HomeMy WebLinkAboutCouncil Reading File - 13383 Letter0
CALIFONNIA
Water Boards
State Water Resources Control Board
June 1, 2017
Certified Mail: 7015 1660 0000 1530 8393
City of San Luis Obispo
Attn: Derek Johnson or Environmental Coordinator
990 Palm Street
San Luis Obispo, California 93401
AI
�l •l _ EDMUND G. BROWN JR.
+,. GOVERNOR
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JUN O 2 2017
SLO CITY CLERK
WDID: 3 40M2000124
WATER CODE SECTION 13383 ORDER TO SUBMIT METHOD TO COMPLY WITH
STATEWIDE TRASH PROVISIONS; REQUIREMENTS FOR TRADITIONAL SMALL
MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PERMITTEES
Dear Derek Johnson:
On April 7, 2015, the State Water Resources Control Board (State Water Board) adopted
statewide Trash Provisions691 to address the pervasive impacts trash has on the beneficial uses
of our surface waters. Throughout the state, trash is typically generated on land and transported
to surface water, predominantly through MS4 discharges. These discharges from Phase II
MS4s are regulated through a statewide general permit (Phase II MS4 Permit) 692 pursuant to
section 402(p) of the Federal Clean Water Act.
The Trash Provisions establish a statewide water quality objective for trash and a prohibition of
trash discharge, or deposition where it may be discharged, to surface waters of the State. For
Phase II MS4 permittees that have regulatory authority over Priority Land Uses,*693 the Trash
Provisions require implementation of the prohibition through requirements incorporated into the
Phase II MS4 Permit and/or through monitoring and reporting orders, by June 2, 2017. The
State Water Board does not anticipate amending the existing Phase II MS4 Permit within the
time frame specified by the Trash Provisions. Therefore, the initial steps in planning for the
implementation of the Trash Provisions are required through this Order in accordance with
Water Code section 13383, as specified in the Trash Provisions,694 and as further authorized by
Clean Water Act section 308(a) and 40 Code of Federal Regulations part 122.41(h). The
implementation plans submitted in response to this Order are subject to approval by the State
Water Board and appropriate Regional Water Quality Control Board (Regional Water Board).
691 Amendment to the Water Quality Control Plan for Ocean Waters of California to Control Trash (Ocean Plan) and
Part 1 Trash Provisions of the Water Quality Control Plan for Inland Surface Waters, Enclosed Bays, And Estuaries
Of California (ISW EBE Plan) to be adopted by the State Water Board. Documents may be downloaded from our
website at http://www.waterboards.ca.gov/water issues/oroarams/trash control/documentation.shtml .
692 National Pollutant Discharge Elimination System (NPDES) General Permit for Waste Discharge Requirements for
Storm Water Discharges from Small Municipal Separate Storm Sewer Systems (MS4s), Order No. 2013-0001-
DWQ, NPDES No. CAS000004.
693 All terms marked with an asterisk " are defined in Enclosure, Trash Provisions Glossary.
694 Chapter IV.A.5.a.(1)B of the ISWEBE Plan and Chapter III.L.4.a.(1)B of the Ocean Plan.
FELICIA MARCUS, CHAIR I THOMAS HOWARD, EXECUTIVE DIRECTOR
1001 1 Street, Sacramento, CA 95814 1 Mailing Address: P.O. Box 100, Sacramento, CA 95812-0100 1 www.waterboards c„
RECYCLED PAPER
City of San Luis Obispo - 2 - June 1, 2017
This Order is issued to implement federal law. The water quality objective established by the
Trash Provisions serves as a water quality standard federally mandated under Clean Water Act
section 303(c) and the federal regulations. (33 U.S.C. § 1312, 40 C.F.R. § 131.) This water
quality standard was specifically approved by U.S. EPA following adoption by the State Water
Board and approval by the Office of Administrative Law. This Order requests information
necessary for municipal permittees to plan for implementation of actions to achieve the water
quality standard for trash. Further, the water quality standard expected to be achieved pursuant
to the Trash Provisions may allow each water body impaired by trash and already on the Clean
Water Act section 303(d) list to be removed from the list, or each water body subsequently
determined to be impaired by trash to not be placed on the list, obviating the need for the
development of a total maximum daily load (TMDL) for trash for each of those water bodies. (33
U.S.C. § 1313(d); 40 C.F.R. § 130.7.) In those cases, the specific actions that will be proposed
by the municipal permittees in response to this Order substitute for some or all of the actions
that would otherwise be required consistent with waste load allocations in a trash TMDL. (40
C.F.R. § 122.44, subd. (d)(1)(vii)(B).) This Order nevertheless allows municipal permittees to
select specific proposed actions to meet the federal requirements.
