Comments and Suggested Changes to the Construction Stormwater General Permit June 4 th 2008 Presented by the Active Treatment Systems Workgroup

ATS Workgroup Applauds the SWRCB for this process.

Who, What, Why Who makes up the ATS Workgroup ProTech General Contracting Services Clear Creek Systems Clear Water Compliance Services HaloSource What we are presenting Why ATS is beneficial on construction sites

What we are presenting History of ATS Regulation CA CVRWQCB Guidance Document WA DOE Technical Review Committee Final Draft GCP guidelines - positive Safeguarding with automated monitoring Trained and certified operators Residual testing for chemical additives

What we are presenting continued ATS Feasibility – Influent/Effluent Data with Percent Reduction – Economic Feasibility ATS Capabilities Recommendations

Influent/Effluent/Percent Reduction Typical Projects Utilizing ATS Project LocationAverage Background System Size (GPM) CoagulantAverage Influent Turb. (NTU) Average Effluent Turb. (NTU) Percent Reduction Kammerer lane Chitosan % Pleasant Grove Creek Chitosan % North Slough Creek Chitosan % Rancho Cordova, CA Chitosan % Oceanside, CA Chitosan % Roseville CA Chitosan %

Economic Feasibility Typical Projects Utilizing ATS Project LocationProject Size (AC) System Size (GPM) CoagulantRange Influent Turb. (NTU) Effluent Turb. (NTU) Cost/Acre Kammerer lane Chitosan $3, Pleasant Grove Creek Chitosan $6, Lincoln CA PAC $2, Roseville CA Dadmac $ Oceanside, CA 8 200Chitosan $3, Roseville CA Chitosan $1,758.00

Capabilities

Aquatic Impacts of Turbidity Source:

Mortality, Reproduction and Behavioral and the Impact of Suspended Solids Lethal Effects - Mortality Rainbow Trout – (Acute) 200 mg/L for 24 hr leads to 5% mortality in fry Rainbow Trout – (Chronic) 21 mg/L for 48 days leads to 62% reduction in egg-to-fry survival Chinook Salmon – (Acute) 82k mg/L for 6 hr leads to 60% mortality of juveniles Chinook Salmon – (Chronic) 488 mg/L for 8 days leads to 50% mortality of smolts Sublethal Effects - Reproduction CutthroatTrout – 35 mg/L for 2 hr leads to feeding ceased, cover sought Coho Salmon – 300 mg/L for 1 hr leads to feeding ceased Behavioral Effects – Modified Behaviors Whitefish – 0.7 mg/L for 1 hr leads to overhead cover abandoned Arctic Greyling – 100 mg/L for 1 hr leads to avoidance response C.P. Newcombe,. and D.D. MacDonald Effects of Suspended Sediments on Aquatic Ecosystems. North American Journal of Fisheries Management 11:

Aquatic Impacts of Turbidity Turbidity Levels at or above which Adverse Effects are estimated to occur to Clear Water Fish (NTUs) DurationSlight impairment [behavioral effects] Significant effects [to growth and habitat] Severe impairment [habitat alienation] 1 hour hours hours hours hours days weeks >10 months Source: Newcombe, 2003, in OR DEQ 2005

Recommendations 1000 NTU NEL should be reduced – Example: – Consider a 500 gpm flow at 1000 NTU, 8 hours a day for a 5 day week. Assume 1000 NTU = 1000 mg/L TSS (this is a conservative assumption). – 500 gpm x 60 min x 8 hrs x 5 days = 1.2 Million gal per week – 1000 mg/L x 3.8 L/gal = 3800 mg/gal – 1.2 M gal x 3800 mg/gal = 4560 kg or about 10,000 lbs – Assume a sediment density of 60 lbs/ft3 – 10,000 lbs/60 lbs/ft3 = 167 ft3 – This equals around 2 Cubic Yards of sediment/week or a standard dump truck per month.

Recommendations Attachment J should be removed Attachment E, page 1, 3.a Current: “Active Treatment Systems will be designed and approved by qualified personnel: CPESC, CPSWQ, registered civil or other professional engineers with a minimum of 10 years demonstrated construction stormwater treatment system design experience. ” Recommendation: …”CPESC, CPSWQ, registered civil engineer, professional engineer, or others with a minimum”…

Recommendations Attachment E, page 1.3.d Current: “The discharger shall install and operate their ATS using personnel with either a minimum of five years construction storm water experience or are licensed contractors specifically holding a California Class A Contractors license.” Recommendation: “The ATS installation and operation firm shall have five years construction storm water experience or be licensed contractors specifically holding a class A contractors license and all operational personnel must meet minimum training criteria listed herein.”

Why ATS beneficial on construction sites Turbidity Reduction – And other contaminants associated – Dirty Water vs. Watery Dirt ATS is in addition to traditional BMP measures Allows year round construction Aquatic Life Going Forward – New and Innovative Technologies

Thank You!