City of Salinas Public Works Department - Engineering and Transportation 200 Lincoln Avenue
Salinas, California 93901
(831) 758-7241
August 4, 2016
Michael D. Godwin Central Coast Regional Water Quality Control Board 895 Aerovista Place, Suite 101 San Luis Obispo, California 93401-7906 Subject: Transmittal of City of Salinas Year 4 (2015-2016) NPDES Annual Report for Order No. R3-2012-0005, NPDES Permit No. CA0049981
Dear Mr. Godwin: The City of Salinas has prepared its 2015-2016 NPDES Permit Program Annual Report. We are transmitting this document to you electronically. Once you have received the document, we would appreciate your sending a confirming email to Ms. Heidi Niggemeyer of the City's Public Works Department at the following e-mail address:
[email protected]. This submittal fulfills the City's obligation with regards to the year 4 Annual Report for NPDES Permit No. CA 0049981, Order NO. R3-2012-0005. Sincerely,
Gary E. Petersen Director of Public Works
Encl:
2015-2016 Annual Report
Cc/encl: Walter Grant, Heidi Niggemeyer
2015 - 2016 (Permit Year 4) ANNUAL STORMWATER REPORT FOR
ORDER NO. R3-2012-0005 NPDES PERMIT NO. CA0049981 CITY OF SALINAS, CALIFORNIA
Natividad Creek Detention Facility
Chinatown Before Clean-Up
Chinatown After Clean-Up
August 4th, 2016
Rec. Ditch MHRT Clean-Up
Table of Contents Executive Summary of City of Salinas Year 4 Annual Report ............................................................................................. vii Provision E: Municipal Maintenance .................................................................................................................................. E-1 E.15.c – Reporting Requirements Since Year 2................................................................................................................... E-1 E.15.c.i – Providing Curb Access for Street Sweepers...................................................................................................... E-1 E.15.c.iii – Maintenance of Structural BMPs.................................................................................................................... E-1 E.15.c.iii.1, and 6 – City Owned Structural BMPs......................................................................................................... E-1 E.15.c.iii.2 – Total Number of Structural BMPs............................................................................................................ E-2 E.15.c.iii.3 – Structural BMP Inspections ..................................................................................................................... E-3 E.15.c.iii.5 – Information Management System ........................................................................................................... E-3 E.15.c.iii.7 and 8 – O&M BMPs .................................................................................................................................... E-3 E.15.c.v – Salinas River Outfall Pollutant Reduction Plan. ............................................................................................... E-3 E.15.e.i– Municipal Inventory .......................................................................................................................................... E-5 E.15.e.ii – Minimum BMPs for Municipal Facilities, Maintenance Operations and Events ............................................. E-6 E.15.e.iii and iv – Updates Made to High Priority Municipal Facility and Event SWPPPs as Well as Maintenance Operations SOPs .............................................................................................................................................................. E-7 E.15.e.v – Description of BMPs to Reduce Tracking of Dirt in the Streets....................................................................... E-8 E.15.e.vi – Summary of Weekly Visual Observations....................................................................................................... E-8 E.15.e.vii – Quarterly and Annual Inspections ............................................................................................................... E-11 E.15.e.ix – Catch Basin Cleaning and Inspection ............................................................................................................ E-12 E.15.e.x – Catch Basin Prioritization .............................................................................................................................. E-12 E.15.f.i – MS4 O&M........................................................................................................................................................ E-13 E.15.f.ii – Street Sweeping ............................................................................................................................................. E-13 E.15.f.iii – Contractor Oversight ..................................................................................................................................... E-15 E.15.f.iv – Training.......................................................................................................................................................... E-15 Provision F: Commercial and Industrial .............................................................................................................................. F-1 F.11 – Reporting requirements: .......................................................................................................................................... F-1 F.11.b: Year 2 On-going Reporting Requirements.............................................................................................................. F-1 F.11.b.i – Commercial and Industrial Inventory............................................................................................................... F-1 F.11.b.ii – Information Management System Updates .................................................................................................... F-1 F.11.b.iii – Commercial and Industrial BMPs Designated ................................................................................................ F-1 F.11.b.iv – Inspection Notification Procedure ................................................................................................................. F-7 i
F.11.b.v – Inspection Procedures ..................................................................................................................................... F-7 F.11.c: Year 3 On-going Reporting Requirements .............................................................................................................. F-7 F.11.c.i – Summary of Inventory and Prioritization Updates ........................................................................................... F-7 F.11.c.ii – Review of BMPs Required ................................................................................................................................ F-8 F.11.c.iii – New Facilities .................................................................................................................................................. F-8 F.11.c.v - vii – Inspection Results ..................................................................................................................................... F-9 F.11.d: Annual Reporting Requirements .......................................................................................................................... F-13 F.11.d.i – Verification of Tracking of Industrial Facility Monitoring Data ...................................................................... F-13 F.11.d.ii – Facility Referrals to CCWB ............................................................................................................................. F-14 F.11.d.iii – Implementation of Enforcement Response Plan ......................................................................................... F-14 F.11.d.iv – Contractor Oversight Procedures ................................................................................................................. F-16 F.11.d.v – Training .......................................................................................................................................................... F-16 F.11.d.vi – Sample Letters to Commercial and Industrial Facilities re: Requirements of Order.................................... F-16 Provision G: Residential ..................................................................................................................................................... G-1 G.6 – Reporting requirements: .......................................................................................................................................... G-1 G.6.c.i: High Priority Residential Areas ........................................................................................................................... G-1 G.6.c.ii: High Priority Private Development .................................................................................................................... G-1 G.6.c.iii: High Priority Residential Area and Activity BMPs ............................................................................................. G-1 G.6.d.i: Training ............................................................................................................................................................... G-4 G.6.d.ii: Residential Outreach of Stormwater Permit Requirements and BMPs ............................................................ G-4 Provision H: Illicit Discharge Detection and Elimination................................................................................................... H-1 H.14 – Reporting requirements: ........................................................................................................................................ H-1 H.14.c.i: Updates to MS4 System Map ........................................................................................................................... H-1 H.14.c.ii: Updates to the High Priority IDDE Area Map................................................................................................... H-1 H.14.c.iii: % Permit Coverage Area Designated as High Priority IDDE Area.................................................................... H-1 H.14.c.iv/v: Summary of Drive-by Inspections ................................................................................................................ H-1 H.14.c.vi: Actions Implemented by Permittee to reduce Incidental Runoff ................................................................... H-1 H.14.d.i: Dry Weather Screening .................................................................................................................................... H-2 H.14.d.ii: IDDE Source Tracking Procedures ................................................................................................................... H-4 H.14.d.iii: IDDE Source Investigations Performed and Corrective Actions Taken .......................................................... H-4 H.14.e.i: Illicit Discharge Calls Received by Illicit Discharge Reporting System .............................................................. H-4 H.14.e.ii: Results of Testing of the Illicit Discharge Reporting System ........................................................................... H-4 H.14.e.iii: Summary of Activities Implemented for Used Oil and Toxic Material Disposal ............................................. H-5 H.14.e.iv: MS4 Inlet Labeling Status ............................................................................................................................... H-5 ii
H.14.e.v: Implementation of Enforcement Response Plan and Enforcement Actions Taken ........................................ H-5 H.14.e.vi/vii: Oversight Procedures for Staff Not Employed by the City/Training ......................................................... H-5 Provision J-Parcel-Scale Development ................................................................................................................................J-1 J.7 – Reporting Requirements: .............................................................................................................................................J-1 J.7.a.i: SWDS revisions Permit year 4: ..............................................................................................................................J-1 J.7.a.ii: Plan Review Process ..............................................................................................................................................J-1 J.7.a.iii: Guidance Provided to Development Project Applicants......................................................................................J-2 J.7.a.iv: Tracking Reports - Information Management System .........................................................................................J-5 J.7.a.v: Non-Priority and Priority Development Information ............................................................................................J-6 J.7.a.vi: Description of Enforcement Activities: ................................................................................................................J-6 J.7.a.vii: Training Report....................................................................................................................................................J-6 Provision K - Construction Site Management .................................................................................................................... K-1 K.13 – Reporting Requirements .......................................................................................................................................... K-1 K.13.a.i: Criteria Established for High Priority Construction Sites .................................................................................. K-1 K.13.a.ii: Implementation of Minimum Construction BMPs at Construction Sites ........................................................ K-1 K.13.a.iii: Review of Erosion and Sediment Control Plans ............................................................................................... K-4 K.13.d.i: Construction Sites That Did/Did Not Implement the Minimum Construction BMPs ....................................... K-8 K.13.d.ii: Summary of Inspections ................................................................................................................................... K-8 K.13.e.i: Structural BMPs Constructed that are Owned/Operated by the Permittee and Privately Owned/Operated .. K-9 K.13.e.ii: Summary of Structural BMPs Inspected During Construction ......................................................................... K-9 K.13.e.iii: Summary of Structural BMPs Inspected After Construction........................................................................... K-9 K.13.e.iv: Enforcement Response Plan ........................................................................................................................... K-9 K.13.e.v: Referrals to the Central Coast Water Board for Noncompliance or Non-filers ............................................... K-9 K.13.e.vi: Oversight Procedures ...................................................................................................................................... K-9 K.13.e.vii: Training Report ............................................................................................................................................. K-10 K.13.e.viii: Letters Sent to Construction Site Owners or Operators Pertaining to the Requirements of the Permit .. K-13 Provision L: Development Planning and Stormwater Retrofits......................................................................................... L-1 L.4.a.i - Specific Plan Conditions for Future Growth Areas .............................................................................................. L-1 L.4.a.iii - Urban Subwatershed-Scale Stormwater Planning ............................................................................................ L-1 L.4.a.iv - Riparian Protection Policies and Requirements ............................................................................................... L-1 L.2.b.i-iii: Retrofit Existing Development ........................................................................................................................ L-4 L.4.c.i - Salinas Participation in the Salinas Valley Integrated Regional Water Management (IRWM) Process ............ L-11 L.4.c.ii - Opportunities Examined by Permittee and IRWM for Stormwater Capture, Re-use and Infiltration for Aquifer Re-charge. ...................................................................................................................................................................... L-11 iii
L.4.c.iii & iv - Salt and Nutrient Management Plan(s). ................................................................................................... L-15 L.4.c.v - Identifying Areas in the Permit Coverage Area for Groundwater Recharge, Stormwater Management and the Location of Resources That Are Used for Groundwater Recharge and Stormwater Management. ............................. L-15 Provision M: Public Education and Public Involvement .................................................................................................. M-1 Introduction ....................................................................................................................................................................... M-1 M.2 – Collaboration........................................................................................................................................................... M-1 M.3 – Priority Stormwater Issues ..................................................................................................................................... M-1 M.4 – Target Audiences..................................................................................................................................................... M-1 M.5 – Outcomes ................................................................................................................................................................ M-2 M.6 – Assessment.............................................................................................................................................................. M-3 M.7 – Education Strategies and Methods: ....................................................................................................................... M-8 M.8 – Development Planning & Stormwater Controls for New Development and Redevelopment Projects: ............. M-9 M.8.a – Development Standards ................................................................................................................................... M-9 M.8.b – Design Requirements........................................................................................................................................ M-9 M.8.c – Conceptual/Preliminary Stormwater Control Plan ........................................................................................... M-9 M.8.d – O&M Requirements .......................................................................................................................................... M-9 M.8.e – Maintenance Declaration ................................................................................................................................ M-9 M.8.f – Water Body Setbacks ....................................................................................................................................... M-10 M.8.g – Planning Process ............................................................................................................................................. M-10 M.8.h – Construction Requirements............................................................................................................................ M-10 M.9 – Public Involvement: .............................................................................................................................................. M-14 M.10 – Website: .............................................................................................................................................................. M-16 M.11 – Annual Reporting: ............................................................................................................................................... M-17 Provision N - Trash Load Reduction ................................................................................................................................... N-1 N.5.a: Reporting Requirements ........................................................................................................................................ N-1 N.5.a.i: Verification of BMP Implementation.................................................................................................................. N-1 N.5.a.ii: Visual Inspection and Abatement Activities ..................................................................................................... N-1 N.5.d.: Progress in Implementing BMP Modifications ................................................................................................... N-5 N.5.e: Verification of Implementation of BMP Modifications ....................................................................................... N-7 N.5.f: Trash Reduction Tracking Methodology .............................................................................................................. N-8 Provision O: TMDLs ............................................................................................................................................................ O-1 O.3 – Reporting Requirements .......................................................................................................................................... O-1 O.3.a: Submittal of Wasteload Allocation Attainment Plan (WAAP) Within One Year or TMDL Approval by OAL – ..... O-1 O.3.b: Annual Reporting of WAAP Implementation, Activities, and Monitoring Results - ............................................. O-1 iv
Provision P: Monitoring, Effectiveness Assessment, ......................................................................................................... P-1 and Program Improvement................................................................................................................................................. P-1 P.8 – Reporting Requirements ............................................................................................................................................ P-1 P.8.a.i – Pesticide, Fertilizer and Herbicide Use ............................................................................................................... P-1 P.8.a.ii – Riparian Protection Data ................................................................................................................................... P-1 P.8.a.iii – Stormwater Discharge Trend Monitoring and Pollutant Loading Assessments............................................... P-1 P.8.d.i – Structural BMPs.................................................................................................................................................. P-1 P.8.d.ii – Pesticide, Herbicide, and Fertilizer Use............................................................................................................. P-1 P.8.d.iii – Industrial Facilities............................................................................................................................................ P-2 P.8.d.iv – Urban Catchment Action Level Pilot Projects .................................................................................................. P-2 P.8.d.v – Trash Action Level ............................................................................................................................................. P-2 P.8.f.i – Inspections .......................................................................................................................................................... P-2 P.8.f.ii – Catch Basin Cleaning .......................................................................................................................................... P-3 P.8.f.iii – Street Sweeping ................................................................................................................................................ P-3 P.8.f.iv – Pesticide, Herbicide, and Fertilizer Application - BMP Modifications.............................................................. P-3 P.8.f.v – Urban Catchment Action Level Pilot Projects .................................................................................................... P-4 P.8.f.vi – Trash Action Level ............................................................................................................................................. P-4 P.8.g.i – Catch Basin Cleaning .......................................................................................................................................... P-4 P.8.g.ii – Trash Quantification .......................................................................................................................................... P-4 P.8.h.i – Inspections ......................................................................................................................................................... P-4 P.8.h.ii – Catch Basin Inspection and Cleaning ................................................................................................................ P-4 P.8.h.iii – Verification the City progress in Reduction of Target Pollutant Exceedances in Industrial Discharges .......... P-4 Provision Q: Watershed Characterization ......................................................................................................................... Q-1 Q.1 – Watershed Data Information Management ............................................................................................................ Q-1 Q.2-Watershed Delineation ............................................................................................................................................... Q-1 Q.2.a Map of Features .................................................................................................................................................... Q-1 Q.2.b. MS4 System Map.................................................................................................................................................. Q-1 Q.3. Water Body Identification: ......................................................................................................................................... Q-1 Q.4. Watershed Physical Condition Assessment ............................................................................................................... Q-2 Q.5. Meteorological Information ....................................................................................................................................... Q-3 Provision R: Fiscal Analysis ................................................................................................................................................. R-1 R.2 – Annual Reporting Requirements ............................................................................................................................... R-1 Provision S: Legal Authority ................................................................................................................................................ S-1 S.5 – Reporting requirements: ............................................................................................................................................ S-1 v
S.5.a: Revisions to Regulations........................................................................................................................................ S-1 S.5.b: Certification Statement ......................................................................................................................................... S-1 S.5.c: Inventory of Illicit Discharges and Actions Taken .................................................................................................. S-1 S.5.d.i: Enforcement Response Plan............................................................................................................................... S-1 S.5.d.ii: Enforcement Tracking ........................................................................................................................................ S-1 S.5.d.iii: Recidivism Reduction ......................................................................................................................................... S-1 S.5.e: Training Report....................................................................................................................................................... S-1 Table of Contents for Supporting Materials ................................................................................................................... TOC-1
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Executive Summary of City of Salinas Year 4 Annual Report Summary The City of Salinas NPDES Permit Compliance Program has undergone major changes in approach, staffing and funding over the past Permit year leading to improved Permit compliance in the near term while addressing previous audit deficiencies and setting the stage for complete compliance in year 5. These changes in the City were complemented by changes in Central Coast Water Board (CCWB) staffing and approach to the mutual benefit of the Permit program. The cooperation between the City and CCWB staff has contributed to a better understanding of compliance requirements in a highly technical NPDES Permit. The City greatly appreciates current CCWB staff providing Permit interpretations and compliance requirement guidance to City. In order to provide transparency in the preparation of this Annual Report and to guide the City’s Permit Compliance Program going forward, the City performed a comprehensive gap analysis of the stormwater program to date and Permit program compliance. That analysis is currently being utilized to facilitate the rebuilding of the stormwater program including, but not limited to, preparation of this Annual Report. There are some areas of permit compliance where the City has exceeded Permit requirements and some areas where the City needs to, and will be required to, improve its Permit compliance performance. Overall the City continues to show marked improvement from past years and will continue that effort in earnest until rated an “A” by Board staff.