Non -municipal MS4 permittees, referred to as non-traditional MS4 permittees, are not subject to
this Order. Non-traditional MS4 permittees generally do not have significant areas of Priority
Land Uses under their authority. Therefore, this Order is not being issued to non-traditional
MS4 permittees. Non-traditional MS4 permittees that generate substantial amounts of trash"'
may be issued a separate Water Code section 13383 Order with requirements for Priority Land
Uses and/or any additional specific land uses within their jurisdiction.
The Trash Provision requires Phase II MS4 permittees with regulatory authority over Priority
Land Uses to select a method of compliance with the trash prohibition. Through this Order, the
State Water Board requires Phase II traditional MS4 permittees to determine and report their
selection of either the following Track 1 or Track 2 compliance methods .116
1. Track 1: Install, operate, and maintain Full Capture Systems* for the storm drain network
that capture runoff from the Priority Land Uses in their jurisdiction.
Phase II MS4 permittees that select the Track 1 compliance method may discover that there
are locations within their storm drain network where full capture systems cannot be
implemented, or are better implemented within another land use area. The Trash Provisions
allow a Phase II MS4 permittee with regulatory authority over Priority Land Uses to request,
from the appropriate Regional Water Board Executive Officer, to substitute one or more
Priority Land Uses with equivalent alternate land uses*697 within the MS4 permittee's
jurisdiction.
2. Track 2: Install, operate, and maintain any combination of Full Capture Systems, Multi -
Benefit Projects," other Treatment Controls,* and/or Institutional Controls' within either the
jurisdiction of the MS4 permittee or the jurisdiction of the MS4 permittee and contiguous
MS4 permittees. The MS4 permittee may determine the locations or land uses within its
jurisdiction to implement any combination of controls. Permittees choosing Track 2 must
695 Chapter IV.A.3.d of ISWEBE Plan or Chapter III1.2.d of the Ocean Plan.
696 Chapter IV.A.3.a. of the ISWEBE Plan and Chapter III1.2.a. of the Ocean Plan.
697 See definition of Priority Land Uses in enclosed Trash Provisions Glossary.
City of San Luis Obispo - 3 - June 1, 2017
demonstrate that the approach 698 will achieve Full Capture System Equivalency.*
To ensure the compliance method selection is completed accurately, the State Water Board,
through this Order, requires the traditional Phase II MS4 permittees to complete and submit the
following:
1. Jurisdictional Maps. Traditional Phase II MS4 permittees must develop jurisdictional maps
identifying Priority Land Use areas, the corresponding storm drain network and associated
drainage areas, and proposed locations for certified Full Capture System installations.
Permittees selecting the Track 1 compliance method and are proposing alternative land
uses shall identify the alternative land uses on the jurisdictional map and the corresponding
priority land uses being substituted.
Permittees selecting the Track 2 compliance method may determine the locations or land
uses within their jurisdictions to implement any combination of controls that achieve Full
Capture System Equivalency. Therefore, the permittee shall also identify on the jurisdictional
maps the selected locations or land uses where a combination of controls, which are
identified in Track 2 above, will be implemented to achieve Full Capture System
Equivalency.
The State Water Board recognizes that field surveys may be necessary to ensure the
accuracy of jurisdictional map development. Therefore, this Order requires Phase II MS4
permittees to provide preliminary jurisdictional maps within three months from the date of
this Order, and final jurisdictional maps within eighteen months from the date of this Order.
