CONSTROVERSIAL ISSUES IN DRAFT MRP MUNICIPAL MAINTENANCE November 20, 2006 Habte Kifle

2 - Municipal Maintenance Activities Controversial Issue 1 1.Street and Road Sweeping and Cleaning – Impl. Level v – “Permittee shall phase in 50% of existing street sweepers with new street sweeping equipment purchases within five years after the adoption of this Order.” Should read: When sweepers are replaced, replace with machines optimized for fine particulate pollutant removal. When sweepers are replaced, replace with machines optimized for fine particulate pollutant removal.

Controversial Issue 2 6. Litter/Trash Control (General) Issue: Requirements appear in several sections, such as maintenance (prescriptive), monitoring, and pollutants of concern (performance based) creating overlap Requirements appear in several sections, such as maintenance (prescriptive), monitoring, and pollutants of concern (performance based) creating overlap Needs consistency and clarity Needs consistency and clarity

Controversial Issue 3 6. Litter/Trash Control Impl. Level iv – “Implement appropriate trash removal program in creeks and stormwater conveyance systems and waterways at least twice a year (before and after the rainy season).” Impl. Level iv – “Implement appropriate trash removal program in creeks and stormwater conveyance systems and waterways at least twice a year (before and after the rainy season).” Issue: Potential significant adverse impact due to lack of CEQA analyses Potential significant adverse impact due to lack of CEQA analyses Lack of cost/benefit analysisLack of cost/benefit analysis

Controversial Issue 4 6. Litter/Trash Control Task Description (b) – Litter receptacles Placement and Maintenance – “Permittees shall place and regularly maintain litter receptacles in parks and public places as part of their pollutant source control efforts.” Task Description (b) – Litter receptacles Placement and Maintenance – “Permittees shall place and regularly maintain litter receptacles in parks and public places as part of their pollutant source control efforts.”Issue: Weak - Revise to read “Assess where more trash receptacles would reduce trash accumulation, and install additional receptacles.” Weak - Revise to read “Assess where more trash receptacles would reduce trash accumulation, and install additional receptacles.”

Controversial Issue 5 7. Catch Basin Inspection and Cleaning – Task Description (b) – Catch Basin Retrofits – “Permittees shall retrofit or redesign catch basin grates in litter problem areas to improve trash interception and removal by street sweepers.” Issue: Vague Vague Lack of demonstrated effectiveness or efficiency of trash grates in preventing litter/trash entering catch basins Lack of demonstrated effectiveness or efficiency of trash grates in preventing litter/trash entering catch basins

Controversial Issue 6 7. Catch Basin Inspection and Cleaning Record/Reporting – “Permittees shall keep records of inspections, cleaning and maintenance for each drain inlet annually and shall provide such information in a summary form within the annual report. Record/Reporting – “Permittees shall keep records of inspections, cleaning and maintenance for each drain inlet annually and shall provide such information in a summary form within the annual report. Issue: Removed trash volume could be overly burdensome requiring unnecessary paperwork Removed trash volume could be overly burdensome requiring unnecessary paperwork Reword to read “Permittees shall keep records of inspections, cleaning and maintenance for drain inlet system, and shall report this information in summary form within the annual report.” Reword to read “Permittees shall keep records of inspections, cleaning and maintenance for drain inlet system, and shall report this information in summary form within the annual report.”

Controversial Issue 7 8. Stormwater Pump Station and Conveyance Systems Impl. Level iv – “Monitor dry weather flows, dissolved oxygen, conductivity, and other pollutants.” Impl. Level iv – “Monitor dry weather flows, dissolved oxygen, conductivity, and other pollutants.” Issues: Add “trash” to the list Add “trash” to the list Clarify vagueness Clarify vagueness

Controversial Issue 8 9. Stormwater Pump Station and Conveyance Systems Impl. Level ix – “Inspect trash racks and oil absorbent booms during or within 24-hours of significant storm events. Remove debris in trash racks and replace oil absorbent booms, as needed.” Impl. Level ix – “Inspect trash racks and oil absorbent booms during or within 24-hours of significant storm events. Remove debris in trash racks and replace oil absorbent booms, as needed.” Issues: Not realistic time frame, hazardous, and generates unnecessary paperwork Not realistic time frame, hazardous, and generates unnecessary paperwork

Catch Basin Req’mnts Catch Basin (Stencil) Inspection requirements must coincide with PIP requirements or only require it at one section. Catch Basin (Stencil) Inspection requirements must coincide with PIP requirements or only require it at one section. Issue - Recommendation: “All storm-drain inlets and catch basins be inspected, cleaned, and stenciled or re-stenciled if necessary at least once per year, with logs and a maintenance plan available to anyone on request.”