City Changes Annual Report Format The format of the Annual Report has traditionally been a Storm Water Management Program tabular-based reporting format. This format has proved difficult in discerning the level of Permit compliance and contained voluminous information in the body of the report and the appendices. It has been replaced with a streamlined Permit Section reporting requirement-based format giving the information required with samples of supporting documentation in the appendices and an executive summary at the beginning. This approach should accomplish the following: vii
The Executive Summary provides a synopsis of the Annual Report contents for the casual observer, making it far easier to discern the City’s stormwater Permit compliance efforts. Reading the complete Annual Report and understanding the information contained therein by those more than casually interested public reviewers should be significantly improved. The Annual Report should be easier for Board staff to check for Permit compliance. By the City referencing the Permit Section reporting requirements, Board staff have a direct “apples to apples” comparison to the Permit requirements.
Funding Measure G is a 1 cent transaction and use tax for General Services for the City of Salinas. The tax became effective April 1, 2015 with funding available for budgeting beginning the 2016-2017 fiscal year and will expire in 15 years. Some Measure G funds have been used to improve pollutant source control during this Permit year including clean-ups of marginally housed (homeless) encampments. With the passage of Measure G, the City is now in a position to make strategic investments to restore services and make strategic investments into staff, public facilities and infrastructure. While not directly funding Permit compliance efforts in most cases, Measure G provides funding to departments like Police and Fire that would normally compete with funding for efforts for NPDES Permit compliance. This increased funding provides the City with much more flexibility in addressing Permit compliance issues and supporting the Permit compliance program. Staffing The Public Works Department reviewed the existing organization to determine a better way to address NPDES Permit compliance issues and accomplish stormwater permit compliance. A rebuilding process was initiated, which includes creation of the first new division in the Department of Public Works for as long as anyone can remember titled Water, Waste and Energy, to address the synergy between these three areas of endeavor. The term “water” is used to emphasize that water is “One Water” as the hydrologic cycle illustrates below. The City, in partnership with the Monterey Regional Water Pollution Control Agency (MRWPCA), is incorporating stormwater capture and reuse, which can be added to the diagram below for a more complete picture of the hydrologic cycle as applies to the City of Salinas and the watershed in general.
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The Public Works Department has also to date: Replaced retired Permit compliance staff in the Maintenance Division by advancing experienced Permit compliance personnel, added Permit compliance staff and is in the process of recruitment to add an environmental compliance inspector to reduce the demands on existing personnel. Added staff to the City’s Permit Center Engineering staff for project review/post-construction requirement compliance and to direct and monitor construction inspection efforts. Added an experienced NPDES Permit Compliance Manager which we are proud to announce is now a full time City of Salinas staff member. Moved the GIS program from the IT Department to Public Works to accelerate reforming our data collection/management and mapping efforts, hired 2 interns to assist in that effort and is currently in the process of hiring a GIS Technician and recruitment of a GIS Administrator to increase our band width and capabilities. Developed a list of outside consultants well versed in Permit compliance efforts to supplement staff as needed. Increased training efforts to improve the expertise of staff in performing Permit compliance duties and to improve consistency of Permit compliance efforts, especially by our construction inspection staff. A training matrix is currently being developed to identify all applicable staff and ensure staff receive required stormwater training Is exploring consolidation of construction inspection efforts (Public and Private) under one umbrella with a lead certified QSD inspector in charge. The re-organization and hiring process in the public sector is a much more complicated and time consuming lengthy process, as compared to the requirements for the private sector, especially when the diminishing pool of applicants with Permit compliance related expertise is considered. Creation of new divisions and adding new positions also requires City Council review and approval which normally takes place during the budget cycle each year. Changes do not happen overnight. ix
Overall Permit Compliance The City has exceeded Permit requirements in some cases: In Section L “Development Planning and Storm Water Retrofits” the City is required to have at least one of a required list of 5 candidate projects at 60% project design stage by the end of Permit year 5 (refer to Section L for details). The City exceeded Permit requirements by the following: o Completion of Skyway Boulevard Roundabout. This reduced impervious surfaces by 36,304 s.f. and reduced the peak flow rate from the 10-year 24-hour storm event by more than 50% from an area of at least 10,000 s.f. of impervious surface to qualify as a retrofit project;
Skyway/Alisal Intersection Before Project and At Completion with Roundabout/LID in Place o Completion of the El Dorado Park retrofit project this year. It currently is slated to begin construction in August 2016 and improvements retain 16,180 c.f. of runoff from the 10-year 24hour rainfall and can infiltrate 100% of the total 10-year 24-hour runoff from the project area; o The 66” Storm Drain Shunt Project a.k.a. Blanco Basin Project is under design (exceeds 60% complete design). The tributary drainage area to the project site is approximately 1673 acres and will divert low flow, first flush and up to the 90% storm flows that normally go to the Salinas River from Southwest Salinas. This will result in estimated annual trash load reductions of 10,004 lbs during the rainy season and the following yearly pollutant load reductions: Pollutant Ammonia as N, Unionized Ammonia as NH3 Chloride Chlorophyll a, water column Chlorpyrifos Diazinon Dissolved solids, Total Nitrate as N Orthophosphate as P Suspended Solids, Total
Average Concentration (lb/AF) 0.783
Flow AF/yr 725
Diverted Pollutant Load (lbs) 57
1.647 287.307 0.0432
725 725 725
1,194 208,298 31
0.0043 0.27 1,733 35.1 1.755 187.542
725 725 725 725 725 725
3 196 1,256,382 25,448 1,272 135,968
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o The Boronda Road Widening Project (slated to begin construction in 2017) is under design. This will incorporate LID retrofits applied to the existing half street and incorporate both median based and roadside based bioretention planters and/or bioswales for stormwater treatment and infiltration. The City is also exploring the use of a roundabout to reduce the required number of lanes from six to four which could reduce impervious pavement area by approximately 50% and will strive to incorporate “Complete Green Streets” design concepts. Besides the obvious water quality benefits, if installed, the roundabout would also reduce traffic congestion, vehicle queues, and idling vehicles which should also provide a significant air quality benefit. o Big Sur Land Trust (BSLT) on Carr Lake acquisition is currently under negotiations with the City. The BSLT is set to acquire 72.4 acres of the land area as an initial phase for the purpose of restoring it to historical use as a wetland and combining it with recreational/other uses. If realized, the project has the potential, once low lying land is fully under the City’s control, to treat stormwater from approximately 100 square miles of upstream tributary area which eventually winds up in the Reclamation Ditch and the Monterey Bay Marine Sanctuary. This is a long term project that could hold tremendous water quality benefits on a watershed scale. This is only the first phase of many required but the progress being made is significant.
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Stormwater related improvement/retrofit projects not required by Permit but being designed as part of the Pure Water Monterey projects and hopefully funded by Prop. 1 implementation grants ($10M applied for) include: o The Reclamation Ditch Diversion Project which includes diverting a portion of the low flow and dry weather flow at Davis Road at the downstream end of the Ditch within City limits to the MRWPCA pump station and eventually for treatment and re-use. The area drained by the Reclamation Ditch at the diversion includes the Reclamation Ditch East and West, Gabilan and Natividad Creek, Carr Lake and Chavez Park Subwatersheds. The tributary area being diverted is 5,896 acres. The anticipated annual Trash Load Reduction is 31,732lbs. Referring to the pollutant load reduction table constituents listed above for the 66” shunt, the anticipated pollutant load reduction in order starting with ammonia as N, Unionized rounded to the nearest pound: 81; 1,698; 296,2025; 45; 4; 278; 1,786,739; 36,179; 1,798; 193,349. o The Blanco Drain Diversion which will divert agricultural drain tile runoff for treatment and reuse. The project is not located within the City limits and therefore is not part of the MS4. However, this collaborative effort with MRWPCA will significantly benefit the watershed by removing an identified source of pollutants which ultimately flow to the Monterey Bay Marine Sanctuary via the Salinas River. This illustrates the City’s intent to address water quality and supply issues increasingly on a watershed basis in collaboration with outside agencies. More information on Pure Water Monterey can be found at http://purewatermonterey.org/ .
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Pure Water Monterey Stormwater Diversion Diagram. Blanco Basin is located near the Pump Station The City has improved compliance with Permit requirements in some cases:
Section N Trash Load Reduction compliance efforts have netted the following trash reduction from the following sources: o Marginally Housed (Homeless) Encampment Clean-up: 165.2 tons (330,400 lbs.) o Public Trash Clean-up events: 3,500 lbs. o Public Watershed Clean-up Events: 1,300 lbs. o City Council Clean-up Events (large/bulky items-large quantities which often are dumped to save disposal fees): 946 tons (1,892,000 lbs.) o Street Sweeping: 1,200 cy o City On-Land Trash Clean-ups: 100 cy o General City Removal: 160 cy o Storm Drain Maintenance: Refer to AR Section E o Bioretention Basins: 800 lbs. o Filtration Systems: 240 lbs.
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Examples of Natividad Creek Marginally Housed Encampments and A Clean-Up by the City Please note one major source of trash and fecal coliform the City has identified in recent years is marginally housed (homeless) encampments. These are not specifically identified as pollutant sources in the Permit and most cities have been reluctant to address this thorny issue. A majority of the individual encampment sites are located within vegetated areas of local creeks and waterways. Please refer to the map of marginally housed encampments in Provision N. By identifying encampment sites and removing the resulting trash, the City is practicing source control on a major scale as evidenced by the tonnage of trash removed. The clean-ups not only included trash (including sharps) but also the removal of the encampments themselves. The encampments are not typically located close to sanitary facilities or the facilities are not close enough to be convenient for the encampments. Therefore, these encampments can be sources of fecal coliform; The City is currently required to comply with the Lower Salinas Valley Fecal Coliform TMDL.
Marginally Housed Encampment and Clean-Up in Chinatown Area The City also addressed a major concentrated marginally housed encampment in the City’s Chinatown area which accounted for a major source of trash and fecal coliform. Being proactive, until the courts xiv
could clear the City to remove the encampments, City crews plugged the storm drain outfalls for the area to protect the Reclamation Ditch. This foresight by the City proved fortunate since most marginally housed areas don’t have convenient access to sanitary facilities. City crews are currently cleaning the storm drains the area is tributary to which have been found to be full of septic effluent that was kept out of the Reclamation Ditch by the City’s actions. Please refer to Provision N for additional trash removal information. Please note that the City has worked with Marginally Housed Service providers in an attempt to find solutions to the homeless issue, not only because of the human factor, but also so that re-habitation and the attendant pollution is at least initially reduced. These include working with groups to find beds/shelter, supporting alternative housing projects and working with a local church group who will provide public sanitary facilities and maintain them to reduce the amount of waste found in the area. This is part of our source control effort. More information on what the City is doing to address this issue to reduce undesirable encampment by-products is available on the City web site at: http://www.ci.salinas.ca.us/services/pw/homelessness.cfm
Section Q “Watershed Characterization” mapping has been revised/updated to be in compliance with Permit requirements. This includes, but is not limited, to Existing and Future Urban Subwatersheds map noted as missing in the latest EPA audit. Please refer to Provision Q for the complete suite of maps.
Based on the City’s in-house permit program gap analysis, the City has improvements to make to its stormwater program implementation and compliance; the following are a few issues needing attention:
Data Collection: The data management system has been identified in past audits as needing improvement. The City is still struggling with data compilation as it transforms to a GIS-based data collection system that will work with other data collection systems currently in use on a broad basis (interdepartmentally) at the City. The difficulty is to create the interfaces between different computer programs currently in use. The City expects to have this issue resolved during Permit year 5 as it is making progress towards tablet-based field data collection process that allows interfacing with other facets of its current data collection system. Additionally, data management systems are being revised to ensure all permit required data is collected and can be reported as necessary. As previously mentioned, Public Works has assumed the GIS effort and hired/is hiring additional staff to expedite resolution of this issue.
Coordination with Other Agencies/Organizations: The City has had great coordination with/cooperation from some agencies as part of the Pure Water Monterey Projects and Prop. 1 Grant Program. However, in recent years the City’s coordination with outside agencies as part of Section M “Public Education and Public Involvement” and other Sections has diminished. The City has recently improved contacts with local entities such as Monterey Regional SW Group, County of Monterey, local Non-Governmental Organizations (NGOs) and will continue to do so in the coming years. It is the city’s goal to identify collaborative opportunities to share the financial/staffing demands of Permit compliance (i.e. PE/PO, inspection, sampling), identify/eliminate duplicative efforts and xv
identify economies of scale. The City is also working to develop a relationship with the local Ag community to address collaborative efforts for water quality compliance efforts. The City has also taken a leadership role in the Greater Monterey County IRWM by agreeing to Chair the IRWM Executive Committee for the purpose of producing the Stormwater Resource Plan (SWRP). The IRWM SWRP will be based on the Functional Equivalent SWRP being prepared by the City and MRWPCA as part of the grant requirements for the Prop. 1 grant program.