These jurisdictional maps will assist review of the compliance method selection by the State
Water Board and Regional Water Boards and also support development of appropriate
permit requirements in a future Phase II MS4 permit reissuance.
2. Trash Assessments. Traditional Phase II MS4 permittees that elect the Track 2 compliance
method must conduct and submit trash assessments to identify existing levels of trash
generation.
Through this Order, the State Water Board directs Traditional Phase II MS4 permittees
selecting Track 2, at a minimum, to conduct a trash assessment of the Priority Land Use
areas, even if they subsequently select other locations or land uses within their jurisdiction
to implement any combination of controls that meet Full Capture System Equivalency. If
proposing to select locations or land uses other than Priority Land Uses, the permittee must
also assess trash levels at those locations or land uses and provide a justification
demonstrating that the selected locations or land uses generate trash at rates that are
equivalent to or greater than the Priority Land Uses. State or Regional Water Board
approval may be based on the proposed trash assessments and corresponding
justification.sss
698 The MS4 permittee may determine which controls to implement to achieve compliance with the Full Capture
System Equivalency. It is, however, the State Water Board's expectation that the MS4 permittee will elect to install
Full Capture Systems where such installation is not cost -prohibitive. (Chapter IV.A.3.a.(2) of the ISWEBE Plan and
Chapter III.L.2.a.(2) of the Ocean Plan).
699 In accordance with Permitting Authority's discretional authority under Chapter N.A.M. of the ISWEBE Plan or
Chapter III.L.2.d. of the Ocean Plan.
City of San Luis Obispo - 4 -
June 1, 2017
The Trash Provisions provide two example trash assessment approaches for permittees to
demonstrate Full Capture System Equivalency when a permittee selects the Track 2
compliance method. Phase II MS4 permittees may use alternative methods to demonstrate
Full Capture System Equivalency. One alternative method currently implemented in the San
Francisco Bay region is the Visual Trash Assessment Approach, an accepted assessment
approach based on on -land visual trash assessments .700 A description of the Visual Trash
Assessment Approach 7111 is enclosed in this Order and may be used by Phase II MS4
permittees to meet the requirement for a baseline assessment.
Information resulting from the trash assessments is necessary to develop appropriate
requirements and provisions in the future Phase II MS4 Permit reissuance, including:
(1) Establishing a baseline for compliance tracking and determinations,
(2) Establishing interim milestones to demonstrate progress towards 100 percent
compliance with the Trash Provisions within 10 years of the effective date of the
implementing permit,702
(3) Evaluating the permittees' planned implementation of Full Capture System Equivalency,
and in
(4) Approving the implementation plan.
Permittees that select the Track 1 compliance method through implementation of certified
Full Capture Systems in all storm drains that capture runoff from all Priority Land Use areas
are not required to conduct trash assessments. Through the Track 1 compliance method,
the State Water Board provides a streamlined compliance pathway with annual progress
reporting of Full Capture System installation.
3. Implementation Plan. The implementation plan required by this Order in clause 3 below
is subject to approval by the State Water Board Executive Director and/or the corresponding
Regional Water Board Executive Officer.703 A request for an equivalent alternative land use
identified on the jurisdictional map, section 1 above, must be submitted within the
implementation plan and approved by the Regional Water Board Executive Officer prior to
installation and implementation of certified Full Capture Systems or Full Capture System
Equivalency trash controls.
700 The State Water Board -funded an evaluation (through Proposition 84 grant funds) of the on -land visual trash
assessment method as part of the Tracking California's Trash project conducted by the Bay Area Stormwater
Management Agencies Association (BASMAA). The evaluation concluded that if visual assessments were conducted
consistent with the protocol, the method could reliably establish baseline trash levels and detect progress in reducing
trash in MS4 discharges over time.
