. The following
information will be gathered and retained:
Collect field data on all
Mapping of known MS4
existing known outfalls.
outfalls and maps depicting
Download data and create
land use for property owned
Due Date: March 2009
appropriate maps and reports
by the Port, and all other
Status: Completed
in GIS to meet Ecology
properties served by the
formatting requirements.
MS4 owned or operated by
Develop land use maps of
the Port.
Phase I Properties.
Collect field data on all
existing known outfalls.
Mapping of tributary
Define drainage basin
conveyances and the
boundaries for tributary
associated drainage areas
systems.
of the MS4 outfalls owned or
Due Date: March 2009
Download data and create
operated by the Port with a
Status: Completed
appropriate maps and reports
24 inch nominal diameter or
in GIS to meet Ecology
larger or equivalent crossformatting requirements.
sectional area.
Develop land use maps of
Phase I Properties.
To the extent consistent with
national security laws and
directives, make available to
Review Port security policies
Ecology upon request, GIS
related to infrastructure
data layers generated by the
Due Date: As requested
information sharing.
Port depicting outfall
Status: No requests to date
If allowable, make GIS data
locations, land use, tributary
layers available to Ecology
conveyances, and
upon request.
associated drainage areas
of outfalls owned or
operated by the Port.
Develop stormwater facility
inventory based on
Document operation and
Due Date: March 2009
construction plans, staff
maintenance records for
Status: Developed an O&M
knowledge, and field visits.
stormwater facilities covered
database to track
Enter inventory data in O&M
under this permit. The
stormwater related
database and track O&M
information shall be
maintenance activities.
actions.
available for inspection by
Records are available to
Create annual O&M reports.
Ecology.
Ecology upon request.
Make reports available to
Ecology upon request.

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Section 3-Illicit Discharge Detection and Elimination (S6.E.3)
Continued
To the extent consistent with
national security laws and
directives, mapping
information and O&M
records shall be provided to
the City in which the Port is
located.

Review Port security policies
related to infrastructure
information sharing.
If allowable, make data layers
available to the City upon
request.

Due Date: Not specified
Status: Records can be
provided upon request.

Conduct field inspections
and visually inspect for illicit
discharges at all known
outfalls that discharge to
surface water. Keep records
of inspections and follow-up
activities.

Develop inspection form to
document field data.
Conduct inspections as
required.
Refer problems to appropriate
staff for follow-up.
Maintain field inspection
records.

Due Date: Inspect 1/3 of
outfalls each year
beginning by March 2009.
Status: Initial inspections of
all outfalls were conducted
as part of field data
collection for mapping effort
(S6.3.c). Inspections are ongoing each summer as
weather and tides allow.

Develop and implement
procedures to identify and
remove any illicit discharges.

Document field inspection
procedures in the IDDE Plan.

Due Date: September 2008
Status: Completed.

Identify qualified spill
responders.
Document spill response
procedures in IDDE plan.

Due Date: September 2011
Status: Completed.

Coordinate with education
efforts in S6.E.1 to train Port
staff.

Due Date: Not specified
Status: Spill response
training included in annual
training program.

S6.E.3.d Field Inspections

S6.E.3.d Spill Response Plan
Develop and implement a
spill response plan that
includes coordination with a
qualified spill responder.
S6.E.3.f Staff Training
Provide staff training or
coordinate with existing
training efforts to educate
relevant staff on proper
BMPs for preventing spills
and illicit discharges.

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Section 4-Construction Site Runoff Control (S6.E.4)
Construction Site Runoff Control (S6.E.4)
This section describes the permit requirements, programs, and planned activities related to
Construction Site Runoff Control.
Current activities in this area include:
Seaport projects and tenant projects on Phase I Properties are subject to the City of
Seattle development code.
At this time, Seaport projects on Phase I Properties will be reviewed by Port staff and
tenant projects on Phase I Properties will be submitted to the City for appropriate
review.
Seaport Master Spec (Section 02270) includes temporary erosion and sediment control
guidelines for construction projects.
Obtained NPDES Construction permits for applicable projects.
Requires Certified Erosion and Sediment Control Lead (CESCL) training for
contractors.
Conducted CESCL training for Seaport staff.
Implementation of the City's relevant ordinances, rules and regulations that govern
construction site runoff.
The following table outlines the implementation plan to achieve the goals and objectives of
the Construction Site Runoff Control program and meet the compliance deadlines in the
Phase I Municipal Stormwater Permit.
Permit Element
S6.E.4

