CONSTROVERSIAL ISSUES IN DRAFT MRP MUNICIPAL MAINTENANCE

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CONSTROVERSIAL ISSUES INDRAFT MRPMUNICIPAL
MAINTENANCE

• November 20, 2006
• Habte Kifle

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2 - Municipal Maintenance ActivitiesControversial
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.

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Controversial Issue 2

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

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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).

• Issue
• Potential significant adverse impact due to lack
  of CEQA analyses
• Lack of cost/benefit analysis

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Controversial Issue 4

• 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.
• Issue
• Weak - Revise to read Assess where more trash
  receptacles would reduce trash accumulation, and
  install additional receptacles.

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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
• Lack of demonstrated effectiveness or
  efficiency of trash grates in preventing
  litter/trash entering catch basins

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Controversial Issue 6

• 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.

• Issue
• 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.

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Controversial Issue 7

• Stormwater Pump Station and Conveyance Systems
• Impl. Level iv Monitor dry weather flows,
  dissolved oxygen, conductivity, and other
  pollutants.

• Issues
• Add trash to the list
• Clarify vagueness

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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.

• Issues
• Not realistic time frame, hazardous, and
  generates unnecessary paperwork

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Catch Basin Reqmnts

• 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.