701 See Enclosure, Recommended Trash Assessment Minimum Level of Effort.
702 Chapter IV.A.5.a.(2) and (3) of ISWEBE Plan or Chapter III1.4.a.(2) and (3) of the Ocean Plan.
703 Chapter IV.A.5.a.(1)B of the ISWEBE Plan or Chapter III1.4.a.(1)B of the Ocean Plan
City of San Luis Obispo - 5 - June 1, 2017
Pursuant to Water Code section 13383, IT IS HEREBY ORDERED THAT, as a Permittee of the
statewide Phase II MS4 permit, you shall:
1. By September 1, 2017, submit electronically via SMARTS:704
a. A letter to State Water Board identifying the permittee's selected compliance
option, (Track 1 or Track 2) as defined in this Order; and
b. A preliminary jurisdictional map(s) identifying the following:
i. Priority Land Use areas discharging to the storm drain network ; and
ii. The corresponding storm drain network that receives discharges from
Priority Land Use areas.
2. Permittees Selecting Track 1: By December 1, 2018, submit electronically via SMARTS,
an updated jurisdictional map(s) identifying the following:
i. All Priority Land Use areas discharging to the storm drain network;
ii. The corresponding storm drain network;
iii. Proposed locations of all certified Full Capture Systems705 and,
iv. Proposed equivalent alternative land uses, documentation demonstrating that the
substitution of equivalent alternative land uses has been approved by the
appropriate Regional Water Board Executive Officer, and corresponding storm
drainage network, if applicable.
3. Permittees Selecting Track 2: By December 1, 2018, submit electronically via SMARTS,
the following:
An updated jurisdictional map(s) identifying the following:
a) All Priority Land Use areas and selected locations and land uses, other than
the Priority Land Uses area, discharging to the storm drain network;
b) The corresponding storm drain network; and
c) Proposed locations of all certified Full Capture Systems and where any
combination of controls will be implemented that will achieve Full Capture
System Equivalency;
d) Trash levels, using the methodology described in the attached recommended
Visual Trash Assessment Approach or other equivalent trash assessment
methodology, for all Priority Land Uses, and for other selected locations or
land uses within the MS4s jurisdiction if proposing to implement any
combination of controls in locations other than Priority Land Uses; and
704 SMARTS stands for Storm Water Multiple Application and Report Tracking System and is an online database for
dischargers to electronically file their permit documents. It can be accessed at:
hUps://smarts.waterboards.ca.gov/smarts/faces/SwSmartsLogi n.xhtmI
705 A list of Certified Full Capture Systems is located at:
http://www. waterboards.ca.gov/water issues/prog rams/stormwater/municipal.shtm I
City of San Luis Obispo - 6 - June 1, 2017
An Implementation Plan that includes the following:
a) The rationale for how the selected combination of controls will achieve Full
Capture System Equivalency;
b) The rationale for how Full Capture System Equivalency will be demonstrated;
c) If using a methodology other than the attached recommended Visual Trash
Assessment Approach to determine trash levels, a description of the
methodology used and rationale of how the alternative methodology is
equivalent to the recommended Visual Trash Assessment Approach; and
d) If proposing to select locations or land uses other than Priority Land Uses, a
rationale demonstrating that the alternative land uses generate trash at rates
that are equivalent to or greater than the Priority Land Uses.
The Legally Responsible Person identified in SMARTS must sign and certify all submittals
required by this Order, with the following certification:
"7 certify under penalty of law that this document and all attachments were prepared
under my direction or supervision in accordance with a system designed to assure that
qualified personnel properly gather and evaluate the information submitted. Based on
my inquiry of the person or persons who manage the system, or those persons directly
responsible for gathering the information, the information submitted is, to the best of my
knowledge and belief, true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fine and
imprisonment for knowing violations."
Failure to comply with this Order, or falsifying any information provided therein, may result in
enforcement action including civil liabilities for late or inadequate reports consistent with Water
Code section 13385.
Questions regarding this Order or any requests for assistance should be directed to
Mr. Leo Cosentini of the Division of Water Quality at (916) 341-5524 or
leo.cosentini @waterboards.ca.gov.