Construction Site Runoff Control

Purpose: Continue to reduce pollutants in stormwater runoff from construction activities.
Applicability: Applies to construction activities on Phase I Properties under the functional control
of the Seaport.
Permit Requirement

Action Plan

Schedule Notes

S6.E.4 Construction Runoff Control Program
Include a program in the
SWMP to reduce pollutants
in stormwater runoff from
construction activities under
functional control of the
Seaport.

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Implement the activities and
BMPs listed in S6.E.4.a
through S6.E.4.e.

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Section 4-Construction Site Runoff Control (S6.E.4)
Continued
S6.E.4.a Compliance with Local Jurisdiction
Comply with all relevant
rules and regulations of the
local jurisdiction that govern
construction stormwater. To
the extent allowed by local
ordinances, comply with the
applicable minimum
technical requirements for
new development and
redevelopment.

Refer tenant new development
and redevelopment projects to
City of Seattle for design
review.
Prepare Project Design
Guidance Manual to guide
internal Seaport projects.

Due Date: March 2008
Status: Project Design
Guidance Manual is
complete. Update
anticipated in 2011.

S6.E.4.b General Permit Coverage for Construction Activities
When applicable, seek and
obtain coverage under the
General NPDES Permit for
Stormwater Discharges
Associated with Construction
Activities.

Apply for permit for projects on
Phase I Properties prior to
construction activity
Refer tenant projects to City of
Seattle and Dept. of Ecology
for permit coverage

Due Date: Ongoing
Status: Continue activities in
2011.

S6.E.4.c Compliance Coordination
Coordinate with local
jurisdiction regarding
projects owned and
operated by other entities
that discharge into
interconnected MS3s.

Coordinate with City of Seattle
as applicable.

Due Date: Ongoing
Status: Continue
coordination on an asneeded basis.

Seaport staff or consultant
staff representatives
responsible for construction
sites will obtain their CESEL
certification from an Ecology
approved resource.
Require construction
contractors responsible for
erosion control to have CESEL
certification

Due Date: Not specified
Status: Continue activities in
2011.

S6.E.4.d Staff Training
Provide training or
coordinate with existing
training efforts to educate
Port Staff responsible for
implementing construction
stormwater erosion and
sediment control BMPs.
OR: hire trained contractors
to perform the work.

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Section 4-Construction Site Runoff Control (S6.E.4)
Continued

S6.E.4.e Access Coordination
Provide Ecology or the local
jurisdiction access (as
requested) for inspection of
construction sites or land
disturbances under the
control of the Seaport during
active grading and/or
construction period.

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Review legal authority and
potential mechanisms to allow
inspections as required.
Provide access as requested
and legally allowable.

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Due Date: As requested
Status: Access provided as
requested.

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Section 5-Post-Construction Stormwater Management for New
Development and Redevelopment (S6.E.5)
Post-Construction Stormwater Management for New Development and
Redevelopment (S6.E.5)
This section describes the permit requirements, programs, and planned activities related to
Post-Construction Stormwater Management for New development and Redevelopment.
Current activities in this area include:
Seaport projects on Phase I Properties that connect to the City's drainage system and
tenant projects comply with the City of Seattle development code.
Seaport projects on Phase I Properties that connect to the City's drainage system and
tenant projects submit to the City for appropriate review and permits.
Completed Project Design Guidance Manual to guide internal Seaport projects.
Implementation of relevant ordinances, rules and regulations that govern new
development and redevelopment activities.
The following table outlines the implementation plan to achieve the goals and objectives of
the Post-Construction Stormwater Management program and meet the compliance deadlines
in the Phase I Municipal Stormwater Permit.
Permit Element
S6.E.5

Post-Construction Stormwater Management

Purpose: Continue to establish controls to prevent or minimize water quality impacts from new
development and redevelopment projects.
Applicability: New development and redevelopment projects on Phase I Properties.
Permit Requirement

Action Plan

Schedule Notes

S6.E.5 Post Construction Stormwater Management
Include a program in the
SWMP to address postconstruction stormwater
runoff from new
development and
redevelopment projects.