Greater Monterey County IRWM Boundary and Pure Water SWRP Boundary (red)
Training: The City has provided training in the past to address the Permit training requirements but has been lax in providing pre and post-training assessments. This has been addressed this past permit year and all training will now have pre and post-training assessments. An example of this can be found in the training discussions in Provision K. The City is also preparing a training matrix listing employees and their positions/departments, training their position requires and dates received. Additionally, the City is committed to creating a web/computer based training program which will require each staff member, for the Permit training they are targeted for, to take a pre-assessment, the training, and a postassessment. Each staff member will be required to complete the training yearly by date certain. Currently the City is addressing staff certification requirements to create a more robust highly trained construction inspection force. All construction inspectors without a current QSD certification have been cleared to take the CPESC certification exam, an underlying certification required prior to sitting for the xvi
QSD exam. Once CPESC certification has been obtained, the City will direct its inspectors to obtain the required QSD training. Until that time, either consultant QSDs will be used or our inspectors will be under the supervision of a QSD for Permit compliance. Suggested Changes to Permit Required to Improve Program Effectiveness: During year 5 of the current and final Permit year, the City will be working with Board staff to compile a new NPDES Permit for the City. Though not a complete list, as both the City and Board staff will determine what modifications are required, and in anticipation of the new Permit, the City respectfully requests consideration of the following Permit changes
Monitoring: The current monitoring program as required by the Permit does not provide adequate water quality information to determine City sources of pollutants. The frequency, constituents being sampled and sampling locations do not coincide and therefore cannot be compared in real time to determine any useful information. The only useful information we can determine, other than just presence of pollutants, is the pollutant load coming into the City is higher than leaving the City. Why? This cannot accurately be determined from the data obtained from the current monitoring program. The City respectfully suggests a different sampling program be developed which provides meaningful data for the City to assess and manage its MS4 stormwater program. The City respectfully suggests the program concentrate sampling/data acquisition in a few targeted subwatersheds at a time (rotating watershed basis) to help determine the processes in each watershed that either contribute to, or reduce pollutant loads. The sampling would be concentrated on the major watercourse and City outfalls/discharges in each subwatershed. Samples would be taken during flow from the upstream end of the watercourse and proceeding downstream at strategic locations like major outfalls, riparian areas, or similar in order to try and sample approximately the same slug of water as it proceeds downstream. In this manner the water quality can be tracked as it proceeds downstream, changes in water quality can be attributed to things like loads from outfalls and/or marginally housed encampments located between sampling locations. If loadings decrease, the City can analyze things like potential dilution from comparatively cleaner flows from outfalls, existence of riparian vegetation cleansing the flow or similar processes.
Several different entities (City, Ag Cooperative, CCAMP) perform duplicative sampling for different programs at the same locations. Some of the data is not shared due to fears data will be misused or misrepresented or used against the entity. The City respectfully suggests that all sampling programs be coordinated to reduce duplication of effort and provide cost efficiencies.
Post-Construction Requirements: The City’s Permit references the original POST-CONSTRUCTION STORMWATER MANAGEMENT REQUIREMENTS FOR DEVELOPMENT PROJECTS IN THE CENTRAL COAST REGION September 6, 2012 (PCRs). Revisions were made to this version on July 12th, 2013 which can be found at: http://www.waterboards.ca.gov/centralcoast/water_issues/programs/stormwater/docs/lid/hydromod _lid_docs/2013_0032resolution_signed.pdf.
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There are some differences between both versions. Board staff in the earlier Permit years opined that the City could not utilize the updated version without bringing the entire Permit back to the Board for consideration. The City chose not to pursue this avenue. If the thrust of future permits is to move toward a consistent watershed based approach, then it would make sense to have the same PCRs apply to all agencies within the same watershed. The City respectively requests that it be allowed to use the same version of the PCRs that surrounding entities in the region use. The closer the requirements are for those entities in the same watershed, the more it facilitates information sharing, potential staff sharing (i.e. project review), reduced developer confusion, and increased collaborative outreach and education opportunities. Having one MS4 have stricter PCRs in an entire region that has different PCRs does not provide increased water quality in the watershed as any minimal benefit that may be accomplished by the City via the stricter requirements could potentially be negated by Ag activities.
Definition of Structural BMP: The current Permit requires the City to inspect all structural BMPs each year. Catch basins, storm drain pipes, concrete channels and similar City facilities have been lumped into the definition of structural BMP as it applies to BMP RAM assessment requirements. The actual definition of a structural BMP from Attachment B of the Permit is “Physical structures used to manage flow and reduce pollutants in stormwater”. Catch basins, storm drain pipes, concrete channels should not be considered structural BMPs even though they may “manage” flow in the sense they direct and carry flow to an end point. They do not provide a reduction in flow like bioretention, detention and retention facilities, nor do they provide a water quality improvement function such as a bioswales or bioretention basin. Additionally, these are not “Best Management Practices” by definition because they are infrastructure items not “practices”. The City does not think this was the intention of the Permit and respectfully requests traditional infrastructure not be included under the definition of structural BMP.
Conclusion The City of Salinas NPDES Permit Compliance Program has been continuously audited by the EPA, assisted by the Regional Board staff, since 2014. The City has made great strides in recent months to improve its Permit compliance. A dedicated and experienced NPDES Permit Compliance Manager has been hired, other staff has been added, the City’s efforts have been reorganized under a single division and funding for the Program increased. Program shortcomings have been identified through the City’s gap analysis and the City is working diligently to address all of the program implementation gaps identified. By the end of the current Permit year (Year 5), with the continued assistance and guidance of Board staff, the City intends to have the programs and procedures in place necessary to be fully Permit compliant. The City fully intends to become, and remain, a leader in Stormwater Management and Permit Compliance in Region 3.
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Provision E: Municipal Maintenance E.15.c – Reporting Requirements Since Year 2 E.15.c.i – Providing Curb Access for Street Sweepers During Years 1 and 2, the City performed car counts to determine areas where sweepers were unable to access the curbs. In Year 3, the City began working with RouteSmart Technologies to restructure the street sweeping routes to make them more efficient and, in tandem with parking enforcement, increase the amount of curb miles swept. A lot of time went into the evaluation of possible street sweeping routes, pairing potential street sweeping routes with manpower and sweeper availability, and the development of a parking enforcement and signage program. A parking enforcement company was contracted in Year 4 to assist with the final development of the street sweeping/parking signage enforcement program. The areas with the highest car counts from data in Years 1 and 2 have been incorporated into the street sweeping route maps currently being proposed. City staff are presenting City Council in the fall with a pilot project to implement “No Parking on (whatever the street sweeping day is)” signage in some of the areas with the highest car counts. Data on the amount of debris removed in these areas will be collected and compared with previous years’ data to determine the increase in pollutant removal from the new increase in curb miles swept. Street sweeping maps are located in Appendix E. The separate Industrial, Commercial, and Residential route maps are included as they depict the routes from which the debris was removed and tabulated. Additional maps included depict the areas where there are high car counts and the new proposed routes under the new RouteSmart program. E.15.c.iii – Maintenance of Structural BMPs E.15.c.iii.1, and 6 – City Owned Structural BMPs A summary of City-owned structural BMPs, as well as the 2015 BMP RAM assessment and a comparison with previous year’s results are included in Appendix E. There were two structural BMPs that scored less than “acceptable”, items #4 and #10 (see map in Appendix E). The existing vegetation at the bioswale at the Aquatic Center was in poor shape with no wetland or riparian vegetation due to extreme drought conditions. The grass swale at the Cesar Chavez Library had deteriorated; the swales were primarily bare earth with low vegetation, also due to extreme drought conditions. The City is currently evaluating whether to replant or to replace the structural BMP with another type more suitable for weather conditions. A rain event did occur after the inspection was performed. Landscape maintenance was performed in areas where vegetation was overgrown. The inspection results also indicated that the inline filters at the E. Laurel Drive location needed cleaning, which was performed a week later as part of the City’s annual maintenance program. Maintenance of Municipal Structural BMP Verification Structural BMPs designed to achieve a quantitative storm water management objective were maintained such that they continue to achieve the specifications they were designed to achieve. City owned and operated structural BMPs were inspected at least once each year. The City has determined that catch basins, open channels, and concrete surface drainage structures are not structural BMPs. They may be structural, but they are not Best Management Practices. They are infrastructure conveyances. They do not provide a water quality or volume management benefit. In fact, if anything, the open channels and conveyances probably pick up contaminants as the water passes through them. The volume of the water passing through does not change. The flow velocity may increase and the water quality decrease so these items of a City’s infrastructure E-1
are not really stormwater best management “practices”. They do manage flow but that is in the context of civil engineering infrastructure design and flood control. The City is developing an effective information management system to track all structural BMPs and surface drainage areas. A web based application with mapping and data collection for field use via Wi-Fi tablets will take the place of current excel data sheet. The City maintained records for maintenance of Structural Controls and surface water drainage channels in an excel spreadsheet for permit year 2015-2016. The data reflects the maintenance activities for each reporting period. Surface drainage systems are inspected and cleaned as required a minimum of once monthly. Structural BMPs have been successfully maintained by implementing a more aggressive schedule than the minimum requirement of the Permit. City owned structural BMP’s are inspected monthly. Privately owned structural BMP’s are inspected and cleaned annually as required by the order. A total of 2078.6 cubic yards of debris was removed from City surface drainage areas and City owned structural BMPs. (Appendix E) Sites that are considered Priority locations that will be inspected at least 3 times annually are: 1. 2. 3. 4. 5. 6.
Santa Rita Creek Natividad Creek Carr Lake/Laurel Basin Expo Ditch Treatment Plant 1 (storm pump station) Salinas River Outfall
Inspections/Maintenance of Privately Owned/Operated Structural BMPs: A summary of the inspections of privately owned/operated structural BMPs within the City is included in Appendix E. The following is a list of under construction/newly constructed projects with structural BMPs: 1. 111 Salinas has not been finaled, but has constructed a permeable parking lot; 2. 1300 Rider Ave (Frank Paul School) is constructing bioswales construction ongoing; 3. 1100 Rogge Rd (High School #5) under construction; 4. 880 Northridge (commercial), recently received Temp. Occupancy, has a bioswale; 5. 100 Northridge (JCPenney) is under construction and has a number of bioswales; 6. 851 Work St (industrial) is under construction and has several bioretention areas; 7. 921 Del Monte Ave (residential duplex) is under construction and has bioswales and porous pavement; 8. 1410 N Main (Credit Union) recently received Temp. Occupancy, has bioretention area; 9. 1110 Montana St (private residence) finaled in April, installed permeable pavers for driveway; 10. 1320 Second St (private residence) finaled in January, installed permeable pavers for driveway; 11. 809 Kilbreth Ave (private residence) has an expired building permit, was permitted to install a permeable paver driveway. E.15.c.iii.2 – Total Number of Structural BMPs The total number of structural BMPs installed to date to comply with the requirements for Priority Development is 85. They are inspected bi-annually. These structural BMPs were not assessed via the BMP RAM tool thereby not receiving a BMP RAM score.
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E.15.c.iii.3 – Structural BMP Inspections All structural BMPs are inspected each year; however, the private structural BMPs were not assessed via the BMP RAM tool in Years 1 – 4. Their assessment will begin in Year 5 with the development of the new Central Coast BMP RAM tool. As noted above, two City owned/operated structural BMPs received a BMP RAM score of less than “acceptable”. This year the City has joined in the Central Coast Joint Effort and has contracted with 2ndNature to integrate Salinas’s urban land use and drainage maps into the BMP RAM tool they are developing for the Central Coast municipalities. This will allow a more regional and watershed-based approach to determination of watershed pollutant load reductions via structural BMPs implemented and use of the TELR tool (Total Estimated Load Reduction). This tool will now be the tool used to assess the City’s as well as any privately owned/operated structural BMPs. E.15.c.iii.5 – Information Management System Our information management system (IMS) for tracking and reporting of all information required in this section is currently under development. Field data collection programs have been put in place for IDDE, catch basin inspection/cleaning, and street sweeping operations. As noted above, a database is being developed through 2ndNature and our GIS dept. for utilization of the BMP RAM and TELR tools. E.15.c.iii.7 and 8 – O&M BMPs The City’s O&M BMPs have been quite effective at preventing pollutants from entering the City’s storm drain system. These BMPs will be reassessed in Year 5 to determine if any modifications need to be made. There were none made in Year 4. There are no new O&M BMPs implemented. E.15.c.iv – Flood Management Projects. There were no flood management projects in the planning stage during year 4. E.15.c.v – Salinas River Outfall Pollutant Reduction Plan. A summary of the progress of the Salinas River Outfall Pollutant Reduction Plan is given below. In accordance with Section E.12 of the City’s stormwater discharge permit (Order No. R3-2012-0005, NPDES Permit No. CA0049981) the City prepared a Pollutant Load Reduction Plan (June 2013). This Plan describes the City’s proposed methods of reducing pollutant loads being discharged from the City’s Salinas River stormwater outfall. The Plan identified (1) Urban Runoff and (2) Groundwater Infiltration and Potential Agricultural Impacts as the potential sources of pollutants in the stormwater discharge. The specific pollutant types that were assessed for each of these two sources were nutrients, salts, pathogen indicators, and pesticides. The Plan concluded that Urban Runoff was only likely to be a significant source of the nutrient orthophosphate and pathogen indicators, and that Groundwater Infiltration was only likely to be a significant source of the nutrient nitrate and salts. The Plan was not able to identify with certainty any likely significant source(s) of pesticides due to a lack of available monitoring data for pesticides. More monitoring of pesticides was recommended in order to be able to make this determination. Based upon the identified pollutant sources, and the beneficial use impairments that have been documented in the Salinas River downstream of the stormwater outfall discharge, the Plan prioritized sources as follows: 1. 2. 3. 4. 5.
Pathogen indicators in Urban Runoff Nitrate in Groundwater Infiltration Orthophosphate in Urban Runoff Salts in Groundwater Infiltration Pesticides in Urban Runoff and/or Groundwater Infiltration E-3
The Plan developed an effectiveness ranking system and evaluated treatment control BMPs, site-design BMPs, source control BMPs, and non-stormwater BMPs for each of the five prioritized sources of pollutants to determine the BMPs having the greatest potential to measurably reduce pollutant loads in the outfall discharge. These BMPs were then prioritized based on their feasibility of implementation, cost, and whether they addressed a potential major pollutant source. The selection of which BMPs to implement was to be determined based on other TMDL and MS4 Permit requirements, with an emphasis being placed on enhancing BMPs that were already in place in the City. A plan was developed for monitoring the discharge of the City’s Salinas River stormwater outfall. That plan listed the constituents to be monitored and the monitoring frequency. The constituents consisted of General Parameters (which included salts as TDS), Nutrients, Bacteria, Metals, and Pesticides. Monitoring was to consist of two dry-weather events (July and September) and three wet-weather events, with monitoring to commence with the September 2013 dry-weather sampling event. Samples were to be taken at two locations: (1) the Salinas River stormwater pump station (309-U19) and (2) at the point of discharge of the Salinas River stormwater outfall (309-SDR). These paired sets of samples were recommended in order to assess the impact of groundwater infiltration into the pipeline section between the pump station and the point of discharge. This section of pipeline underlies agricultural fields, which were considered to be a potential source of pollutants in groundwater infiltrating into this section of pipeline. The Plan proposed to assess the effectiveness of the pollutant reduction actions based on pollutant load reductions in the discharge from the Salinas River stormwater outfall. The Plan also proposed to establish preliminary pollutant reduction goals to assist in the effectiveness evaluation, after completion of the first year of paired monitoring of the water quality at the Salinas River stormwater pump station and the Salinas River stormwater outfall. The Implementation Plan included an Implementation Schedule broken down into the following categories: 1. Outfall monitoring (ongoing annually) 2. Identification of actions aimed at pesticide reductions (following 3 years of data collection under the outfall monitoring program) 3. Implementation of actions aimed at pollutant reductions in urban runoff (varying implementation schedules proposed depending on the individual actions to be taken) 4. Implementation of actions aimed at pollutant reductions from agricultural runoff (implementation schedule to be determined based on the results of effectiveness assessments) A summary of the findings in the monitoring report is provided as follows: In the prior Permit term (Years 1, 2, and 3) turbidity only exceeded the WQO of 126 NTU at the pump station and the outfall during wet weather events, but the dry weather events never exceeded the WQO. In the current Permit term (Year 4) turbidity only exceeded the WQO at the pump station during wet weather events. During the prior and current permit terms nitrate was below the WQO of 10 mg/L at the pump station during all events; however, nitrate levels were above the WQO at the Salinas River outfall. During the prior and current permit terms orthophosphate exceeded the WQO of 0.12 mg/L at both the pump station and the outfall.