Sincerely,
Thomas Howard
Executive Director
Enclosures (3): Trash Policy Implementation Procedure Flowchart
Trash Provisions Glossary
Recommended Trash Assessment Minimum Level of Effort
cc: [see next page]
City of San Luis Obispo - 7 - June 1, 2017
cc: [via email]
Matthias St. John
North Coast regional Water Quality Control Board
matth ias. st. ioh n @ waterboards. ca.gov
Bruce Wolfe
San Francisco Bay Regional Water Quality Control Board
bruce.wolfe @ waterboards.ca.aov
John Robertson
Central Coast Regional Water Quality Control Board
iohn.robertson @waterboards_ca.gov
Samuel Unger
Los Angeles Regional Water Quality Control Board
sam u el, un a er @ waterboards.ca. aov
Pamela Creedon
Central Valley Regional Water Quality Control Board
Pamela. creedon @ waterboards.ca.gov
Patty Kouyoumdjian
Lahontan Regional Water Quality Control Board
Patty.kouyoumdiian @ waterboards.ca.gov
Jose Angel
Colorado River Basin Regional Water Quality Control Board
i ose. a nae I @ waterboards, ca.aov
Kurt Berchtold
Santa Ana Regional Water Quality Control Board
kurt. berchtold @ waterboards.ca.gov
David Gibson
San Diego Regional Water Quality Control Board
david. g ibson @ waterboards. ca.gov
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Trash Provisions Glossary
Water Boards
This glossary is an excerpt of the Trash Provisions of the Water Quality Control Plan for Inland
Surface Waters Enclosed Bas and Estuaries of California, and the California Ocean Plan.
Full Capture System: A treatment control*, or series of treatment controls, including but not
limited to, a multi -benefit project* or a low -impact development control* that traps all particles
that are 5 mm or greater, and has a design treatment capacity that is either:
a) of not less than the peak flow rate, Q, resulting from a one-year, one-hour, storm in the
subdrainage area, or
b) appropriately sized to, and designed to carry at least the same flows as, the corresponding
storm drain.
[Rational equation is used to compute the peak flow rate: Q = C x I x A, where Q = design
flow rate (cubic feet per second, cfs); C = runoff coefficient (dimensionless); I = design
rainfall intensity (inches per hour, as determined per the rainfall isohyetal map specific
to each region, and A = subdrainage area (acres).]
Prior to installation, full capture systems* must be certified by the Executive Director, or
designee, of the State Water Board. Uncertified full capture systems will not satisfy the
requirements of these Trash Provisions*. To request certification, a permittee shall submit a
certification request letter that includes all relevant supporting documentation to the State Water
Board's Executive Director. The Executive Director, or designee, shall issue a written
determination approving or denying the certification of the proposed full capture system or
conditions of approval, including a schedule to review and reconsider the certification. Full
capture systems certified by the Los Angeles Regional Water Board prior to the effective date of
these Trash Provisions and full capture systems listed in Appendix I of the Bay Area -wide Trash
Capture Demonstration Project, Final Project Report (May 8, 2014) will satisfy the requirements
of these Trash Provisions, unless the Executive Director, or designee, of the State Water Board
determines otherwise.
Full Capture System Equivalency: The trash* load that would be reduced if full capture
systems were installed, operated, and maintained for all storm drains that capture runoff from
the relevant areas of land (priority land uses*, significant trash generating areas*, facilities or
sites regulated by NPDES permits for discharges of storm water* associated with industrial
activity, or specific land uses or areas that generate substantial amounts of trash, as
applicable). The full capture system equivalency* is a trash load reduction target that the
permittee quantifies by using an approach, and technically acceptable and defensible
assumptions and methods for applying the approach, subject to the approval of permitting
authority*. Examples of such approaches include, but are not limited to, the following:
(1) Trash Capture Rate Approach. Directly measure or otherwise determine the amount of
trash captured by full capture systems for representative samples of all similar types of
* Defined within this document. Page 1
land uses, facilities, or areas within the relevant areas of land over time to identify
specific trash capture rates. Apply each specific trash capture rate across all similar
types of land uses, facilities, or areas to determine full capture system equivalency.