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Implement the activities and
BMPs listed in elements
S6.E.5.a and S6.E.5.b

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Section 5-Post-Construction Stormwater Management for New
Development and Redevelopment (S6.E.5)
Continued
S6.E.5.a Compliance with Local Jurisdiction

Comply with all relevant
ordinances, rules and
regulations of the local
jurisdiction that govern postconstruction stormwater
pollution prevention
(including operation and
maintenance). To the extent
allowed by local ordinances,
comply with the applicable
minimum technical
requirements for new
development and
redevelopment.

Prepare Project Design
Guidance Manual to guide
internal Seaport projects.
Review internal Seaport
projects that propose new
development and
redevelopment projects on
Phase I Properties for
compliance with the Project
Design Guidance Manual.
Refer tenant new development
and redevelopment projects to
City of Seattle for design
review.
Develop an operation and
maintenance program as
described in element S6.E.6.

Due Date: March 2008
Status: Project Design
Guidance Manual is
complete. Update
anticipated in 2011.

Coordinate with City of Seattle
as applicable.

Due Date: Ongoing
Status: Continue
coordination as needed.

5.3 Compliance Coordination
Coordinate with local
jurisdiction regarding
projects owned and
operated by other entities
that discharge into
interconnected MS3s.

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Section 6-Operation and Maintenance Program (S6.E.6)
Operation and Maintenance Program (S6.E.6)
This section describes the permit requirements, programs, and planned activities related to
the Operation and Maintenance Program.
Current activities in this area include:
Parking lot and street sweeping.
Catch basin cleaning.
Routine maintenance of stormwater treatment facilities and other structural BMPs.
Inspection of suspected problems at stormwater treatment facilities and other structural
BMPs.
Prepared Operations and Maintenance Manual for stormwater infrastructure, including
inspection schedules, maintenance standards, and required maintenance activities.
Tracking maintenance activities in the Seaport's Maximo database.
The following table outlines the implementation plan to achieve the goals and objectives of
the Operation and Maintenance Program and meet the compliance deadlines in the Phase I
Municipal Stormwater Permit.
Permit Element
S6.E.6

Operation and Maintenance Program

Purpose: Ensure that all BMPs continue to function properly by developing an operation and
maintenance program.
Applicability: All stormwater treatment facilities, flow control facilities, and catch basins on
1
Phase I Properties under functional control of the Seaport.
Permit Requirement

Action Plan

Schedule Notes

S6.E.6 Operation and Maintenance Program
Include an operation and
maintenance program in the
SWMP for all stormwater
treatment and flow control
facilities and catch basins.

Implement the activities and
BMPs listed in elements
S6.E.6.a through S6.E.6.d.

See below

1 The O&M Program does not apply to tenant-controlled properties. However, many tenant-controlled

properties are subject to the source control requirements, including inspection and maintenance of stormwater
facilities, outlined in Permit Element S6.E.7.
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Section 6-Operation and Maintenance Program (S6.E.6)
Continued

S6.E.6.a O&M Manual

Prepare an O&M manual for
all stormwater BMPs under
the functional control of the
Seaport. Retain a copy of
the manual in the
appropriate Seaport
department.

Develop facility-specific
maintenance standards that
are as protective as those in
the Ecology Manual to
determine when
maintenance is required.

Document stormwater facilities
on Phase I Properties under
Seaport control.
Review existing operation and
maintenance practices.
Prepare operation and
maintenance manual.
Retain copies of the manual at
Seaport Maintenance and
Environmental Department.
Review maintenance
standards in Chapter 4 of
Volume V of the 2005
Stormwater Management
Manual for Western
Washington.
Incorporate maintenance
standards into the O&M
manual.

Due Date: March 2009
Status: Complete.

Due Date: March 2009
Status: Complete.

S6.E.6.b Annual BMP Inspections and Maintenance

Manage maintenance
activities to inspect all
facilities listed in the O&M
Manual annually.

