Regulatory Refresher The Municipal Regional Permit

Kristin Kerr, P.E., QSD EOA, Inc.

Municipal Maintenance Training Workshop May 23, 2013

Regulatory Refresher Municipal Regional Permit

Requirements• C.2 Municipal Operations• C.5 Illicit Discharge Detection & Elimination• C.7 Public Information and Outreach• C.10 Trash Load Reduction

SMCWPPP Resources

Municipal Stormwater Permits

Since 1987 the federal Clean Water Act has required municipalities to obtain permits to discharge stormwater from municipal storm drain systems

These are National Pollutant Discharge Elimination System (NPDES) Municipal Stormwater Permits

Municipal NPDES Permitting Authority

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

What Do Municipal Stormwater Permits Require?

If you only remember two general things:I. Implement controls to reduce the

discharge of pollutants in stormwater to the maximum extent practicable, AND

II. Effectively prohibit non-stormwater discharges into the storm drains

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

Provision C.2 – Municipal Operations

Field Activities• Street/Road Repair

and Maintenance• Sidewalk/Plaza

Maintenance & Pavement Washing

• Bridge & Structure Maintenance

• Graffiti Removal• Rural Public Works

(Roads) Construction and Maintenance

Provision C.2 – Municipal Operations

Fixed Facilities• Corporation Yards• Pump Stations

Municipal Operations Requirements in the MRP

Provision C.2 Implement appropriate BMPs during

operation, inspection & routine repair/maintenance activities

Specific BMPs for Field Activities Specific BMPs for Fixed Facilities Monitoring and Inspections at Fixed Facilities

*BMPs = Best Management Practices

MRP Requirements - Field Activities

Manage materials, debris and wastewater

Control erosion and sediment runoff Protect storm drain inlets Avoid discharges to the storm drain

Sources of BMPs CASQA Stormwater BMP Municipal Handbook

(2003) - BMP Fact Sheets • Road & Street Maintenance• Plaza & Sidewalk Cleaning• Vehicle & Equipment Fueling• Vehicle & Equipment Cleaning• Vehicle & Equipment Repair• Parking/Storage Area Maintenance• Outdoor Storage of Raw Materials• Waste Handling & Disposal• Outdoor Container Storage

Sources of BMPs Caltrans Storm Water Quality Handbook

Maintenance Staff Guidance – 2003• Flexible Pavement (paving, crack/joint

grinding/sealing, pothole repair, sealing)• Rigid Pavement (cement crack/joint sealing,

mudjacking & drilling, concrete slab&spall repair)• Graffiti Removal• Bridges• Management & Support (storage, vehicle &

equipment fueling, cleaning, maintenance and repair, spill control, etc.)

MRP Requirements – Fixed Facilities

Stormwater Pump Stations• Inventory – completed March 2010• Inspections

– 2x during wet season after storm*– 2x during dry season– Observe trash, color, odor, turbidity, oily sheen

• Sampling– 2x during dry season for DO– weekly if DO ≤ 3mg/L

• Corrective actions if DO < 3mg/L

*first business day after ≥ ¼ inch storm preceded by min 2 weeks dry period

MRP Requirements – Fixed Facilities

Corporation Yards• Stormwater Pollution Prevention Plan• Inspections

— at least 1x year before wet season — follow up inspections if issues found

MRP Requirements - Training Rural Roads &Public Works Construction

and Maintenance• Training – 2x during permit term• SMCWPPP Training coming in Fall 2013

Illicit Discharge Detection and Elimination Requirements in the

MRP Provision C.5 Collection System Screening

• Catch basin and outfall inspections for illicit discharges/illegal dumping

• 1x year in dry weather conditions• Regular conveyance system inspections

count

Public Information & Outreach Requirements in the MRP

Provision C.7 Minimum 80% of municipal storm drain inlets

marked Inspect & maintain 80% at least 1x per 5-year

permit term Report annual % of inlet markings inspected &

maintained

Trash Load Reduction

Provision C.10 Install and maintain full trash capture

devices Clean Trash Hot Spots annually More information to come later in

Workshop!

SMCWPPP Assistance Municipal Maintenance Subcommittee

Meetings SMCWPPP Orientation Training materials Website: www.flowstobay.org

• Corporation yard inspection form• Stormwater pump station dry season DO

monitoring & inspection form• Corp yard SWPPP template• Sources of SW BMP information