Trash capture rates may be determined either through a pilot study or literature review.
Full capture systems selected to evaluate trash capture rates may cover entire types of
land uses, facilities, or areas, or a representative subset of types of land uses, facilities,
or areas.
With this approach, full capture system equivalency is the sum of the products of each
type of land use, facility, or area multiplied by trash capture rates for that type of land
use, facility, or area.
(2) Reference Approach. Determine the amount of trash in a reference receiving water in a
reference watershed where full capture systems have been installed for all storm drains
that capture runoff from all relevant areas of land. The reference watershed must be
comprised of similar types and extent of sources of trash and land uses (including
priority land uses and all other land uses), facilities, or areas as the permittee's
watershed. With this approach, full capture system equivalency would be demonstrated
when the amount of trash in the receiving water is equivalent to the amount of trash in
the reference receiving water.
Institutional Controls: Non-structural best management practices (i.e., no structures are
involved) that may include, but not be limited to, street sweeping, sidewalk trash* bins, collection
of the trash, anti -litter educational and outreach programs, producer take -back for packaging,
and ordinances.
Low -Impact Development Controls: Treatment controls that employ natural and constructed
features that reduce the rate of storm water runoff, filter out pollutants, facilitate storm water
storage onsite, infiltrate storm water into the ground to replenish groundwater supplies, or
improve the quality of receiving groundwater and surface water. (See Water Code § 10564.)
Multi -Benefit Project: a treatment control* project designed to achieve any of the benefits set
forth in section 10562, subdivision (d) of the Water Code. Examples include projects designed
to: infiltrate, recharge, or store storm water for beneficial reuse; develop or enhance habitat and
open space through storm water and non -storm water management; and/or reduce storm water
and non -storm water runoff volume.
Municipal Separate Storm Sewer System (MS4): Same meaning set forth in 40 Code of
Federal Regulations section 122.26(b)(8).
Preproduction Plastic: Same meaning set forth in section 13367(a) of the Water
Code.
Priority Land Uses: Those developed sites, facilities, or land uses (i.e., not simply
* Defined within this document. Page 2
zoned land uses) within the MS4 permittee's jurisdiction from which discharges of trash* are
regulated by these Trash Provisions* as follows:
(1) High-density residential: all land uses with at least ten (10) developed dwelling
units/acre.
(2) Industrial: land uses where the primary activities on the developed parcels involve
product manufacture, storage, or distribution (e.g., manufacturing businesses,
warehouses, equipment storage lots, junkyards, wholesale businesses, distribution
centers, or building material sales yards).
(3) Commercial: land uses where the primary activities on the developed parcels involve the
sale or transfer of goods or services to consumers (e.g., business or professional
buildings, shops, restaurants, theaters, vehicle repair shops, etc.)
(4) Mixed urban: land uses where high-density residential, industrial, and/or commercial
land uses predominate collectively (i.e., are intermixed).
(5) Public transportation stations: facilities or sites where public transit agencies' vehicles
load or unload passengers or goods (e.g., bus stations and stops).
Equivalent alternate land uses: An MS4 permittee with regulatory authority over priority
land uses may issue a request to the applicable permitting authority* that the MS4
permittee be allowed to substitute one or more land uses identified above with alternate
land uses within the MS4 permittee's jurisdiction that generates rates of trash that is
equivalent to or greater than the priority land use(s) being substituted. The land use
area requested to substitute for a priority land use need not be an acre -for -acre
substitution but may involve one or more priority land uses, or a fraction of a priority land
use, or both, provided the total trash generated in the equivalent alternative land use is
equivalent to or greater than the total trash generated from the priority land use(s) for
which substitution is requested. Comparative trash generation rates shall be established
through the reporting of quantification measures such as street sweeping and catch
basin cleanup records; mapping; visual trash presence surveys, such as the "Keep
America Beautiful Visible Litter Survey"; or other information as required by the
permitting authority.