Take appropriate
maintenance action when
the maintenance standard is
exceeded. Maintenance
shall be performed within the
timeline identified in permit
condition S6.E.6.b(ii).

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Establish an inspection
schedule in the O&M Manual.
Create a stormwater facility
inspection checklist or report
form.
Train staff on facility inspection
as part of element S6.E.6.c.
Allocate staff resources to
facility inspections.
Prepare inspection reports to
document all inspection
activities as part of element
S6.E.6.d.
Prepare maintenance requests
for facilities that exceed the
maintenance standard.
Conduct maintenance
activities as needed.
Prepare maintenance records
as part of element S6.E.6.d.

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Due Date: Annually
Status: Schedule and report
forms are complete.
Continue training and
inspections in 2011.

Due Date: As need is
identified
Status: Maintenance
schedule depends on
inspection results.

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Section 6-Operation and Maintenance Program (S6.E.6)
Continued

S6.E.6.c Staff Training

Provide appropriate training
for Port maintenance staff.

Identify training courses.
Send an appropriate
percentage of maintenance
staff to training each year.
Establish resources for
internal trainings - videos,
webcasts, staff meetings,
hiring an outside trainer, etc.

Due Date: Not specified
Status: Training activities
are ongoing.

Maintain maintenance records
in Maximo database.

Due Date: Ongoing
Status: Continue activity in
2011.

S6.E.6.d Record Keeping
Maintain records of
inspections and
maintenance activities.

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Section 7-Source Control in Existing Developed Areas (S6.E.7)
Source Control in Existing Developed Areas (S6.E.7)
This section describes the permit requirements, programs, and planned activities related to
Source Control in Existing Developed Areas.
Current activities in this area include:
Phase I Properties with individual, industrial, or boat yard NPDES permits have
prepared Stormwater Pollution Prevention Plans (SWPPPs).
Phase I Properties with individual, industrial, or boat yard NPDES permits are
implementing appropriate source controls.
Implementation of the City of Seattle's relevant ordinances, rules and regulations that
govern source control activities.
Adoption of policies and activities to require pesticide-free and synthetic fertilizer-free
landscaping.
Distributed SWPPP templates to tenants required to develop SWPPPs.
Provided technical assistance to tenants developing SWPPPs.
Completed SWPPPs for Port-controlled Phase I Properties, including Maritime
Industrial Center, Fisherman's Terminal, Shilshole Bay Marina, and Marine Maintenance
Areas at Pier 2, Terminal 5, and Terminal 91.
SWPPPs are complete or in progress for numerous Port-controlled Phase I Properties
(piers and terminals) that house office space, parking, and moorage areas as well as
vacant lands.
The following table outlines the implementation plan to achieve the goals and objectives of
the Source Control program and meet the compliance deadlines in the Phase I Municipal
Stormwater Permit.

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Section 7-Source Control in Existing Developed Areas (S6.E.7)
Continued

Permit Element
S6.E.7

Source Control

Purpose: Identify and implement measures to prevent and control the contamination of
discharges of stormwater to surface or ground water.
Applicability: All Port-owned lands not covered by either a General Permit or an individual
NPDES permit issued by Ecology that covers stormwater discharges. Note: SWPPPs will apply to
1. Heavy Equipment Maintenance, 2. Storage Yards, 3. Material Storage, and 4. Maintenance
2
Areas.
Permit Requirement

Action Plan

Status

S6.E.7.a Stormwater Pollution Prevention Plans (SWPPPs)
Develop and implement one
or more SWPPPs to identify
and implement measures to
prevent and control the
contamination of discharges
of stormwater to surface or
ground water.

Identify sites already covered
by a General Permit or an
individual NPDES permit.
Implement the activities and
BMPs listed in elements
S6.E.7.b through S6.E.7.g.

Due Date: March 2009
Status: Identification
complete. See below for
implementation activities.

Establish a list of sites that
must be covered by a new
SWPPP.
Conduct site inspections to
collect data for the facility
assessment.
Prepare facility assessment for
each site including site plan,
identification of pollutant
sources, and description of
drainage system.

Due Date: March 2009
Status: Complete for Portcontrolled Phase I
Properties.