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Fecal coliform exceeded the WQO of 400 MPN/100 ml in 3 out of 8 events at the Pump Station and 7 out of 11 events at the outfall. The largest exceedances occurred on November 3, 2015, a storm event of 1.22 inches. No consistent trends were observed from wet to dry events for zinc or copper. Copper and zinc are not appearing to be a water quality issue for Salinas.
The City is still pursuing Prop. 1 funding to construct the Flow Diversion Project. The actions required by the Permit (which involve illicit connection removal, sanitary sewer overflow repair, catch basin/sump clean out, landscaping/fertilizer education for homeowners, and wash water management) were all ongoing during the current Permit Year. Other actions involving the implementation of permeable pavers, green roofs, porous pavement, detention and infiltration basins and trenches are considered during project plan review for LID requirements. The City is always looking for opportunities for regional collaboration regarding landscaping irrigation and fertilizer use education for homeowners. Constructed wetlands and riparian restoration are a priority for implementation when the Carr Lake parcel, currently in final purchasing negotiations by the Big Sur Land Trust, is deeded over to the City. The 2015-2016 Stormwater Monitoring Program Report, included in Appendix M, indicates that in the current Permit Year (Year 4) the levels of orthophosphate and fecal coliform were considerably higher at the outfall than in the previous Permit Year (Year 3), and levels of this constituent had been steadily trending upward over the previous two Permit Years. The levels of nitrogen, copper, and zinc were lower than in the previous Permit Year. There appears to be a steady downward trend in the levels of copper and zinc, but the nitrogen level spiked upward in Year 3 then declined in Year 5, so there was no steady downward trend in this constituent. The City has collected data regarding homeless encampments throughout the City, homeless encampments being a potential source of fecal coliform in the storm drain system. A map indicating all homeless encampment cleanups for 2015-2016 is located in Appendix E. A potential reason for the increase in fecal coliform throughout the last 3 permit years may be due to the increase in size of homeless encampments throughout the City. For example, a cleanup was performed in 2012 which resulted in 16 dump truck loads of trash for disposal. Clean up of that same area in 2016 resulted in 71 dump trucks of trash for disposal. The homeless encampment had increased in size by a factor of 4.5. Humans, however, are not the only source of fecal coliform pollution. In Year 5, the City will perform some PCR testing at the urban catchment outfalls (if flow) and the Salinas pump station and Salinas River Outfall to determine if the fecal coliform is related to humans or potentially caused by manure placed on the Ag fields. There are no concentrated animal feedlots or ranches around the City of Salinas that would potentially be another source of fecal coliform. E.15.e.i– Municipal Inventory A municipal inventory of the following was developed in Year 2: Salinas catch basins High Priority Private Development areas Structural BMPs owned or operated by the City of Salinas Facilities, maintenance operations, and events The municipal inventory was reviewed and updated in Year 4 to reflect current conditions (name changes, new facilities or modifications to existing facilities, provide additional information). The following changes were made: 1. Reformatted Municipal Facility Inventory Table to categorize facilities by type, making future updates, including additions or deletions, easier to document. New categories are: Municipal Facilities (MF) (Various General Public Buildings) E-5
Fire Stations (MF-FS) Golf Courses (MF-GC) Parks (MF-P) Parking Lots (MF-PL) Waste Water Facilities (MF-WW)
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Added a key for the Source Control BMP’s used for facility, event and operations assessments as adopted from the CASQA Municipal BMP Handbook
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Updated Inventory and Tables to include: additions, deletions, and to correct omissions and errors. Added assessment of Fire Station # 3, (MF-FS-03) Added assessment of Twin Creeks Golf Course, (MF-GC-02) Updated parking lot inventory PL-11 removed (address not valid, does not exist) PL-12 address correction Added PL-15, 18, 19, 20 to assessment Deleted Airport Parking Lot from list as the Airport is covered under their own NPDES permit Relocated the Hebron Heights Community Center (MF-16) & Breadbox Recreation Center (MF-15) assessments from the Park section to the Municipal Facility category to maintain consistency with the facility assessment types in each category Added separate assessment for Police Dept./ Public Safety Building (MF-12) Added assessment for Salinas Animal Shelter, (MF-13) Added Listing in Municipal Facility Inventory table for the Salinas Firehouse Recreation Center (MF14) Updated the inventory assessment for Sherwood Park (MF-P-34) to include the New Aquatic Center, associated parking lot, landscaping, and structural BMP’s. Added assessment for Monte Bella Park (MF-P-25)
4. Updated the parking lot inventory to provide consistency with the Municipal Inventory Table and Assessments. Deleted Airport parking lot as it is under a separate permit Deleted the City Yard, Animal Shelter, and Library parking lots from the table as they are included as part of each site’s Municipal Inventory assessment and not listed separately in the Table or Inventory, as are the various City Park parking lots Removed PL-11; not an existing parking lot Added PL-15,18,19,20 as new additions to the Inventory under MF-PL-04 Corrected address for PL-12 5. City-owned or operated structural BMPs were added to the inventory 6. Inventory of MS4 catch basins updated A listing of all City catch basins, municipal structural BMPs, municipal facilities, maintenance operations, and events is located in Appendix E. E.15.e.ii – Minimum BMPs for Municipal Facilities, Maintenance Operations and Events BMPs applicable to municipal facilities, maintenance operations and events in the municipal inventory are included in supporting documentation in Appendix E. These BMPs have been selected from the CASQA E-6
Municipal BMP handbook and are available to staff for personnel training or as a reference document to ensure BMPs are properly implemented. E.15.e.iii and iv – Updates Made to High Priority Municipal Facility and Event SWPPPs as Well as Maintenance Operations SOPs Pollutant Discharge Potential Assessment The pollutant discharge potential for municipal maintenance operations is included in Appendix E. An assessment of pollutant discharge potential for each municipal facility and outdoor public events was not performed. For events, a weekly Special Events planning meeting is held to discuss storm water program requirements with each special event applicant. The handout of requirements for public events is provided in the supporting documentation in Appendix E; this is given to each event applicant and returned with their signature. Each applicant is required to provide a site map for their event that includes the locations of all catch basins in and in the immediate vicinity of the event area, locations of any portable restrooms or hand wash stations, locations of their trash management/recycling areas, locations of any outdoor food vendor stations, and locations of any animal activities or face painting activities. From the site maps submitted, applicants are provided a summary of required storm water BMPs for implementation during the event. The City provides catch basin covers to help protect the catch basins/inlets from trash generated from the event. High Priority Municipal Facilities, Maintenance Operations, and Events A listing of high priority facilities, maintenance operations, and events were submitted in the Year 2 Annual Report. There are 72 municipal facilities (each sanitary sewer lift station counted individually) of which 13 are high priority; 10 maintenance operations of which six are high priority, and four “types” of special events, each designated as high priority. Vehicle/Equipment Maintenance and Repair (MOP 5) and Landscape Maintenance (MOP 9) were added as high priority in Year 4 due to the types of chemicals used in the operations and the pollutants that are generated from these maintenance activities. The high priority municipal facilities, maintenance operations, and events are as follows: High Priority Facilities
City of Salinas Corporation Yard Sanitary Sewer Lift Stations - Lake Street - Carpenter Hall - Mille Lake - Santa Rita - Vista Nueva - Las Casistas - Airport – La Guardia - De La Torre - Harkins Road - Spicer - TP2 - Airport Industrial Waste
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High Priority Maintenance Operations
Roads, Street, and Highways Operations and Maintenance – MOP 1 Building and Grounds Maintenance and Repair – MOP 2 Parking Lot, Plaza, Sidewalk Maintenance and Cleaning – MOP 3 Vehicle/Equipment Maintenance and Repair – MOP 5 Sewer Utility Operation and Maintenance – MOP 7 Landscape Maintenance – MOP 9
High Priority Events
Parades/Processions/Walks/Runs Festivals/Carnivals Farmer’s Markets Major Events (Airshow, Rodeo)
The inventory of municipal facilities, maintenance operations, and special events will be reviewed and revised in Year 5; determination of the “high priority” facilities, operations, and events will be re-evaluated. Proximity to a 303(d) waterbody will be added as a criterion for High Priority designation in Year 5. High Priority Municipal Facilities, Maintenance Operations, and Events SWPPPs Stormwater Pollution Prevention Plans (SWPPPs) were developed in Year 2 for the City of Salinas Corporation Yard, the Sanitary Sewer Lift Stations/Sanitary Sewer Collection System, and for events in general. The SWPPP for the Sanitary Sewer Lift Stations and Sanitary Sewer Collection System was included in the Year 2 (2013-2014) Annual Report, Volume 2. Copies of the other two SWPPPs are located in the supporting documentation in Appendix E. All three SWPPPs were developed in Year 2; however, they were not reviewed or updated on an annual basis. Inspection checklists and schedules were not included in the SWPPPs. In Year 5, these SWPPPs will be revised to include the required inspection checklists, inspection schedules for weekly observations, quarterly inspections, and visual observations of stormwater discharges. High Priority Maintenance Operations SOPs Standard operating procedures (SOPs) for sanitary sewer system operations and maintenance are included in the 2014 Sanitary Sewer Management Plan located on the City’s website: http://www.ci.salinas.ca.us/services/pw/pdf/PublicReview_SanitarySewerManagementPlanUpdate2014.pdf This plan does address storm water discharges to sanitary sewer, illegal connections, sanitary sewer/stormwater diversions, and inspections of storm water conveyance systems. SOPs for other maintenance operations will be developed in Year 5 following the review of all maintenance operations for High Priority status. E.15.e.v – Description of BMPs to Reduce Tracking of Dirt in the Streets The City has not to date developed any BMPs to reduce tracking of dirt in the streets. In Year 5, the City will perform outreach to the surrounding Ag community, Cal Trans, and the County to inform them of our stormwater permit requirements prevent and/or reduce the tracking of dirt onto City streets. The City’s practice to date has been to send out street sweepers to address any issues around dirt that has been tracked into the streets, mainly from surrounding Ag. E.15.e.vi – Summary of Weekly Visual Observations Currently there are three areas that perform daily/weekly visual observations/inspections – parks, parking lots, and sewer lift stations. Examples of completed inspection forms are included in Appendix E. Weekly visual E-8
observations have not occurred for all municipal facilities and operations due to manpower constraints. The City determined that parking lots, parks, and sewer lift stations have the greatest probability of discharging pollutants to the City’s MS4; these facilities were inspected as required. Park Division Summary of Weekly Observations:
Park maintenance staff duties have always included daily observation and inspection, (not just weekly) of all city park facilities, including park landscape and hardscape areas, parking lots and medians.
During the current NPDES permit period, additional emphasis has been placed on these tasks as they relate to maintaining or improving storm water quality through the implementation and training on the BMP’s developed in the SWMP, and from the CASQA Manual as listed in Table E 5,6,7, and 8 of the 2012-2013 SWMP.
Our current documentation of these tasks includes a daily park route assignment inspection form developed originally for playground safety inspections, but which also includes areas for reporting and documenting existing or resolved park problems, hazards or conditions. o In addition, the park supervisor and the manager regularly check park areas for problems including excessive litter, garbage, irrigation problems, homeless encampments, contractor operations, and other issues that affect storm water quality, as well as for structural and safety concerns. The results of these inspections are currently not documented except where follow up was required by Emergency Services or Wastewater under Hazardous Material, Illicit Discharge, or Homeless Encampment policies, or if Contractors were needed and purchase orders were generated. o The park route checklists include all city parks, libraries, and major thoroughfares on a daily basis, exceeding the weekly observations requirement of the permit. o These checklists ensure that the areas are assigned daily and that the employees will observe, report, and/or correct major problems, including potential storm water related issues, as well as make every effort to remove daily litter to the maximum extent practicable with current staffing levels. Those levels and seven-day work weeks for park operations results in many minimal staffing days of 4-5 employees for four days of the week and a maximum of 10 employees for 3 days of the week (two employees on holidays), which is well below past staffing levels of 40 + employees available for park route duties.
To improve effectiveness and assessment of this BMP the dept. holds training tailgate meetings directly related to parking lot maintenance, and incorporate a specific parking lot inspection component to our daily route checklist forms. We continue to stress the importance of preventing pollutants from entering storm water systems and ensuring that staff make specific efforts to maximize their effectiveness by addressing obvious major sources of pollution, such as illicit dumping of vehicle parts and fluids, large visible trash, other hazardous materials, and litter and debris cleanup as time and available manpower allows. They will also prioritize areas directly flowing to storm drains to remove debris.
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Contract landscape operators are used to supplement park staff in litter and garbage removal in many areas, including medians and parks such as: o Alisal and Market St., Davis Road, Blanco Road, and Abbot St landscape and median areas on a weekly basis, park staff also monitor and drive these areas daily to control litter and inspect irrigation systems for problems. o Monte Bella Park (daily litter control) & the Aquatic Center and associated parking lot and landscaping at Sherwood Park (daily litter control). o Landscape Contractors attend an annual meeting to be informed of the requirements of the permit, including pesticide application use and scheduling, litter and garbage control as contracted, and protection of storm drains during landscape operations to prevent storm water contamination.
Individual volunteers and groups are also utilized to assist in litter and garbage removal in parks, parking lots and surface drainage and structural BMP areas in various parks when available. o Salinas Social Vocational Services provide additional litter removal once per week in the park and parking lots at Cesar Chavez & Natividad Creek.
Any problems discovered by park employees or contractors as a result of the daily park routes, supervisor or manger observations, contractor operations, calls from other agencies or the public regarding litter, irrigation problems, illegal dumping, homeless encampments, or any other issues in park facilities or medians affecting storm water are evaluated and assigned for follow up as they are discovered or reported. o Park staff pick up litter to the MEP during daily assigned park routes, empty garbage cans as needed on a daily basis, and remove any illegally dumped materials in parks or parking lots as discovered, if it is within their capability. o If they cannot handle the issue themselves, they report it to their supervisor for follow up action: i.e.: Hazardous materials on streets or in parks and parking lots are reported to Wastewater or Emergency Services as the conditions and Hazardous Waste Training requires. Illegal dumping is picked up by park staff as possible, reported to Street Division, or contracted out if required. Homeless Encampments in park facilities or medians are reported for follow through the City Homeless Encampment Policy, which involves proper notification to the individuals, with follow up removal of any debris or garbage left behind upon their departure. Parking Lot Inspections: Daily inspections occur for the following City-owned parking lots. All issues found are addressed immediately. Due to the fact that these visual observations were not documented in Year 4, as overall assessment of recurring issues and how these issues were resolved cannot be performed. These are now documented beginning in Year 5.
