MRP Pollutants of Concern Trash Provisions

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MRP Pollutants of Concern Trash Provisions

• Monday November 20, 2006
• Richard Looker - RWQCB

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Overview and Philosophy

• Making significant progress on trash during this
  permit is a high priority for POC.
• Two components to Water Board approach
• Trash in urban tributaries
• Trash entering the Bay via storm drains
• Our approach focuses on accountability and
  measurable progress
• Permit specifies assessment methods and
• Expectations of progress
• DOES NOT prescribe methods or means, we leave
  that totally up to programs.

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Component 1 - tributaries

• Conduct 2 wet and 2 dry weather baseline
  assessments using Rapid Trash Assessment v8.
• Where lower reaches of most major tributaries in
  region (needs to be specified in permit).
• Need them spaced at least one month apart to
  better estimate accumulation rates.
• Emphasize those sites that are likely impacted by
  trash from industrial locations, commercial use,
  intensive public access, etc.
• Report results in Year 2

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Component 1 - tributaries

• Implement necessary control measures to ensure
  these performance standards are met
• Dry season accumulation rate lt 1 piece /100
  ftday.
• Wet season accumulation rate reduced by 50 for
  those sites with accumulation rates greater than
  2 pieces / 100ftday
• Number of items found reduced by 50 for those
  sites where baseline assessments found gt 300
  items/100ft.
• Report results in Year 4 and status report of
  actions being taken in Year 3
• For sites not meeting performance standard,
  submit a plan of action to achieve it during next
  permit term.

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Component 2 storm drains

• Conduct wet season baseline assessments in all
  urban storm drains to Bay over period of 2 yrs
• Measure amount of trash in a consistent set of
  units
• Report results in year 4
• Evaluate attainable performance standards or
  effluent limit options for various seasons,
  conditions and drainage types (tribs and storm
  drains).
• Refine assessment methodologies if necessary
  (tribs and storm drains)

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BASMAA provisions

• BASMAA submitted provisions that had LOTS of
  detail about updating legal authority,
  identifying candidate sites and conducting
  demonstration projects.
• We are not willing or able to regulate trash in
  this manner.
• Rather, we will prescribe
• Assessment methods improvement targets
• Programs decide HOW to achieve targets

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Feedback from Municipalities

• Overlap and redundancy between POC provisions and
  Section 2 provisions streamline and consolidate
• Litter is a bad habit that cities cannot do
  anything about
• Cities cannot control trash thrown directly into
  creeks
• Cities cannot enter creeks for cleanup without
  cooperation of the owner (flood control
  districts)
• 2 wet 2 dry baseline assessments is too many
• Do cost/benefit analysis to support requirement
  of trash removal programs

8
Environmental NGOs said

• Make clear that trash impairs water quality no
  matter what the pathway, and permit holders are
  responsible for reducing/preventing impacts from
  trash through all pathways, not just storm
  drains.
• Add clear provisions for enforcement and
  penalties for failure to comply with requirements
  of MRP.
• Streamline the provisions and eliminate
  inconsistencies between different mentions of
  trash throughout permit.

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Environmental NGOs (cont)

• Define urban and ensure that use of this term
  does not exclude areas that are less urbanized
  but still highly impacted by trash.
• Include or attach a list of applicable
  tributaries and locations thereon that should be
  assessed.
• The urban tributaries section gives permittees
  two years to gather baseline data and then calls
  for measurable reductions from that baseline. Do
  the same for urban storm drains section.
• MRP should make assessment data publicly
  available.

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Other issues to work out

• Where to do assessments (use Santa Clara and
  SWAMP experience)?
• Number of locations and effort can be scaled to
  population?
• Modifications to assessment protocols.
• Need to coordinate assessment with creek cleanup
  efforts so not to bias assessment.
• i.e. Do not do baseline or follow-up assessment
  the day after a creek cleanup effort.