S6.E.7.b Facility Assessment

SWPPP(s) shall include a
facility assessment with a
site plan, identification of
pollutant sources, and
description of drainage
system.

2 These are the four land uses that require source control and SWPPPs as described in permittee and other

secondary permittee sections of the NPDES Phase I Permit. The City of Seattle source control code and
manual applies to "all Port lands" as well as all City properties. The Port will include City BMPs as part of the
Stormwater Management Program to all applicable properties.
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Section 7-Source Control in Existing Developed Areas (S6.E.7)
Continued

S6.E.7.c BMP Identification
Identify BMPs used or
proposed for use. Implement
non-structural BMPs
immediately following plan
development. Include
schedule for implementing
structural BMPs in the
SWPPP.

Identify structural and nonstructural BMPs already in
place.
Identify additional source
control BMPs.
Develop an implementation
schedule for structural BMPs.

Due Date: March 2009
Status: Identification
complete. Implementation to
follow schedule in each
SWPPP.

Maintain list of sites covered
by a SWPPP.
Establish legal authority to
conduct site inspections for
source controls.
Develop an inspection
schedule.
Conduct site inspections to the
extent allowed by local
ordinances, rules, and
regulations.

Due Date: September 2011
Status: Inspections are
ongoing.

Review existing Seaport
maintenance plan prohibiting
the use of pesticides.
Update policy if needed.

Due Date: March 2009
Status: Complete.

S6.E.7.d Inspections

Maintain a list of sites
covered by the SWPPP(s)
required by this permit.
Inspect at least 15 percent
of listed sites annually and
80 percent of all listed
properties within 180 days of
the permit expiration.

S6.E.7.e Pesticide Policy
Identify policies to reduce
pollutants associated with
pesticides, herbicides, and
fertilizer.

S6.E.7.f Illicit Connections, Discharges and Spills
Include measures to
prevent, identify, and
respond to illicit discharges,
illicit connections, spills, and
improper disposal. Notify the
City or County and Ecology
immediately upon becoming
aware of a spill.

Include reference to the
Seaport's IDDE Program in
SWPPPs.
Implement Seaport IDDE
Program on Phase I
Properties.
Notify City and Ecology of
spills as needed.

Due Date: March 2009
Status: Complete. See
Section 3 (S6.E.3) for
details.

S6.E.7.g Inspection and Maintenance
Include a component related
to inspection and
maintenance of stormwater
facilities and catch basins
that is consistent with the
Port's Operation and
Maintenance Program.
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Include reference to the
Seaport's O&M Manual in
SWPPPs.
Implement Seaport O&M
Program on Phase I
Properties.
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Due Date: March 2009.
Status: Complete. See
Section 6 (S6.E.6) for
details.

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Section 8-Total Maximum Daily Load Requirements (S7)
Total Maximum Daily Load Requirements (S7)
The Total Maximum Daily Load (TMDL) requirements only apply if a stormwater TMDL
has been established for receiving waters that receive stormwater discharge from the
stormwater system on Phase I Properties owned or operated by the Seaport. The applicable
TMDLs that require additional compliance activities are listed in Appendix 2 of the Phase I
Municipal Stormwater Permit. At this time, none of the TMDLs listed in Appendix 2 affect the
Port. As such, no additional activities are required for compliance with TMDL conditions.
The Port will continue to track the development of TMDLs and participate in their
development and implementation when appropriate.