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Lot # 1 2 3 5 8 10 12 15 16 17 18 19 20 ITC*
Address 219 Salinas Ct 345 Salinas St 222 Monterey St 300 Monterey St 210 Salinas St 128 Salinas St 112 Lincoln Ave 321 Church St 30 Lincoln Ave 101 West Alisal St 60 West Market St 323 California St 342 Front St 3 Station Place
*Intermodal Transit Center (Train Station Lot) Downtown Parking Garages (Structures) Salinas St Garage
320 Salinas St
Monterey St Garage
20 East Market St
Sewer Lift Station Weekly Inspections: The sewer lift stations were designated as High Priority. These stations are inspected at least weekly. Samples of inspection reports are in Appendix E. It should be noted that these inspection forms used are not included in the SWPPP for the Sewer Lift Stations. E.15.e.vii – Quarterly and Annual Inspections Quarterly inspections for High Priority facilities, operations, and events has not been completely implemented. Currently, the sewer lift stations, designated as high priority, are inspection at least weekly. And the Corporation Yard is inspected annually. Parking lots and parks, not designated as high priority, are being inspected daily. The entire inspection program for facilities, operations and events needs to be revised to meet permit conditions/frequencies. The only high priority operation being inspected quarterly is Vehicle Equipment Maintenance and Repair. No events were inspected in Year 4. An inspection form for Events was developed in Year 3 (2014-2015) and included in Volume 1 of the Year 3 Annual Report; however, an inspection program for events had not been implemented in Year 4. The Events inspection form has not been incorporated into the Special Events SWPPP document. Only the Corporation Yard Annual Inspection had an inspection rating. The inspection rating given was a “4”. The inspection is performed by our Environmental Compliance Officer who also performs our commercial/industrial inspections. The rating system being used in our Commercial/Industrial program was not IAW Appendix G; the rating system was corrected and all commercial and industrial inspections now follow the correct inspection rating system.
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E.15.e.viii – Summary of Municipal Facilities, Operations, and Events Assessments The list of High Priority municipal facilities, operations, and events and their assessments for pollutant discharge potential are included in Appendix E. Those facilities, operations and events that had the highest potential for pollutant discharge to the MS4 system we designated as High Priority. The proximity of a facility or event to a 303(d) waterbody was also used in the High Priority determination. These will be reassessed in Year 5. E.15.e.ix – Catch Basin Cleaning and Inspection The City continues to use the modified cleaning program including measuring and recording sediment and debris depth in compliance with the implementation plan. The depth of sediment and debris detected in each catch basin is recorded during each inspection and prioritized on the basis of data collected. A summary of debris removed from catch basins in Years 1 – 4 is located in Appendix E. Program modifications were made in Year 3 to clean all catch basins with a debris depth of 2 inches or greater to increase the number of catch basins cleaned and to be more protective of water quality objectives. The data shows that utilizing the 2” threshold actually resulted in a reduced amount of debris removed as there were less catch basins that met the threshold level. The catch basins that met the 2” threshold level in Year 3 were considered High Priority for cleaning in Year 4 in addition to the catch basins in the new zones being cleaned. Year 4 data will be used to modify the cleaning schedule for permit year 5. The cleaning schedule for further years will be based on similar criteria—debris depth of over 2 inches. Modifications to the catch basin inspection process were made in Year 3. The total number of catch basins in the City were divided up into zones in the City. This allowed for approximately the same number of catch basins to be inspected each year (20%/year for 5 years). Zones 18, 6, and 5 were inspected and cleaned in Year 3; Zones 1 – 4 were inspected and cleaned in Year 4. Priority for inspections in permit year 4 were based on addressing inspection zones with the most debris collected in permit year 3 (2014-2015), with all catch basins in the City’s inventory to be inspected over a 5-year cycle per permit requirements. In Zones 1, 2, 3, and 4 there were 618 catch basins requiring inspection. There were 581 high priority catch basins for inspection from previous years’ inspections (in various zones). Total catch basins inspected were 1199 with 439 catch basins cleaned. Catch basins that contained trash of any amount were cleaned in addition to catch basins that met or exceeded the 2 inch cleaning threshold. Catch basins with a debris level of 2 inches or greater became high priority catch basins for inspection in Year 5 in addition to the Zones scheduled to be inspected and cleaned that year. Year 5 catch basin cleaning is being modified to incorporate 300 foot buffers along all 303d waterbodies within the City. These additional catch basin inlets have been deemed as high priority for inspection and cleaning. There are 241 high priority catch basin inlets within these buffer zones. All data will be reviewed for further evaluation of the catch basin cleaning and inspection program in subsequent years. The criteria used for cleaning catch basins in permit year 4 was occlusion of a catch basin equal to or greater than 2 inches of sediment, trash or debris. A summary of catch basin cleaning and debris totals as well as a comparison with Years 1 - 3 in included in Appendix E. E.15.e.x – Catch Basin Prioritization The assessment of catch basin prioritization is located in the tables in Appendix E. In Year 3 there were 66 high priority catch basins and in Year 4 the number increased to 108. Zone 1 had an increase of 9 catch basins, Zone 2 remained the same, Zone 3 had an increase of 18 catch basins, Zone 4 had an increase of 15 catch basins. An overall increase in 42 high priority catch basins. A map of these zones is included in Appendix E. E-12
E.15.e.xi (see E.15.c.i previously reported) E.15.f.i – MS4 O&M The information management systems are currently under development. All data collected in the past was collected on various spreadsheets developed by individuals within various depts. The City is moving towards a data management system where data collection applications are being developed for electronic collection of field data. This data is then transferred to the City’s database for utilization in GIS mapping and consistent spreadsheet reporting. Electronic forms for all permit-required data collection/reporting are being developed so hard copy, populated reports can be generated. E.15.f.ii – Street Sweeping 1. The number of route miles swept and the total volume of debris collected for each sweeping event for each individual route is included in the street sweeping data in Appendix E. There are some weekly residential and industrial routes; however, the way the data was being collected, it could only be parsed out according to type of route and if it was a ‘Payday” or “Non-Payday” route. The entire street sweeping program is currently under revision. New street sweeping routes have been developed to increase sweeping efficiency, potentially increase curb miles swept in conjunction with the new “No Parking on street sweeping days” signage program, and ensure efficient manpower usage. The new routes have been designed to maintain a weekly sweeping schedule for those routes initially required to be swept weekly per the permit.
The total volume of debris collected for all sweeping events per individual route is as follows: Residential: Commercial: Industrial:
Payday – 842 cu yds Payday – 1081 cu yds Payday – 1115 cu yds
Non-Payday – 879 cu yds Non-Payday – 998 cu yds Non-Payday – 943 cu yds
The total volume of debris collected for all sweeping events for all routes combined is 5858 cu yds. A comparison of street sweeping debris removed in Years 1 -4 is included in Appendix E. Data shows there was a downward trend in debris removed from Year 1 to Year 4 in all three categories of sweeping routes; residential, commercial and industrial. Since this is the first year actual trending of data has occurred, the City is working to determine the reason for this reduction in debris collected. Since the information management system is not completely developed yet, the number of miles swept for each type of route could not be determined for each of these sweeping route categories at the time of this report. The street sweeping routes did not change from Year 1 to Year 4. Due to the upcoming implementation of “No Parking” signage for street sweeping days, an increase in the amount of curb miles swept may be achieved. 2. All routes were swept IAW the required schedule to the best of our ability. As usual, there were various maintenance issues that required alternate sweepers, when available, to provide coverage for the routes normally swept by the broken sweeper. And there were staff absences that resulted in reduced sweeping at times. Normal issues for maintenance activities. 3. Parking Lots and Parking garages are visually inspected daily. Daily inspections are not documented. The daily inspection performed involves checking for trash and debris, both solid and liquid. Anything found is cleaned up at that time. Any storm drains within the lot and the surrounding area downstream are inspected for any trash and debris, both solid and liquid. Any necessary cleaning is performed by Public Works Waste E-13
Water staff that day. Any illicit discharges are report and addressed. Documented weekly inspections are performed on the last day of the week, as early in the morning as possible, when fewer cars are present. Surface lots are swept weekly by a private contractor with a vacuum sweeper. The amount of debris and trash removed by sweeping is not currently documented. Parking Garages are not swept with a vacuum sweeper due to low clearance ceilings. Parking garages are inspected daily as described above by surface lot daily inspections. Weekly documented inspections are performed at the time the surface lots are done. Any needed cleaning is performed at the 20 East Market Street Garage by on site staff. The 320 Salinas Street Garage is cleaned by a private contractor once a week or as needed by the daily inspections. The Transit Center lot (ITC or Intermodal Transit Center) is cleaned once a week by the same contractor who services 320 Salinas Street Garage. 4.
Residential: Commercial: Industrial:
Avg: 0.32 cu yd/route mi swept Avg: 0.38 cu yds/route mi swept Avg: 0.38 cu yds/route mi swept
5. The City used to perform car counts to determine what percentage of the sweeping route was not accessible. In Year 2, this was determined to be a safety issue (distraction of the driver) so this was discontinued. From early data, the City has identified areas with high car to curb ratios; however, the miles swept in these areas can vary weekly. Once the new “No Parking during sweeping days” signage program is implemented, a better estimate of actual curb miles swept can be accomplished. The first pilot project for this program is scheduled for roll-out in the fall following approval from City Council. 6. The City has Elgin Eagle Mechanical Broom sweepers. These were purchased in 2002, 2007, and 2013. A new Elgin sweeper is being purchased in 2016 to replace the unit from 2002. The City also has two vacuum-type sweepers (Johnson 770 Cyclone) that used to be used to pick up fine particulate matter in residential areas; however, these sweepers are unreliable. Parts are no longer available for the 770 Cyclone). One sweeper is used to replacement parts for the other sweeper. The City is currently awaiting one sweeper and will purchase another one this coming fiscal year (July 1 2017). Mechanical sweepers are used for every route. The City has 3 sweeper operators that alternate doing the high density hand sweeping in the dead ends (areas infeasible for street sweeping). The sweeper operators indicate that 2-3 cu yds of materials is removed from hand sweeping. However, this is not documented and has not been accounted for in the debris removal totals in Appendix E. The information management system for the collection of street sweeping data is being developed/revised in Year 5. 7. The City maintains sweeper spec sheets in the Maintenance Dept. 8. The City contracts a sweeper to clean dirt from the roads in the Monte Vella subdivision. The dirt is due to agriculture operations in the development. The debris removed is not documented and therefore is not included in the sweeping data in Appendix E. 9. Dead ends of streets in residential areas are hand swept by sweeper operators. Parking garages are also hand swept due to the low clearances. The amount of debris removed is not documented. 10. See item 6. E-14
E.15.f.iii – Contractor Oversight Parks Division
The Park and Urban Forestry Division utilizes contractors for landscape maintenance and repair operations to supplement City staff. Contractors are informed of the requirements of the permit at an annual meeting on the NPDES Permit and its importance to their operations, including: o Landscape maintenance activities such as mowing, edging, pruning, tree work o Pesticide, herbicide, and fertilizer application o Irrigation repair and maintenance o All activities required while performing the above activities The Contractors are provided with a Contractor Compliance Manual for reference, which includes: o An overview of the purpose and goals of the Stormwater Management Plan through excerpts from the NPDES Permit, the Stormwater Management Plan, the City of Salinas Urban Watershed Management Program, and the California Stormwater BMP Municipal Handbook o CASQA BMPs associated with the contractor’s operations o Pesticide Use Requirements of the permit including weather forecast use and reporting and pesticide use reporting (Documentation of Weather forecast check implemented in Year 5). o A copy of the annual pesticide use report and rainfall summary for evaluation of their effectiveness in meeting requirements of the previous permit year. o Sign Up Sheet for Meeting and Training Attendees The Permit Meeting attendees include representatives from all of the contractors utilized by the Park and Urban Forestry division who are involved in stormwater-related operations, the Park and Urban Forestry Manager, Park & Urban Forestry Supervisors, and the Facility Maintenance Crew Supervisor (Oversees Assessment Districts and their contractors). The meetings include discussion of the Permit requirements, associated BMP’s, results of pesticide use reports and compliance effectiveness for the previous permit year, and any adjustments or changes required to improve compliance, or to meet changes in the Permit or Plan. Specific BMP’s that are also emphasized and reviewed are: o Protection of stormdrains during landscape operations o Requirement to print and utilize weather reports for compliance with pesticide application criteria for rainfall events Oversight of contract operations for this permit year was through observation and assessment of ongoing scheduled contract operations by supervisors and the manager of the Park and Urban Forestry Division, as well as evaluation of individual contract operations as they were issued and completed to assess proper compliance with the permit and with the scope of work required by the City for proper completion of the contract. Observations were visual and not recorded, unless they were part of the Annual Park Facility Inspection -2015, that included contractor operations in parks, such as mowing and landscape operations and irrigation repairs.
E.15.f.iv – Training A listing of staff trained, the average score received, and a copy of the training presentation and assessment used are included in Appendix E. An evaluation of the post-training assessments indicated that it was not understood that a swimming pool in a Rec Center discharging to the City’s storm drain system is an illicit discharge. The maintenance staff had been taught that this type of discharge was allowed if the water was E-15
dechlorinated first, which is true. So this distinction will be added to the next training presentation. It was also not clear who all to call in case of an illicit discharge. Staff did not understand that 9-1-1 can be called as well as the City Yard Hotline. During the training it was explained that discharges from Fire Dept exercises utilizing foam and the washing of Fire Trucks are illicit discharges. However, in the assessment it was not clear that discharges from Firefighting activities (real fire responses) are not illicit discharges. Staff were provided information to resolve the confusion around these issues. Future training presentations will provide more clarity when addressing these types of illicit discharges. Evaluation of the post-training assessments for municipal maintenance and residential BMPs indicated there were two questions that most people struggled with. The first was identification of a PVC pipe discharging to a ditch as being representative of something you would find as part of the City’s storm drain system. Most felt this was an illicit discharge (as the City often does regarding Ag discharges ). Second, most people in attendance did not clearly understand what a “structural BMP” is. In the future, more clarity will be provided in the definition of what a constitutes a structural BMP. Documentation of Contractor training is included in Appendix E.
