MRP Pollutants of Concern Copper Provisions Monday November 20, 2006 Richard Looker - RWQCB

Architectural Copper Prevent storm drain discharges of wash waters during installation of copper architectural features: Details:  Update BMPs for accomplishing this  Ensure compliance either through  Copper roof building permit issuance  Annual training of installers

feedback “Cleaning, washing, and other routine maintenance of private buildings does not require a permit from municipalities, and it is unreasonable to expect that municipalities conduct these inspections.” WB observations:  This measure deals with INSTALLATION of the copper roofs.  There is municipal oversight through building permit approval process.  There is second option - training of installers.

Architectural Copper (cont) 1.2 Washwater management from copper roofs: Details:  Develop ordinance OR  Certify that legal authority exists  Report on the ordinance OR progress on enforcing/implementing existing authority

feedback “ most municipalities already includes language in the municipal code prohibiting the discharge of ANY washwater into the storm drain system. Development of a separate ordinance is not a productive use of permittee resources..” WB observation:  The provision explicitly speaks to the case where an existing legal authority exists.  We call for measures that are similar to those proposed in BASMAA provisions.

Copper-containing Pesticides 2.1 Prohibit pool, spa, or fountain discharge containing copper: Details:  Develop ordinance OR  Certify that legal authority exists  Report on the ordinance or progress on enforcing/implementing existing authority

feedback “ Many older sanitary sewer systems do not have the capacity to handle the pool discharges. Eliminate requirement until the Board receives approval from sewage agencies. Alternate treatment measures such as directing pool runoff through landscaping or other filtering devices should be allowed. “ WB observations:  This already SHOULD be happening.  The Board does not need approval to require this.  We could consider alternate treatment measures.  The volume is probably not a big issue – could be investigated and confirmed as part of implementation.

BASMAA provisions Outreach and Education Enforce non-stormwater discharge prohibition by applying appropriate BMPs WB observations:  We are probably fairly close to agreement for this, but:  You can do outreach and education as needed, not going to be required.  The second part is fairly consistent with what we are calling for.

Vehicle Brake Pads Participate in Brake Pad Partnership and track decision point coming soon. Details:  Participate in deliberations and report on outcome

Vehicle Brake Pads (cont) Pilot test enhanced system design, operation and maintenance. Details:  Locations chosen where brake pad wear debris is most concentrated  Pilots may involve retrofits, street sweeping, cleanouts, etc.

BASMAA provisions BASMAA provisions say “report on BPP and consider legislation”. WB observations:  This is not acceptable because:  BPP may not achieve its goal.  Even if successful, it will take time to realize benefits.  So, there has to be a backup strategy for BPP.  Main point – programs have a responsibility to deal with this source that goes beyond simple reliance on BPP.  This is the biggest source of copper.  Urban Runoff is the conveyance.  It is not acceptable to punt responsibility to the BPP forever.

Industrial Sources 4.1 Ensure compliance with BMPs for control of copper where it is used consistent with adequate industrial inspection and enforcement Details:  Identify existing industrial sources using copper  As part of inspections component of industrial stormwater, ensure that proper BMPs are in place to minimize discharge of copper to stormdrains, including roof runoff.

feedback “ Control Measure 4.1 for copper is redundant to business inspection requirements elsewhere in the permit.. “ WB observations:  In reviewing permit, we feel that it is not redundant but complementary.  The identification process is to confirm that copper-using facilities are being inspected.  Making sure proper BMPs are in place is a complement to what is stated in business inspection section.