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Section 9-Monitoring (S8)
Monitoring (S8)
This section describes the permit requirements, programs, and planned activities related to
Monitoring.
The permit requires the development of monitoring programs with three components:
Stormwater Runoff Monitoring
Targeted SWMP Effectiveness Monitoring (two practices)
BMP Evaluation Monitoring
Current activities in this area include:
Selected outfall for stormwater monitoring.
Prepared and submitted draft Stormwater Monitoring Program Quality Assurance
Project Plan (QAPP). Received and incorporated Ecology comments on the Stormwater
Monitoring QAPP.
Finalized approved Stormwater Monitoring QAPP.
Began stormwater monitoring program.
Identified targeted action, environmental outcome, and related hypotheses for Targeted
SWMP Effectiveness monitoring.
Prepared and submitted draft SWMP Effectiveness monitoring QAPP. Received and
incorporated Ecology comments on the SWMP Effectiveness QAPP.
Finalized approved SWMP Effectiveness QAPP.
Began SWMP Effectiveness monitoring activities.
Identified site for BMP Evaluation monitoring.
Prepared and submitted draft BMP Evaluation monitoring QAPP.
Received and incorporated Ecology comments on the BMP Evaluation QAPP.
Submitted revised BMP Evaluation plan for Ecology review and received verbal
approval of revised plan.
Continued work on baseline monitoring to support BMP Evaluation monitoring.
Baseline data will be used to determine tidal influence and contribute to development of
finalized BMP Evaluation QAPP.
The following table outlines the implementation plan to achieve the goals and objectives of
the three part Monitoring program and meet the compliance deadlines in the Phase I
Municipal Stormwater Permit. Because the permit language is extensive in this area, the
requirements have been summarized in the implementation table below. See the Phase I
Municipal Stormwater Permit (Section S8) for the complete Monitoring program requirements
language.

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Section 9-Monitoring (S8)
Continued

Permit Element
S8

Monitoring

Purpose: Develop and implement a long term monitoring program to characterize stormwater
runoff quantity and quality, evaluate stormwater management program effectiveness, and
evaluate BMP effectiveness.
Applicability: Phase I Properties at the Port of Seattle and Port of Tacoma
Permit Requirement

Action Plan

Schedule Notes

S8.C.1 Long Term Monitoring Program
Develop and implement a
long term monitoring
program with three
components:
Stormwater Monitoring,
Targeted SWMP
Effectiveness Monitoring,
and BMP Evaluation
Monitoring.

Develop a monitoring plan as
described below.
Implement monitoring as part
of elements S8.D through
S8.F.

Due Date: Varies (see
below)
Status: Monitoring program
status should be included in
each annual report.

S8.C.2 Quality Assurance Project Plan (QAPP)

Each of the components of
the monitoring program shall
include a QAPP prepared in
accordance with Ecology's
QAPP guidelines. The
monitoring program shall be
developed by qualified staff
or contractors with
experience in applying
Ecology's or EPA's QAPP
Guidelines.

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Hire qualified contractor to
develop QAPP.
Coordinate with the Port of
Tacoma on joint monitoring
efforts.
Prepare QAPP for each
monitoring component.
Submit to Ecology for review
and approval prior to
conducting monitoring
activities.

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Due Date: March 2008 for
draft Stormwater and
Targeted SWMP
Effectiveness QAPPs.
September 2008 for final
Stormwater and Targeted
SWMP Effectiveness
QAPPs and draft BMP
Evaluation QAPP. March
2009 for final BMP
Evaluation QAPP.
Status: Stormwater and
Targeted SWMP
Effectiveness QAPPs are
complete and approved.
Revised plan for BMP
Evaluation program has
been approved (verbally) by
Ecology. Revised BMP
Evaluation QAPP will be
submitted following baseline
data collection.

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Section 9-Monitoring (S8)
Continued

S8.D Stormwater Monitoring
Select one outfall or
conveyance for monitoring.
Stormwater monitoring sites
shall have the tributary
conveyance system and
drainage area mapped, and
shall be suitable for
permanent installation and
operation of flow-weighted
composite sampling
equipment.

Sample the stormwater
monitoring site according to
the frequency outlined in
permit condition S8.D.2.a.