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Provision F: Commercial and Industrial F.11 – Reporting requirements: F.11.b: Year 2 On-going Reporting Requirements F.11.b.i – Commercial and Industrial Inventory The Commercial and Industrial inventory can be found in Appendix F. F.11.b.ii – Information Management System Updates The information management system for collecting commercial and industrial data is still in progress. Consolidation of all data gathered into one location, how the data is gathered electronically, and report formatting are all issues being addressed in year 5. F.11.b.iii – Commercial and Industrial BMPs Designated A summary of BMPs designated for all Facilities and operations on the Commercial and Industrial Inventory have been assembled from the use of CASQA BMPs and those implemented by the City of Salinas Public Works Department. A copy of the handouts referred to below are included in Appendix F. 1) Industrial Facilities SC-30 Outdoor Loading/Unloading SC-32 Outdoor Equipment Operations SC-11 Spill Prevention, Control & Cleanup SC-75 Waste Handling and Disposal SD-32 trash Storage Areas SD-13 Storm Drain Signage Salinas Hand Out- Pressure Washing BMP Handout Salinas Hand Out- Illicit Discharges 2) Commercial Food Services SC-71 Plaza and Sidewalk Cleaning SC-60 Housekeeping Practices SC-41 Building and Grounds Maintenance SC-75 Waste Handling and Disposal SD-13 Storm Drain Signage Salinas Hand Out- Pressure Washing BMP Handout Salinas Hand Out- Illicit Discharges 3) Commercial Automotive Repair Facilities and Operations a. Gas Stations Retail or Wholesale Gasoline Outlets SD-30 Fueling Areas SD-13 Storm Drain Signage SC-11 Spill Prevention, Control & Cleanup F-1
SC-71 Plaza and Sidewalk Cleaning SD-32 Trash Storage Areas Salinas Hand Out- Pressure Washing BMP Handout Salinas Hand Out- Illicit Discharges
b. Automotive Repair, Cleaning, and Maintenance, Commercial Carwashes SC-41 Building & Grounds Maintenance SC-22 Vehicle and Equipment Repair SC-11 Spill Prevention, Control & Cleanup SC-21 Vehicle and Equipment Cleaning SC-75 Waste Handling and Disposal SD-13 Storm Drain Signage Salinas Hand Out- Pressure Washing BMP Handout Salinas Hand Out- Illicit Discharges c. Automotive Auto body and Auto Dealerships SC-22 Vehicle and Equipment Repair SC-21 Vehicle and Equipment Cleaning SC-41 Building & Grounds Maintenance Sc-11 Spill Prevention, Control & Cleanup SC-30 Outdoor Loading/Unloading SC-32 Outdoor Equipment Operations SD-13 Storm Drain Signage SD-32 Trash Storage Areas Salinas Hand Out- Pressure Washing BMP Handout Salinas Hand Out- Illicit Discharges 4) Transportation, Trucking Centers SC-41 Building & Grounds Maintenance SC-22 Vehicle and Equipment Repair SC-21 Vehicle and Equipment Cleaning SD-30 Fueling Areas SC-11 Spill Prevention, Control & Cleanup SC-75 Waste Handling and Disposal SD-32 Trash Storage Areas SD-13 Storm Drain Signage Salinas Hand Out- Pressure Washing BMP Handout Salinas Hand Out- Illicit Discharges
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5) Commercial and Retail Centers a. Department Stores SC-41 Building and Grounds Maintenance SC-71 Plaza and Sidewalk Cleaning SC-43 Parking/Storage Area Maintenance SD-13 Storm Drain Signage SD-32 Trash Storage Areas Salinas Hand Out- Pressure Washing BMP Handout Salinas Hand Out- Illicit Discharges b. Building Materials SC-41 Building & Grounds Maintenance SC-71 Plaza and Sidewalk Cleaning SC-30 Outdoor Loading/Unloading SC-32 Outdoor Equipment Operations SC-60 Housekeeping Practices SD-13 Storm Drain Signage SD-32 Trash Storage Areas Salinas Hand Out- Pressure Washing BMP Handout Salinas Hand Out- Illicit Discharges c. Paint-Glass-Wallpaper SC-75 Waste Handling and Disposal SC-71 Plaza and Sidewalk Cleaning SC-60 Housekeeping Practices SC-43 Parking/Storage area Maintenance SD-32 Trash Storage Areas SD-13 Storm Drain Signage Salinas Hand Out- Pressure Washing BMP Handout Salinas Hand Out- Illicit Discharges d. Property Management SC-43 Parking/ Storage Area Maintenance SC-41 Building & Grounds Maintenance SC-71 Plaza and Sidewalk Cleaning SD-12 Efficient Irrigation SD-13 Storm Drain Signage SC-60 Housekeeping Practices SD-32 Trash Storage Areas Salinas Hand Out- Pressure Washing BMP Handout Salinas Hand Out- Illicit Discharges F-3
e. Distributor SC-75 Waste Handling and Disposal SC-11 Spill Prevention, Control & Cleanup SC-43 Parking/Storage area Maintenance SC-30 Outdoor Loading/Unloading SC-32 Outdoor Equipment Operations SD-13 Storm drain Signage SD-32 Trash Storage Areas Salinas Hand Out- Pressure Washing BMP Handout Salinas Hand Out- Illicit Discharges 6. Commercial Mobile Operations a. Mobile Auto Detailing SC-10 Non-Stormwater Discharges SC-21 Vehicle and Equipment Cleaning SC-30 Outdoor Loading/Unloading SC-32 Outdoor Equipment Operations SC-11 Spill Prevention, Control & Cleanup SC-75 Waste Handling and Disposal SC-60 Housekeeping Practices SD-32 Trash Storage Areas Salinas Hand Out- Pressure Washing BMP Handout Salinas Hand Out- Illicit Discharges b. Mobile Maintenance Services, Carpet Cleaning etc. SC-10 Non-Stormwater Discharges Sc-21 Vehicle and Equipment Cleaning Sc-30 Outdoor Loading/Unloading Sc-32 Outdoor Equipment Operations SC-11 Spill Prevention, Control & Cleanup SC-75 Waste Handling and Disposal SC-60 Housekeeping Practices SD-32 Trash Storage Areas Salinas Hand Out- Pressure Washing BMP Handout Salinas Hand Out- Illicit Discharges c. Welding & Fabrication SC-75 Waste Handling and Disposal SC-11 Spill Prevention, Control & Cleanup SC-43 Parking/Storage Area Maintenance SC-30 Outdoor Loading / Unloading SC-32 Outdoor Equipment Operations F-4
SD-13 Storm Drain Signage SD-32 Trash Storage Areas Salinas Hand Out- Pressure Washing BMP Handout Salinas Hand Out- Illicit Discharges
7. Commercial Trash and Garbage Facilities and Operations a. Recycling Centers SC-75 Waste handling and Disposal SC-41 Building & Grounds Maintenance SC-11 Spill Prevention, control & Cleanup SC-30 Outdoor Loading/Unloading SC-32 Outdoor Equipment Operations SD-13 Storm Drain Signage SD-32 Trash Storage Areas Salinas Hand Out- Pressure Washing BMP Handout Salinas Hand Out- Illicit Discharges 8. Aviation, Marine, and Equipment Facilities and Operations a. Aviation SC-41 Building & Grounds Maintenance SC-21 Vehicle and Equipment Cleaning SC-75 Waste Handling and disposal SC-11 Spill Prevention, Control & Cleanup SC-60 Housekeeping Practices SD-32 Trash Storage Areas Salinas Hand Out- Pressure Washing BMP Handout Salinas Hand Out- Illicit Discharges b. Equipment Rental SC-22 Vehicle and Equipment Repair SC-21 Vehicle and Equipment Cleaning SC-41 Building & Grounds Maintenance SC-11 Spill Prevention, Control & Cleanup SC-30 Outdoor Loading/Unloading SC-32 Outdoor Equipment Operations SD-13 Storm Drain Signage SD-32 Trash Storage Areas Salinas Hand Out- Pressure Washing BMP Handout Salinas Hand Out- Illicit Discharges
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c. Equipment Sales SC-22 Vehicle and Equipment Repair SC-21 Vehicle and Equipment Cleaning SC-41 Building & Grounds Maintenance SC-11 Spill Prevention, Control Cleanup SC-30 Outdoor loading/Unloading SD-13 Storm drain Signage SD-32 Trash Storage areas Salinas Hand Out- Pressure Washing BMP Handout Salinas Hand Out- Illicit Discharges 9. Commercial Landscaping and Pest Control Operations a. Specialty Contractors SC-41 Building & Grounds Maintenance SC-22 Vehicle and Equipment Repair SC-21 Vehicle and equipment Cleaning SC-30 Outdoor Loading/Unloading SC-32 Outdoor equipment Operations SD-12 Efficient irrigation SD-32 Trash Storage Areas SD-13 Storm drain Signage b. Pest Control Services SC-75 Waste Handling and Disposal SC-11 Spill Prevention, Control & Cleanup SC-43 Parking/Storage Area Maintenance SC-30 Outdoor Loading/Unloading SC-32 Outdoor Equipment Operations SD-13 Storm Drain Signage SD-32 Trash Storage Areas Salinas Hand Out- Pressure Washing BMP Handout Salinas Hand Out- Illicit Discharges c. Cemeteries and Golf Courses SC-75 Waste Handling and Disposal SC-11 Spill Prevention, Control & Cleanup SC-43 Parking/Storage Area Maintenance SC-30 Outdoor Loading/Unloading SC-32 Outdoor Equipment Operations SD-13 Storm Drain Signage SD-32 Trash Storage Areas Salinas Hand Out- Pressure Washing BMP Handout F-6
Salinas Hand Out- Illicit Discharges 10. Miscellaneous Commercial Facilities or Operations a. Pet Services/Veterinary Services SC-75 Waste Handling and Disposal SC-43 Parking/Storage Area Maintenance SC-71 Plaza and Sidewalk Cleaning SC-60 Housekeeping Practices SD-32 Trash Storage Areas SD-13 Storm drain Signage Salinas Hand Out- Pressure Washing BMP Handout Salinas Hand Out- Illicit Discharges b. Commercial Laundries SC-75 Waste Handling and Disposal SC-71 Plaza and Sidewalk Cleaning SC-60 Housekeeping Practices SC-43 Parking/Storage Area Maintenance SD-32 Trash Storage Areas SD-13 Storm Drain Signage Salinas Hand Out- Pressure Washing BMP Handout Salinas Hand Out- Illicit Discharges
F.11.b.iv – Inspection Notification Procedure Each facility being inspected in the permit year is sent a letter notifying them of the City’s permit requirement to perform the inspection. A sample inspection sheet is included with the mailing in case the business would like to perform a self-assessment prior to the official inspection. Each facility is notified one month prior to inspection visit. 100% of all commercial and industrial facilities inspection in Year 4 were notified of their inspection, provided a sample inspection form, and provided BMP brochures during the inspection visit. F.11.b.v – Inspection Procedures A guidance for performing Industrial inspections was developed for the City in 2000 (See Attachment F). This procedure is still used; however, updated inspection checklists, a current commercial/industrial inventory, current BMP brochures, and current excerpts from the City’s Stormwater permit and the IGP permit are used. The overall inspection guidance manual will be updated in Year 5 to include these updated materials and to also address commercial business inspections. F.11.c: Year 3 On-going Reporting Requirements F.11.c.i – Summary of Inventory and Prioritization Updates The City has implemented holding a kickoff meeting each year prior to beginning commercial and industrial inspections. Industrial facilities are reviewed and prioritized according to their past inspection performance (if a facility was issued an NOV or required a follow-up inspection), if a facility has a diversion valve, has a past F-7
history of water quality exceedances, wastes that are generated by the facility’s activities, and a facility’s proximity to a 303(d) waterbody. Facilities meeting any of criteria are considered higher priority and are inspected during the permit year. All industrial facilities were inspected in Years 3 and 4. Starting in Year 5, not all industrial facilities will be inspected every year, only those that meet the criteria based upon potential threat to water quality. Per the permit requirements, the “industrial” facilities are a category of facilities on the commercial and industrial inventory. 20% of all facilities in the inventory are required to be inspected each year. So all industrial and commercial facilities in the inventory will be inspected by Year 5, with only those facilities meeting the prioritization criteria inspected multiple times in the five-year period. Commercial facilities are inspected according to the listing of categories in the permit. Not all 1401 facilities are in our information management system and therefore are not mapped to determine proximity to a 303(d) waterbody. All facilities within a commercial business category are inspected in a permit year, whether they would be higher priority or not. The inventory is being reviewed in Year 5 to determine potential pollutants from a facility’s activities (commercial businesses) and all facility information is being entered into a data management system in order to facilitate mapping of the various category businesses on a watershed map. This will allow for greater ease of prioritization. F-F.11.c.ii – Review of BMPs Required Beginning in Year 5, BMPs for the various categories of commercial businesses and the industrial facilities are reviewed to determine continued applicability of current BMPs and if additional BMPs are necessary. If additional BMPs are necessary, they will be added to the list sent to facilities each year. There were no updates to the required BMP list sent to commercial and industrial facilities in Year 4. F.11.c.iii – New Facilities During this inspection period we were able to provide two new industrial facilities and three new commercial facilities with the most recent BMPs that would help protect water quality at their facility. All facilities were provided notice of the Salinas permit requirements for Business and Industrial inspections. The new facilities are: Industrial:
Green Rubber – Kennedy Ag: Fabrication/Welding and Casting operations Clean-Tech Logistics: Tote washing operations
Commercial:
Patty Cakes – 1564 Constitution Blvd.
El Pastore Taqueria- Northridge Mall Islas Marietta Restaurant- 330 Main St.