Permitting Authority: The State Water Board or Regional Water Board, whichever issues the
permit.
Significant Trash Generating Areas: All locations or facilities within the Department's
jurisdiction where trash* accumulates in substantial amounts, such as:
(1) Highway on- and off -ramps in high density residential, commercial, and industrial land
uses (as such land uses are defined under priority land uses* herein).
(2) Rest areas and park -and -rides.
(3) State highways in commercial and industrial land uses (as such land uses are defined
under priority land uses herein).
(4) Mainline highway segments to be identified by the Department through pilot studies
and/or surveys.
* Defined within this document. Page 3
Storm Water: Same meaning set forth in 40 Code of Federal Regulations section 122.26(b)(13)
(Nov. 16, 1990).
Treatment Controls: Structural best management practices to either (a) remove pollutants
and/or solids from storm water` runoff, wastewater, or effluent, or (b) capture, infiltrate or reuse
storm water runoff, wastewater, or effluent treatment controls* include full capture systems* and
low impact development controls*.
Trash: All improperly discarded solid material from any production, manufacturing, or
processing operation including, but not limited to, products, product packaging, or containers
constructed of plastic, steel, aluminum, glass, paper, or other synthetic or natural materials.
Trash Provisions: The water quality objective for trash*, as well as the prohibition of discharge
and implementation requirements set forth in Implementation of Water Quality Objectives of the
Water Quality Control Plan for Inland Surface Waters, Enclosed Bays, and Estuaries of
California Plan.
* Defined within this document. Page 4
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Recommended Trash Assessment Minimum
Level of Effort for
Establishing Baseline Trash Generation Levels
The following trash assessment minimum level of effort (TAMLE) is recommended by the State
Water Resources Control Board (State Water Board) for establishing baseline trash generation
levels in Priority Land Uses and/or other land uses and locations. The TAMLE is based on the
findings of a recent Proposition 84 study (Tracking California's Trash) completed in 2016 that
was funded by the State Water Board. The recommended TAMLE utilizes Tracking California's
Trash On -land Visual Trash Assessment protocols to establish qualitative estimates of the
amount of trash generated on street segments, sidewalks and adjacent land areas, and
transported into the MS4. The complete protocol can be found here:
http://basmaa.org/Announcements/tracking-cas-trash-on-land-visual-assessments
The protocol has been extensively and successfully used by San Francisco Bay Area Phase I
municipalities to establish baseline trash generation maps that serve as the starting point for
demonstrating trash reductions into the MS4. Trash generation categories (A -Low, B -Moderate,
C -High, and D -Very High) based on the levels of trash observed during assessments are
assigned to adjacent land areas (e.g., priority land use areas), which are then illustrated on
baseline trash generation maps. Each trash generation category has a corresponding trash
generation rate that was established during the Bay Area Trash Generation Rate Study
(BASMAA 2014) and confirmed during the recent Tracking California's Trash project (BASMAA
2016).
Establishing Baseline Trash Generation Maps
Consistent with the 13383 Order, Phase II MS4 permittees (Permittees) are directed to submit
maps illustrating priority land uses and/or other land uses and locations that drain into their
MS4. Connections from within priority land use private property must also be identified. These
areas serve as the locations where trash reductions are mandated by the Trash Amendments.
Additionally, Permittees selecting Track 2 are also directed to identify baseline trash generation
levels for each priority land use and/or other selected land uses and locations.
Equipment and Methods
The TAMLE methodology is relatively simple and inexpensive to use, but provides a level of
precision needed to accurately depict baseline trash generation. The protocol requires a
minimum of two field crew members, both for objectivity and safety, each trained in the use of
the TAMLE protocol. Very limited equipment is needed (i.e., clipboard, pencils/pens, digital
camera preferably with GPS capabilities, and field forms and maps). Bright clothing or safety
vests are also recommended for field crew members.