Sample storm events using
flow weighted composite
sampling and conduct
laboratory analysis as
outlined in permit conditions
S8.D.2.b and S8.D.2.c.
Annually test the seasonal
first-flush for toxicity as
outlined in permit condition
S8.D.2.d.
Collect grab samples to test
for TPH and Fecal coliform
bacteria as outlined in
permit condition S8.D.2.e.
Collect annual sediment
samples at the monitoring
site as outlined in permit
condition S8.D.2.f.
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Review Phase I Properties
and identify potential sites
meeting site selection criteria.
Document basin sizes, land
use types, and contributing
drainage areas.
Select monitoring site.
Document site selection
criteria and justification in
QAPP.
Outline sampling procedures
in the QAPP.
Develop system to track storm
events, identify qualifying
storms, and mobilize staff to
collect samples.
OR
Hire consultant to track storm
events, identify qualifying
storm events, and collecting
samples at appropriate times.
Purchase sampling
equipment.
Identify lab for sample
analysis and submit samples
for analysis following
qualifying storm events.
Outline sampling and testing
procedures in the QAPP.
Identify lab for sample
analysis and submit samples
annually.
Outline sampling and testing
procedures in the QAPP.
Identify lab for sample
analysis and submit samples
annually.
Outline sampling and testing
procedures in the QAPP.
Identify lab for sample
analysis and submit samples
annually.
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Due Date: March 2008
Status: included in QAPP.

Due Date: March 2008 for
Draft QAPP; September
2008 for Final QAPP.
Status: QAPP approved;
Sampling activities are
underway.

Due Date: March 2009
Status: Ongoing

Due Date: March 2009
Status: Ongoing

Due Date: March 2009
Status: Ongoing

Due Date: March 2009
Status: Ongoing

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Section 9-Monitoring (S8)
Continued
Calculate the Event Mean
Concentrations, total annual
pollutant load, and the
seasonal pollutant load for
the wet and dry seasons as
outlined in permit condition
S8.D.2.g.

Outline evaluation procedures
in the QAPP.
Collect and maintain records
of laboratory analysis as
completed.
Analyze data and track
analysis results.

Due Date: As data is
collected
Status: Ongoing

S8.E Targeted SWMP Effectiveness Monitoring

Develop a monitoring
program to evaluate the
effectiveness of a targeted
action (or suite of actions)
as outlined in permit
condition S8.E.

Develop a monitoring
program to evaluate the
effectiveness of achieving a
targeted environmental
outcome as outlined in
permit condition S8.E.

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Identify the targeted action:
Increasing knowledge and
changing behaviors of tenants
through stormwater education.
Formulate a hypothesis about
the action that can be tested
using before and after
surveys.
Outline a monitoring program
with the elements listed in
S8.E.3 and submit to Ecology
for review.
Identify appropriate survey
questions and methods for
distributing and collecting
surveys.
Begin initial surveys once
Ecology has approved
monitoring plan.
Conduct public education
campaign outlined in S6.E.1.
Conduct follow-up surveys to
evaluate knowledge and
behavior changes.
Identify the environmental
outcome to be evaluated.
Formulate a hypothesis about
the outcome that can be
tested using monitoring data.
Identify the parameters to be
measured and methods for
collecting/testing the data.
Hire a consultant to prepare a
QAPP outlining the
procedures for conducting
targeted environmental
outcome monitoring.
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Due Date: March 2008 for
monitoring. March 2009 for
starting surveys.
Status: QAPP approved;
initial surveys and education
program are complete;

Due Date: March 2008 for
draft QAPP. September
2008 for final QAPP. March
2009 for program
implementation.
Status: QAPP approved;
monitoring program is
underway.

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Section 9-Monitoring (S8)
Continued
Submit QAPP to Ecology for
review and finalize QAPP.
Begin collecting and analyzing
data once QAPP has been
approved.
S8.E BMP Evaluation Monitoring
Identify potential BMPs and
applicable sites on Phase I
Properties for monitoring.
Coordinate with Ecology to
receive approval for the
proposed monitoring sites.
Document site selection
criteria and justification in
QAPP.

Due Date: September 2008
Status: included with QAPP.

Use appropriate sections of
Ecology's guidance for
preparing, implementing,
and reporting on the results
of the BMP evaluation
program.

Hire a consultant to prepare a
QAPP for the BMP monitoring
that follows Ecology's
"Evaluation of Stormwater
Treatment Technologies"
document.

Due Date: Final QAPP due
90 days after receiving
Ecology comments.
Status: Draft QAPP
submitted to Ecology;
comments received; revised
monitoring plan submitted;
verbal approval received;
baseline monitoring
underway to determine
QAPP modifications.

Monitor whole water and
sediment parameters as
outlined in permit conditions
S8.F.5 and S8.F.6.