F.11.c.iv – Total Number of Facilities Inspected 395 (28%) industrial and commercial facilities were inspected in Year 3. 252 (18%) commercial facilities as well as 78 industrial facilities were inspected in Year 4. The industrial inspections and any follow-up inspections were not counted toward the 20% annual inspection requirement. Nine industrial facilities (10%) and 11 commercial food facilities (4%) required follow-up inspections. Samples of TrakIt follow-up inspection reports are located in Appendix F. F-8
To date, 647 commercial and industrial inspections have been completed of the 1401 facilities listed in the inventory. This inventory is being reviewed in Year 5 and is being revised to removed businesses that are inside shopping malls and those that have no potential to impact water quality via stormwater runoff (such as a real estate office). This will reduce the number of facilities requiring inspections closer to the 1250 minimum required by our permit. The City has completed inspection of 46% of the 1401 facilities currently in our commercial/industrial inventory. The revised inventory of only those facilities that truly have the potential to threaten water quality via business activities and pollutants generated will show that the City is inspecting well above the 20% required each year. F.11.c.v - vii – Inspection Results The results for the Year 4 inspection of industrial and commercial food facilities in contained in Appendix F. Although 80 industrial facilities are listed, 78 industrial inspections were completed for Year 4. Two facilities were unavailable for inspection. The two facilities that were not inspected were: 1. Cal Pacific Specialty Foods: No operations took place at the facility during the inspection cycle. The facility is only used as an overflow site for their Moss Landing Plant. 2. International Paper: Hansen’s Site Facility was not inspected as they shut down seasonal operations before we could schedule an inspection. Only two industrial facilities had a BMP rating < 3, Monterey County Yard and Salinas Tallow Company. These were re-inspected and achieved a rating of 3. These facilities will be re-inspected in year 5 to ensure the BMP rating is maintained at 3 or greater. Only one commercial food facility, Kristy’s Donuts, received a trash rating below 3. The facility was re-inspected and achieved a 3 rating. All facilities are given a carbon copy of their inspection results at the time of inspection completion. Industrial Facilities:
The BMP scores of our Industrial facilities for this season are: 51 of 80 facilities scored a 4 for BMP = 64% above baseline compliance 22 of 80 facilities scored a 3 for BMP = 28% at baseline compliance 1 facility scored a 5 for BMPs = Quin Caterpillar 4 facilities scored an initial score of 2 for the BMPs at their facilities, but have since made corrections and are now back in compliance (score of 3) 93% of the Industrial facilities that receive a yearly Stormwater Environmental Compliance Inspection were compliant with a score of 3 or better at the time of their yearly inspection. Follow-up inspections were completed on-site at 8 facilities and 1 was completed via email photos. 10% of our inventory of Industrial facilities received a list of follow-up items to complete and were brought into compliance once these were completed. Two New facilities were added to the list for initial inspection this year: Green Rubber-Kennedy Ag: Fabrication/Welding and casting operation Clean-Tech Logistics: Tote washing operation Facilities that received a 2 as their initial inspection rating for 2015/2016: Salinas Tallow: WDID 3271015984 Monterey County Maintenance Yard: WDID3271017898 Green Gate Fresh: WDID 3271024447 F-9
Tovar Construction Notice of Violations were sent to the following four Industrial facilities for illicit discharges 2015/2016 (see Appendix H for details): Coastal Cooling/Western Logistics Newstar Fresh/Organic Girl Cool Pacific Coastal Tractor The following facilities failed to improve the BMP inspection rating score the past year. Their IR fell from a 4 to a 3 in 2015: Monterey Fish Drew Masa Cooling Salinas Real Property Americold Logistics Granite rock Construction Uni-Cool Market Street Performance Ag (previously was NH3) Coastal Tractor Salinas Valley Cooling Valley Fabrication Seed Dynamics Tovar Construction Green Gate Fresh
Comparison of Inspection Ratings Recorded over the Past 3 Permit Years: 2015/2016:
39 facilities had an average score of 4 = 50% well above baseline compliance. 13 facilities had an average score of 3.5 = 16% above baseline compliance. 18 facilities had an average score of 3-3.3 = 23% baseline compliance. 2 Facilities received a score of 4.3 over the past three years: Quin Cat & Culligan Water. 71 of 80 facilities within the City of Salinas on the Industrial Inventory have maintained an average score of 3 or better. That means 88% of the Industrial facilities have been in compliance since we began the rating system in 2013. Based on the past three years of compliance inspections, we have had the following facilities with an average score of less than 3: Salinas Tallow Company Golden Gate Petroleum Monterey County Maintenance Yard Green Gate Fresh Tovar Construction The facilities listed below were not included in the survey of 3-year averages because they have only been inspected once in the 3-year cycle of inspections. F-10
Cal Pacific Kennedy Green Rubber Clean Tech Facilities that have improved their inspection score between 2014 to 2015: Taylor Farms (1225 Abbott St) West Rock (aka Rock Tenn) Mann Packing Crop Production Services Quin Cat
2014/2015: Inspection rating comparison to the first year (2013) we recorded inspection ratings:
15 of 78 facilities have improved their inspection score between 2013 to 2014, 19% of facilities improved their rating. 57 of 78 facilities received a score of 4 or better = 73% well above baseline compliance. One facility achieved a rating of 5 at the time of the inspection: Culligan Water. 17 of 78 facilities received a score of 3 = 22% baseline compliant. 4 facilities received a score of 2 and a follow-up inspection to regain their compliance, which is less than 5% of facilities having non-compliant BMPs at the time of their inspection. 74 of 78 (95%) facilities were compliant at the time of their Environmental Stormwater Compliance inspection. Industrial Facilities that received a Notice of Violation in 2014 for illicit discharges: Joyce Vineyards Express Harvesting (Old River Ranch) - moved in 2015
2012/2013: This was the first year that we applied the inspection rating system for the BMPs.
76 Environmental Compliance Inspections were completed. 46 of these facilities scored 4 or better on their first inspection = 61% were well above baseline compliant. 26 facilities received a score of 3 = 34% baseline compliant. 4 facilities received a score of 2 and required a follow-up inspection to regain compliance. Upon reinspection, they received a passing score of three = 1 acre in size. These large private lots are areas that would require maintenance to prevent debris from reaching the City’s storm drainage system. The large green spaces are areas where proper, responsible pesticide/fertilizer management is necessary to prevent associated pollutants from reaching the City’s waterbodies. Included from previous years are the private residential streets and the airport. The updated map, Figure G-2, is included in Appendix G. G.6.c.iii: High Priority Residential Area and Activity BMPs The City has many residential outreach brochures on its website: (http://www.ci.salinas.ca.us/services/engineering/planning/permit_forms.cfm) Additionally, the City has posted “Water Quality Tips for Residents” (http://www.environmentsalinas.com/water/water-quality-tips-residents) The City’s public education and outreach program implements programs to educate City residents on the high priority residential stormwater issues identified in Year 1. The focus of this outreach is: 1. Residential automobile maintenance, washing and parking. 2. Home and garden care activities and product use. 3. Trash disposal, bulky waste, pet waste, and household hazardous waste Salinas expanded its integrated pest management (IPM) campaign this year using the acclaimed program “Our Water Our World” (OWOW). Several nurseries and hardware stores were stocked with IPM literature and “shelf-talkers” that provide guidance on healthy garden choices. Major chain stores like Home Depot and Orchard Supply Hardware and several smaller hardware stores, such as Ace Hardware were included. Salinas
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took particular care to ensure that stores within a neighborhood in proximity of 303 (d) listed water bodies and neighborhoods where residents may be disenfranchised were included--see photos for examples. Bulky waste was targeted as part of the city’s CBSM activities. A summary of that program can be found in Provision M. Through its joint powers agreement with the Salinas Valley Solid Waste Authority, Salinas continued its household hazardous waste abatement program. Educational materials can be found on this site: http://svswa.org/ In addition, Salinas is partner to the regional effort to abate household hazardous waste among other solid waste issues. Salinas contributes to program activities and funding for towards the Protect Your Central Coast program that provided information and opportunities for engagement regarding hazardous and other waste materials---see link: http://protectyourcentralcoast.org/
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G.6.d.i: Training All personnel involved with ensuring residential BMPs are implemented are Public Works staff and our public education/outreach staff. Please see section Appendix E for information on staff training on residential BMPs. G.6.d.ii: Residential Outreach of Stormwater Permit Requirements and BMPs There were no letters sent out to Salinas residents regarding our stormwater permit requirements and recommended implementation of residential BMPs.
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Provision H: Illicit Discharge Detection and Elimination H.14 – Reporting requirements: H.14.c.i: Updates to MS4 System Map The City’s MS4 System map and Urban Subwatershed map were updated to correct the subwatersheds to align with those indicated in Salinas’ Permit Attachment F (“Salinas Existing Urban Subwatersheds”) and to add infrastructure information for the new Monte Bella and Auto Center subwatersheds. The revised maps are included in Appendix Q (Figure Q.2.1 and Figure Q.2.2). H.14.c.ii: Updates to the High Priority IDDE Area Map The City’s map of High Priority IDDE areas was revised to correct the subwatersheds to align with those indicated in Salinas’ Permit Attachment F (“Salinas Existing Urban Subwatersheds”), update the map for past illicit discharges and sanitary sewer overflows (SSOs), areas of “Marginally Housed”/homeless camps and cleanup areas, and to revise the “High Priority” IDDE area. H.14.c.iii: % Permit Coverage Area Designated as High Priority IDDE Area The revised High Priority IDDE Area map was re-evaluated and the High Priority IDDE Area was revised to remove areas that had very few illicit discharges, remove those areas that are not within the permit coverage area and add the downtown area. The new High Priority IDDE area is 20% of the total permit coverage area. H.14.c.iv/v: Summary of Drive-by Inspections Summaries of the night-time quarterly inspections for Years 3 and 4 (for comparison) are located in Appendix H. In reviewing the results of the inspections for both years, it appears most of the illicit discharges found during the evening/late night drive-bys are due to runoff caused by pressure washing, outside cleaning activities, or outside vehicle maintenance activities. Some of the facilities received Notices of Violation letters as a result of the activities noted. These facilities are entered into the TrakIt system for follow-up inspections which usually occur on a monthly basis until issue resolved. H.14.c.vi: Actions Implemented by Permittee to reduce Incidental Runoff The City passed ordinances in 1991 that comprise Section 36A (Water Conservation) of the Salinas Municipal Code. This chapter has mandatory restrictions that address over-irrigation, broken sprinklers, vehicle cleaning, pressure washing and draining of swimming pools/hot tubs. Applicable sections are included below:
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H.14.d.i: Dry Weather Screening Included in Appendix H is a map of dry weather screening locations for Year 4 and a new map of dry weather screening locations to be utilized in Year 5. All 489 sampling locations were sampled in Year 4. This was found to be an exorbitant amount of sampling locations. A new dry weather screening plan was developed for Year 5 taking into account the following: Areas with older infrastructure Areas containing industrial and commercial facilities on the City’s inspection inventory Areas with a history of illegal dumping Areas with a history of past illicit discharges or likely to have illicit discharges or illegal connections H-2
Areas with septic systems Areas with older sewer lines or a history of SSOs
From the evaluation of the map containing all of these areas, “High Priority IDDE Areas” were designated. The new dry weather screening stations selected for Year 5 are the City outfalls and a few chosen manholes in the lower left quadrant of the map. It was determined these sites would sufficiently represent flows from all areas of the subwatersheds. Any dry weather flow identified would be source-tracked up the watershed via storm system sectional maps. The City is developing an application to provide electronic maps to staff performing dry weather screening and illicit discharge/illegal connection response. A summary of the dry weather screening data for Year 4 is included in Attachment H. The data management system was not set up in Year 4 to collect all required information. Personnel also did not complete all required fields in the electronic field application so there is information missing regarding the dry weather flows found. The GIS Dept. has revised the electronic field applications to provide drop-down boxes for each data field required per the permit. The record for the manhole or outfall being inspected cannot be closed unless all applicable boxes have been completed. Additionally, staff have been apprised of the importance of completion of all information in the dry weather screening records as well as providing thorough information regarding source tracking results. City staff performed field assessments of 489 dry weather screening locations. Based on visual observations and field sampling of flowing or ponded water, the source tracking process was implemented. 100% of the 489 locations were completed in the City for 2015-2016 reporting period. Eight locations of ponded, and flowing water were detected at various outfall and manhole sampling sites, with sampling results exceeding the action limits, thus qualifying them as an illicit discharge. There were 4 Notices of Violation letters issued for illegal cross-connections and various BMP implementation issues pertaining to detergent from washing events. In most of the 8 incidents, the sites with ponded water were not ongoing discharges. Follow-up investigations found no evidence that would aid in identifying a source of these discharges. Detailed chronological history on these exceedances at these various locations are documented in Appendix H. The field monitoring consisted of analysis of the following constituents: Turbidity, Detergents, pH, and Conductivity. The established benchmark action levels are presented in the table below: Water Quality Criteria and Dry Weather/Illicit Discharge Action Levels for the SSMP Pollutant
Action Level
pH
7.0 – 8.5b
Turbidity (NTU)
126a
Detergent (mg/L)
0.5c
Potential Problem Conductivity (uS/cm)
Degree or Restriction on use c None
Slight to moderate
Severe
700
700-3000
>3000
The City’s Dry Weather Screening locations were determined using the “grid system” outlined in the permit. The guidelines used established mapping of the MS4 to determine High Priority IDDE areas. The dry weather manhole screening locations, grid locations in ¼ mile increments per permit requirements, and watersheds indicated for each grid area were used for the 2015-2016 dry weather screening program. In year 5, modifications will be based on selected stations that are determined to provide adequate coverage of the discharges from the entire MS4 system in each subwatershed. The City worked to ensure the selection H-3
of stations meets, exceeds, or provides equivalent coverage to the coverage established by the “grid system” requirements in the permit. City GIS staff is developing a new mapping and data collection program to meet the modifications for reporting period 2016-2017. A summary of Dry Weather screening station exceedances and the follow-up actions taken are located in Appendix H. H.14.d.ii: IDDE Source Tracking Procedures A flow chart depicting the illicit discharge or dry weather flow investigation and source tracking procedure, as well as a revised Salinas IDDE response form are located in Appendix H. The “Illicit Discharge/Dry Weather Screening Guidance Manual” is currently being revised to make the manual more user friendly to the new employee who has no experience with the IDDE process. H.14.d.iii: IDDE Source Investigations Performed and Corrective Actions Taken A detailed summary of illicit discharge responses is located in Appendix H. H.14.e.i: Illicit Discharge Calls Received by Illicit Discharge Reporting System A log of illicit discharge calls received is located in Appendix H. H.14.e.ii: Results of Testing of the Illicit Discharge Reporting System The City tests the reporting system to ensure it is operating as intended each year. City staff tests the reporting system a minimum of four times monthly. A test alarm is sent from a sewer pump station to test the emergency call-out system. An automated alarm is sent to County Communications (911) indicating a problem in a sewer lift station that might result in an overflow. The problem codes report a range from high water alarm, power off condition or low wet well indicating a potential blockage in the sewer system preventing water from reaching the lift station. During business hours the alarm first goes to 911 and the call is dispatched to the City’s Environmental & Maintenance Service 758-7233 number for dispatch to response personnel. The emergency alarm is also setup to independently call the pump station mechanic, and two other senior maintenance personnel for redundancy. After hours, weekends and holidays, County Communications will page the on-call person. The on-call roster provided to County Communications also includes home phone numbers, City cell phone numbers and personal cell phone numbers of the on-call person and other maintenance personnel that are on the on-call list. The list also includes the contact numbers for responsible supervisors and managers for redundancy for escalation of the response if required. The reporting system is regularly tested by calls that are successfully routed for response to illicit discharges, spills or other requests for emergency or non-emergency assistance during business hours and after hours. The reporting system is effective in reaching response personnel in a timely manner that allows for an immediate response to illicit discharges, spills or other emergency or nonemergency calls. The reporting system has been effective in allowing a 100% containment and recovery of reported illicit discharges and spills. Logs of illicit discharge reports received by the City and sample sheets of sanitary sewer pump station check lists showing testing of alarm system are located in Appendix H. During this permit year 2015-2016 processes for logging calls were modified by setting up access to logs and IDDE database so other responsible personnel can regularly update or review.
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H.14.e.iii: Summary of Activities Implemented for Used Oil and Toxic Material Disposal Management and disposal of all used oil, vehicle fluids, batteries, paint and other household hazardous waste is facilitated through Salinas Valley Solid Waste Authority’s HHW Disposal program and Republic Services (used oil). Both are collaborative education and outreach partners with the City focusing these efforts on educating the public on proper waste oil and HHW disposal and drop-off locations. A summary of used oil and toxic material disposal is located in Appendix H. The recycling programs resulted in 13,055 gal of used oil, 540 gal of antifreeze and 4270 lbs of oil filters recycled. H.14.e.iv: MS4 Inlet Labeling Status The City labeled 1,471 catch basin inlets (41% of total) with bilingual inlet markers for permit year 2015-2016. There are 3551 total storm drain inlets within the MS4 system. 95 % are completed and 5% still remain to be installed to complete entire system labeling as required by end of permit year 5. There were no additional bilingual “No Dumping” signs installed during permit year 2015-2016. The City will complete the labeling of the entire MS4 system by end of permit year 5. A summary of all catch basin inlet labeling for Year 4 is included in Appendix H. Bilingual Storm Drain Inlet Marker
H.14.e.v: Implementation of Enforcement Response Plan and Enforcement Actions Taken Sample Notice of Violation (NOV) letters are included in Appendix H. H.14.e.vi/vii: Oversight Procedures for Staff Not Employed by the City/Training Everyone who responds to illicit discharge events, performs source tracking or dry weather sampling, or labels storm drains either works for the City or the County Dept. of Environmental Health. Monterey County is held to the same illicit discharge permit requirements as Salinas and works in tandem with City staff. There are no contracted staff who perform activities required in this section. All applicable City staff are trained to Illicit Discharge detection and response procedures annually. Training records are located in Appendix E. The City is developing an overall City training matrix to determine who requires what stormwater training and ensure initial and refresher training are completed per the permit.
