Regulatory Refresher The Municipal Regional Permit Kristin Kerr, EOA, Inc. Illicit Discharge Stormwater Inspector Training Workshop April 24, 2013

Regulatory Refresher  Municipal Regional Permit Requirements C.4 Industrial/Commercial Site Controls C.6 Construction Site Control C.5 IDDE C.13 Copper Controls C.15.b Conditionally Exempt Discharges  SMCWPPP Resources

What is the Municipal Regional Permit (MRP)?  Applies to cities, counties, and districts in: San Mateo, Alameda, Contra Costa, and Santa Clara Counties Fairfield and Suisun City (Solano County) Vallejo (Solano County)  Regional permit regulating municipal stormwater systems Adopted by Regional Water Board: October 14, 2009 Effective date: December 1, 2009 Permit renewed every 5 years

Permit Provisions  C1 –Compliance with Discharge Prohibitions  C2 – Municipal Maintenance  C3 – New Development and Redevelopment  C4 – Industrial and Commercial Discharge  C5 – Illicit Discharge Detection and Elimination  C6 – Construction Inspection  C7 – Public Information and Outreach  C8 – Water Quality Monitoring  C9 –Pesticide Toxicity Control  C10 – Trash Reduction  C11 – Mercury Load Reduction  C12 – PCBs  C13 – Copper  C14 –PBDE and Legacy Pesticides  C15 – Exempted & Conditionally Exempted Discharges  C16 – Reporting

Commercial/Industrial Inspection Requirements in the MRP  Provision C.4  Implement commercial & industrial site inspection & control program at all sites that could cause or contribute to pollution of SW runoff  Inspection Content Prevention of SW runoff pollution or illicit discharge by implementing BMPs

Industrial/Commercial Inspection Requirements in the MRP  Staff Training Topics Topics — Urban runoff pollution prevention — Inspection procedures — Illicit discharge detection, elimination and follow-up — Implementation of typical BMPs at Industrial and Commercial Facilities Minimum within the 5-year permit term Report Annually training dates, topics and percentage of inspectors attending

Construction Site Inspection Requirements in the MRP  Provision C.6  Implement construction site inspection & control program at all construction sites  Inspection Content Visual observation of actual discharges

Illicit Discharge Inspection Requirements in the MRP  Provision C.5  Implement program with centralized complaint collection & follow-up component and active surveillance component  Detect & control illicit discharges not already controlled under C.4 Industrial/Commercial Site Controls and C.6 Construction Site Controls

C.5 Illicit Discharge Detection & Elimination (IDDE)  Legal Authority  Enforcement Response Plan  Spill & Dumping Complaint Response Inspections  Collection System Screening  Record Keeping  Reporting  Control of Mobile Sources

C.5 IDDE  Legal authority to prohibit, control and eliminate non-stormwater discharges Sewage Wash water from cleaning exterior surfaces, pavement or equipment Runoff from material storage areas Pool or fountain water discharges containing chlorine, biocides, chemicals or filter backwash Sediment, pet waste, vegetation clippings, landscape or construction related wastes Food related wastes

C.5 IDDE - Illicit Discharge Inspection Requirements  Enforcement Response Plan Implemented by April 1, 2010 Enforcement Actions Timely correction of violations — Before next rain event — ≤ 10 business days — Provide rationale if > 10 business days needed Escalated responses to achieve compliance

C.5 IDDE - Illicit Discharge Inspection Requirements  Complaint Response Central contact point Spill/dumping response flow chart, phone tree or contact list Conduct reactive inspections & follow-up Data Tracking — Complaint info — Investigation info — Response time

Illicit Discharge Inspection Contacts on Flows to Bay Website

Illicit Discharge Inspection Data Tracking – Field Form

Illicit Discharge Inspection Data Tracking – Tracking Table

C.5 IDDE - Illicit Discharge Inspection Requirements  Annual Reporting Number of discharges reported Number discharges reaching storm drains &/or RW Number and % discharges resolved in a timely manner Summary of major types of discharges and complaints

Illicit Discharge Inspection Data Major Types of Discharges

C.5 IDDE  Collection System Screening Survey for illicit discharges and illegal dumping Survey strategic collection system check points (end of pipes, storm drain inlets, catch basins, etc.) Once a year in dry weather Survey can occur with routine maintenance activities or inspections

C.5 IDDE  Control of Mobile Sources Program — Minimum standards & BMPs for mobile business types such as automobile washing, power washing, steam cleaning, and carpet cleaning — Enforcement strategy that addresses unique characteristics of mobile businesses — Outreach — Inspection as needed

C.5 IDDE  Control of Mobile Sources Cooperate regionally in developing and implementing programs, including sharing — mobile business inventories — BMP requirements — Enforcement action information — Education

C.5 IDDE  Control of Mobile Sources BASMAA Regional Project — Current Surface Cleaner Training & Recognition Program ( – Video & self test application (English & Spanish) – Web-based database of trained cleaners – Program materials: training & marketing — Add automotive washing and carpet cleaning — Create web-based application to share information about mobile businesses

Copper Controls  C.13.b Manage discharges from pools, spas & fountains containing copper-based chemicals  C.13.a Manage waste generated from cleaning and treating of copper architectural features post construction Concerns after construction — Roof power washing, re-patination (“Patination” solution contains acids), sealing — Runoff containing copper residue BMPs During Maintenance — Block storm drain inlets — Discharge wash water to landscaping or sanitary SMCWPPP Fact Sheet

Conditionally Exempt Discharges  C.15.b.iv Individual Residential Car Washing Discourage through outreach efforts Encourage individuals to direct car wash waters to landscaped areas, use as little detergent as necessary, wash cars at commercial car wash facilities, etc.  C.15.b.v Swimming Pool, Hot Tub, Spa, and Fountain Discharges Implement Illicit Discharge ERP for polluted discharges into the storm drain — contains chlorine, copper algaecide, filter backwash, or other pollutants

SMCWPPP Assistance  CII Subcommittee Meetings  CII Training Workgroup Meetings  SMCWPPP Orientation Training materials  BASMAA Pollutants of Concern (POC) training materials for PCBs and Copper  Website:

Contact Information: Kristin Kerr , X122