Outline monitoring procedures
and parameters to be tested in
the QAPP.
Hire a consultant to collect
and analyze monitoring data
according to the procedures
outlined in the QAPP.
Collect and maintain records
of laboratory analysis as
completed.
Analyze data and track
analysis results.

Due Date: To be
determined based on
QAPP review schedule.
Status: Baseline monitoring
to support QAPP
development is underway;
Full monitoring will begin
after approval of final QAPP.

Identify at least one
treatment BMP (no less than
two sites) for full scale field
monitoring as outlined in
permit conditions S8.F.1,
S8.F.2 and S8.F.3.

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Section 9-Monitoring (S8)
Continued

S8.H Monitoring Program Reporting Requirements
Submit the stormwater
monitoring report each year
with the annual report
beginning in 2009 for
independent monitoring and
2010 for collaborative
monitoring. Reports shall
include the information
outlined in permit condition
S8.H.1.

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Analyze and review collected
data as part of elements S8.D
through S8.F.
Summarize and format data
annually to meet reporting
requirements.
Prepare QA/QC report for
each part of the monitoring
program.
Prepare and submit annual
monitoring report.

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Due Date: March 2009.
Status: Complete for
inclusion with the annual
report.

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Section 10-Reporting (S9)
Reporting (S9)
This section describes the permit requirements, programs, and planned activities related to
Reporting.
Current activities in this area include:
Submitted 2007, 2008, and 2009 Annual Reports and accompanying SWMP documents
prior to the March 31 permit deadlines.
Preparing 2010 Annual Report for submittal to Ecology.
Preparing updated SWMP document to reflect activities completed in 2010 and planned
for 2011.
Ongoing record keeping of SWMP activities.
The following table outlines the implementation plan to achieve the goals and objectives of
the Reporting program and meet the compliance deadlines in the Phase I Municipal Stormwater
Permit.
Program Element
S9

Reporting

Purpose: Document SWMP activities on Phase I Properties and submit annual reports to
Ecology.
Applicability: All Seaport stormwater program activities on Phase I Properties related to NPDES
Phase I Permit compliance.
Permit Requirement

Action Plan

Schedule Notes

S9.A, B, and G Annual Report

Prepare and submit an
annual report to Ecology
covering the previous
calendar year. The annual
report shall include the
information outlined in
permit condition S9.G.

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Prepare SWMP document
including implementation
schedules and plan for
meeting permit deadlines.
Update SWMP annually.
Complete Ecology provided
annual report form (permit
Appendix 3).
Prepare stormwater
monitoring report as part of
S8.H beginning in 2009.
Identify and document
jurisdictional boundary
changes as applicable.
Obtain necessary signatures
and submit to Ecology on an
annual basis.
Ma na g em e nt

Pla n

f or

Due Date: March 31 each
Year
Status: Annual reports for
2007, 2008, and 2009 are
complete. Annual report for
2010 is in development.

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Section 10-Reporting (S9)
Continued
S9.C Maintain Records

Keep all records related to
the permit and the SWMP
for at least five years.
Except as required in permit
condition S9.G, records
need to be submitted to
Ecology only upon request.

Identify Seaport staff
responsible for recording
SWMP activities.
Develop procedures or
develop database for
collecting and consolidating
SWMP records.
Review records annually as
part of annual report
development.

Due Date: Ongoing
Status: in progress

Identify locations for storing
permit and SWMP documents.
Post documents or information
about document availability on
the Seaport website.
Copy records or annual
reports as requested.

Due Date: Not specified
Status: records are available
upon request.

S9.D Public Access
Make records related to this
permit and the Permittee's
SWMP available to the
public at reasonable times
during business hours.
Provide a copy of the most
recent annual report to any
individual entity, upon
request.

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Conclusion
Conclusion
This Stormwater Management Plan has been prepared to demonstrate compliance with the
requirements of the NPDES Phase I Municipal Stormwater Permit. The implementation tables
indicate current and planned activities on Phase I Properties as of February 2011. The
Stormwater Management Plan for Phase I Properties is a living document that will be
updated annually to document progress in implementing the stormwater management
programs required for compliance with the Phase I Municipal Stormwater Permit.

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