MS4 permittees employ the following steps to establish baseline trash generation levels via
TAMLEs:
Recommended Trash Assessment Minimum Level of Effort
For Establishing Baseline Trash Generation Levels
1. Assemble equipment needed to conduct the assessment including the field form delineating
the assessment area and review trash assessment category definitions presented in the
protocol.'
2. Once at the Priority Land Use area and other selected land use or locations to be assessed
(hereinafter referred to as Assessment Area), safely walk at a normal pace on the sidewalk
adjacent to the Assessment Area observing the levels of trash present on the street,
sidewalk, and adjacent land areas that could be transported to the MS4. In areas where no
sidewalk is present, assessments may be conducted by slowly driving adjacent to the
Assessment Area and observing trash on the street and sidewalk.z
3. Collectively agree on the appropriate trash generation category to assign the Assessment
Area and document the category observed on field data sheets and/or maps. Crew members
should take at least one photograph per Assessment Area to document that the site was
visited and to document the level of trash present.
4. Assessment results should be transferred to trash generation maps to illustrate baseline trash
generation levels in the Assessment Areas. Color -coding maps based on the trash levels
observed (Green=Low, Yellow=Moderate, Red=High, and Purple=Very High) during
TAMLEs.
Frequency and Timing of Assessments
To accurately establish baseline trash generation levels for the Assessment Area, a minimum of
two TAMLEs should be conducted on streets and sidewalks associated with each Assessment
Area (BASMAA 2016). To the extent possible, assessments should be conducted during both
the dry (April -September) and wet (October- March) seasons. So that baseline trash generation
levels are not under -predicted, assessments should be conducted at timeframes when the
greatest level of trash has accumulated on streets and sidewalks (e.g. directly before street -
sweeping events). Additionally, in order to reduce the influence of recent rainfall -runoff events
that may have washed street trash into storm drains, TAMLEs should only be conducted if less
than 0.5 inches of rainfall has occurred in a 24 hour period, 48 hours prior to the assessment.
Estimated Resources Needed to Establish Baseline Generation Levels via TAMLEs
The extent of the Assessment Areas within each MS4 permittee's jurisdiction will govern the
level of effort needed to establish the baseline trash generation levels using TAMLEs. The more
Assessment Areas within a city/county, the more time and resources will be needed to conduct
assessments and map the results. The following examples are based on the experience of
MS4s in the San Francisco Bay Area and are given to provide rough estimates of the time that
an MS4 permittee (small or moderate sized city) would need to expend to establish baseline
trash generation levels in Assessment Areas using the TAMLE approach.
'Trash generation rates are: Low (0 — 5 gallons/acre/year); Moderate (5-10 gallons/acre/year);
High (10-15 gallons/acre/year); and Very High (50-150 gallons/acre/year).
'This technique should only be used when automobiles are not parked on the street, which can
obstruct the view of trash.
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Recommended Trash Assessment Minimum Level of Effort
For Establishing Baseline Trash Generation Levels
Task
Example #1
Smaf-S&ed To
Polo - 1Z500)
Example #2
Moderate -Sized City
(Aw = SELWD)
Assumptions
PLU Area (acres)
150
1500
Assessment Length per PL U Area(feet W acre)
75
75
Hrs for two staff to conduct 1,000 ft assessment
(including travel time)
0.5
0.5
Frequency of Assessment in each PLU Area
2
2
Tasks
Staff Hours
Staff Hours
Preparation for Assessments
5
20
Conducting OVTAs (Two Staff Members)
11
113
Data Compilation/Management
3
20
Mapping Assessment Results
24
40
Total Estimated Staff Hours
43
193
Citations
Bay Area Stormwater Management Agencies Association (BASMAA). 2014. San Francisco Bay Area Stormwater Trash
Generation Rates. Prepared by EOA, Inc. May.
Bay Area Stormwater Management Agencies Association (BASMAA). 2016. Evaluation of the On -land Visual Assessment
Protocol as a Method to Establish Baseline Levels of Trash and Detect Improvements in Stormwater Quality. Tracking
California's Trash Project. State Water Resources Control Board Grant Agreement No. 12-420-550. Prepared by EOA, Inc.
December.
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