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Provision J-Parcel-Scale Development J.7 – Reporting Requirements: J.7.a.i: SWDS revisions Permit year 4: None. J.7.a.ii: Plan Review Process These are changes that were made to the City’s plan review process, regulations and/or other components of the New Development and Redevelopment provisions to effectively require development to adhere to the NPDES Permit requirements: All applicants for specific plans are required to add a Section 7.0 “Stormwater and Water Quality Management” to each specific plan document and demonstrate how the project meets the Permit requirements, SWDS, SWSPs and includes site/parcel based BMPs to the MEP. The requirements of Section 7.0 include the following or similar standard verbiage to require the development to adhere to the Permit: 7.01 Introduction Purpose The City of Salinas initially published draft Stormwater Development Standards (SWDS) in January 2013, to assist project applicants to comply with the City of Salinas NPDES Permit CA0049981 (Resolution No. R32012-0005) and the Central Coast Regional Water Quality Control Board’s (CCRWQCB) Post-Construction Stormwater Management Requirements for Development Projects in the Central Coast Region (Resolution No. R3-2012-0025; amended by Resolution No. R3-2013-0032). The current SWDS edition is December 2013. The City of Salinas SWDS require new and redeveloped projects to apply Low Impact Development (LID) site design strategies and incorporate stormwater Best Management Practices (BMP) on a parcel/site basis to the Maximum Extent Practical (MEP) to reduce the impacts of urban runoff on receiving waters and promote healthy watersheds. Project applicants are required to prepare and implement a Stormwater Control Plan (SWCP) to detail how stormwater runoff and associated pollutants will be managed. The SWCP is required to be prepared under the direction of a Professional Civil Engineer in the State of California, and shall provide sufficient information to evaluate the environmental characteristics of the project area, potential impacts of the proposed development on water resources, and the effectiveness and applicability of measures proposed for managing stormwater runoff. The proposed __________ Specific Plan is a ________development within the City of Salinas __________ Future Growth Area (FGA). The urban development will modify the existing hydrologic conditions of the watershed and introduce new pollutants to receiving waters. The purpose of this section is to outline development standards and guidelines applicable to the _________ Specific Plan to comply with the requirements of the City of Salinas NPDES Permit and the latest edition of the City of Salinas SWDS. Permit Compliance This Specific Plan conforms to the requirements of the City of Salinas NPDES Permit CA0049981 and the latest edition of the City of Salinas 2013 Stormwater Development Standards. If any part of this or any other section of this Specific Plan conflicts with this section or the permit and/or SWDS, the Permit/SWDS shall govern over this section, and this section shall govern over the remaining sections of the Specific Plan. Nothing contained herein shall be construed to permit or allow non-conformance with the Permit/SWDS unless specifically allowed as provided under the Permit Provisions for Alternate Methods of Compliance and justified by sufficient “Alternate Compliance Justification” as outlined in Permit Section J.4.h.ii and approved by the City of Salinas and the CCRWQB staff.
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Projects in the CASP area will manage rainfall at the source using uniformly distributed decentralized controls, natural treatment, and volume reduction BMPs (e.g., bioretention, vegetated swales, filter strips) as a first means of compliance for meeting the numeric criteria for stormwater management to the MEP under the permit and SWDS. If approved by the City Council of the City of Salinas, and for the length of time the approved Specific Plan remains valid and in effect, this Specific Plan shall meet or exceed the requirements of the latest version of the Permit (CA0049981) and SWDS (currently December 2013) in effect at the time of Council Specific Plan adoption in accordance with permit section J.2.C. Project details shall meet or exceed the requirements of the City of Salinas Stormwater Standard Plans (SWSP) adopted April 8, 2014. The italicized verbiage above, and especially the highlighted sentence above, can be pointed to as “changes that have been made to effectively require development to adhere to the NPDES Permit requirements” and that all other documents are subordinate to the Permit unless approved by the City and CCRWQCB staff. J.7.a.iii: Guidance Provided to Development Project Applicants A description of the guidance (i.e. workshops, manuals, brochures, face-to-face discussions) provided to development project applicants to provide assistance in meeting the requirements of the SWDS is presented below. Guidance provided to project applicants took many forms depending upon the level of knowledge of the applicant, the type of project, complexity of the project and when in the project design process, the designer contacted the City. Following are descriptions of each guidance tool, who received the guidance and when in the process they received the guidance and guidance effectiveness: 1. Brochures- http://www.ci.salinas.ca.us/services/engineering/planning/stormwater.cfm The City has several different brochures it provided to applicants depending on the inquiry (see web link above and next page for examples). For those interested in a site development project a general LID brochure (available in both English and Spanish) can be provided by either the initial planner the applicant meets with or a Permit Center (PC) engineer if the planner immediately refers applicants to an engineer. PC engineers will provide the appropriate brochure to the applicant if a planner has not already. For those who contact Planning for a simple car wash or some similar function to see if, and what type of, permits are required, we have brochures similar to the second brochure on the following page. For those that contact a planner to determine what the process is for reducing lawns or removing a pool, especially pertinent for the current drought, we have the third brochure.
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The majority who receive the brochures are home/property owner applicants, design professionals representing the home/property owner as the applicant or contractors investigating what requirements they may need for a project. They receive the brochures normally on first contact with the Salinas Permit Center. They can also receive the brochures from the PC engineer upon review of projects for building permit projects which do not need to go through the planning process. As a side note the City Commercial/Industrial inspectors also utilize the brochures if deemed educational/informative for their contacts during those inspections. Most of the brochures are available in both English and Spanish. Effectiveness is difficult to judge on an applicant by applicant basis. Overall the brochures appear to be well received except for two exceptions: those applicants who balk at compliance whether it is to City codes in general or stormwater requirements in specific, and those applicants who insist the City do the compliance work for them. These applicants, in our experience, are either home/property owners who lack sufficient design experience/knowledge or “designers”. The term “designer” is used for unlicensed J-3
“design professionals” who have difficulty understanding design complexities that licensed professionals do. 2. Workshops- Workshops, when provided by the City, are normally held independent of the review process. Workshops are designed to inform licensed design professionals of Permit requirements. The City advises applicants who are not design professionals to obtain the services of a licensed design professional for more complicated projects. The City judged interest from the local engineering community the past Permit year through the American Public Works Association-Monterey Bay Chapter e-mail blast to members. The members were queried as to whether or not they would be interested in a free seminar on City of Salinas SWDS, and if so, to send the City an e-mail expressing interest and how many would attend if held. We received 2 e-mails of interest for 3 attendees. Most local engineers have been through the approval process so they appeared not to be interested. Those who responded are 2 firms the City would use to supplement staff for Permit compliance and would not be submitting applications on behalf of a client. The City decided it would be better to do individual training through the review/permitting process for all including local firms who may not have been through the process plus out of the area firms.
Salinas Stormwater Development Standards (SWDS) and Stormwater Standard Plans (SWSPs) 3. Manuals- The City has provided all applicants with the link to the City’s SWDS, Stormwater Standard Plans (SWSPs) through the City’s website or through brochures or face to face meetings early in the permit application process, either early in the planning process or early in the building permit process if the project is exempt from planning review/approval. The SWDS manual contains a Threshold Determination and Design Spreadsheet TDDS to assist applicants in determining the requirements that apply to their specific project through entering pertinent data on existing site surface status and proposed changes to the site surface. If an applicant has questions on the use of the TDDS, the applicants are directed to the City’s Stormwater consultant Michael Baker Inc., who will help them through the process free of charge. This also applies to review of the preliminary (conceptual) and final stormwater control plans and assistance in their preparation. This procedure maintains consistency from applicant to applicant. City staff will advise applicants on ways of improving their sites with pervious materials in the interest of being under the minimum design threshold (2,000 s.f. net new/replaced impervious area). The SWSPs are provided along with the SWDS to assist the applicants with conforming to the Permit. J-4
The SWSPs provide applicants with guidance on how PCBMPs and related improvements are to be constructed and also contain guidance on green streets. This process appears effective since it has been the City’s experience all applicants that go through this process become familiar with the SWDS and require minimal assistance upon subsequent project submittal/review processes. 4. Face to Face Meetings Including Phone Conferences- The City holds face to face meetings and/or phone conferences with applicants when requested by the applicant or as a result of referral by planning to answer any questions they may have regarding the permit approval process/Permit requirements. These occur early in the process (prior to application submittal) when the City is provided the opportunity by the applicant and the City encourages this. This opportunity is not always provided to the City as some applicants/design professionals do not do their research into the City’s requirements prior to producing a preliminary design and submitting an application. The City’s effort to gain compliance is made more difficult with this process. Normally the design professional in these cases is reluctant to make the required changes since their design fee does not normally include revisions of a significant scale in order to be low bidder on the design process and retained by the developer/property owner. This normally occurs with out of area engineers and “designers”. However, once the review process has been completed, these applicants are well versed on how not to approach a project and the value of contacting the City early before designing a project. This process appears effective since it has been the City’s experience most applicants that go through this process become familiar with the SWDS and require minimal assistance upon subsequent project submittal/review processes. As much as the City wishes every applicant would contact the City for guidance in Permit compliance prior to designing a project, the City cannot force applicants/designers/design professionals to meet with us prior to the first time they submit a project application. Once applicants/designers/design professionals experience their first application review process and see the value of early consultation with the City, the behavior changes for the better and we are contacted earlier in the process, sometimes as early as the “I’m thinking about this type of project in this location. What type of Permit requirements will I be subject to?” phase of the project. This allows the applicant to have a much better idea of what the true cost of the project will be before proceeding. Those that don’t become familiar with the Permit requirements, and there have been a few recidivists as there seems to be for any type of permit application process, are repeatedly reminded of the Permit requirements. Their projects are not approved until they are fully in compliance with the Permit requirements. Permit compliance is self-reinforcing in this case as these “designers” have a tendency to lose clients or shy away from doing work in Salinas due to review delays and the large number of review cycles, which is not due to the City’s non-performance but due to non-compliant submittals from the applicants/designers/design professionals. It has been staff’s experience that the recidivists provide low design fees to procure work. They then blame the City for cost overruns due to the City’s Permit requirements, obtain additional fee from the client, and the longer they argue with the City about Permit compliance, the more fee they tend to charge their clients. We gained this knowledge through discussion with some property owners who had repeated non-compliant submittals. J.7.a.iv: Tracking Reports - Information Management System The Permit requires the City to develop and maintain an effective information management system to manage and document projects required to implement the requirements of this Section. Specifically, the Permittee shall be able to retrieve each item of information listed below for all projects. a) Tracking information for the following project types: i) Non-Priority Development Projects; and ii) Priority Development Projects; See table in Appendix J J-5
b) Completion date, for the above project types, of the following project stages, where applicable: i) Permittee notified of project; ii) Project application submitted; iii) Project planning application deemed complete; iv) Permittee determines project meets the requirements of this Section; v) Building permit issued by Permittee; vi) Construction commences; vii) Final approval/occupancy; and viii)Maintenance plan approved by Permittee [Note: Tracking O&M addressed in Section E (Municipal Maintenance)] Please note that the City tracks application date (i, ii, iii, permit issued date (iv, and v and vi), completion/occupancy permit issued date (vii, viii). This information is available for specific projects upon request. c) Data used to determine if the project met the applicability threshold for Non-Priority or Priority Development Project [(e.g., impervious area created or replaced, number of housing units, type of project (e.g., automotive repair shop, restaurant, hillside development, or gasoline outlet)]: PSWCP and Final SWCP (where applicable-plans that do not require a planning permit may be required to file only a Final SWCP) are available for projects that the City reviewed and they contain that information. Sample Provided in Appendix J. d) The SWCP: PSWCP and Final SWCP (where applicable) are available for projects that the City reviewed and they contain that information. Sample Provided in Appendix J e) Documentation of the plan review and SWCP review (for Priority Development Projects), to demonstrate the Permittee verified each project met all applicable requirements of this Section, for each approved Non-Priority Development Project and Priority Development Project: PSWCP and Final SWCP (where applicable) are available for projects that the City reviewed and they contain that information. Sample documentation is provided in Appendix J. J.7.a.v: Non-Priority and Priority Development Information See table in Appendix J. J.7.a.vi: Description of Enforcement Activities: Enforcement activities consisted of Correction Notices for those projects found to be non-compliant with the Construction General Permit (1 acre and over) and City Permit requirements for all other construction where the issues could not be resolved at the time of inspection and issuance of red tags to stop work for those projects that were determined not to have a permit from the City. Most correction notices were issued verbally by the City inspector. For year 5 the inspector was trained in the use of the construction inspection forms on April 29th, 2016 and was instructed to document enforcement activities in writing. J.7.a.vii: Training Report 1. See Appendix J for detailed information. List of all staff whose job duties are related to implementing the requirements of this Section/Dates Training Occurred/Topics Covered: Walter Grant, P.E., Senior Engineer, Division Manager, Water, Waste and Energy Division of DPW/Set Up 3/31/13 Training/Managed-Directed-Reviewed Creation of SWDS by Consultant; Prepared presentation and provided 11-18 & 12-10-16 training covering Section J.6 Heidi Niggemeyer, Environmental Resource Planner, Water, Waste and Energy Division of DPW/3-31-13/SWDS &TDDS Use J-6
Robert Russell, P.E., City Engineer, Engineering Division of DPW/3-31-13/SWDS &TDDS Use; 1118-15/Section J.6 Adriana Robles, P.E., Senior Engineer, Division Manager-Permit Center Engineering of DPW/3-3113/SWDS &TDDS Use; 11-18-15/Section J.6 Jamie Lipe, Junior Engineer, Permit Center Engineering of DPW/3-31-13/SWDS &TDDS Use Lucy Ayala, Junior Engineer, Permit Center Engineering of DPW/3-31-13/SWDS &TDDS Use Maria Contreras, Junior Engineer, Permit Center Engineering of DPW/3-31-13/SWDS &TDDS Use Frank Aguayo, Senior Engineer, Manager, Engineering Design Division of DPW/3-31-13/SWDS &TDDS Use; 11-18-15/Section J.6 Eda Herrera, Associate Engineer, Engineering Design Division of DPW/3-31-13/SWDS &TDDS Use; 11-18-15/Section J.6 Phavana Aramkul, Engineering Technician, Engineering Design Division of DPW/3-31-13/SWDS &TDDS Use; 11-18-15/Section J.6 Josie Lantaca, Assistant Engineer, Engineering Design Division of DPW/3-31-13/SWDS &TDDS Use; 11-18-15/Section J.6 Victor Cuin, Engineering Aide I, Engineering Design Division of DPW/3-31-13/SWDS &TDDS Use; 12-10-15/Section J.6 Kathy Wilson, Assistant Engineer, Engineering Design Division of DPW/Returned to work 4-3-16, retired 6-10-16 Steven Margaretten, Junior Engineer, Engineering Design Division of DPW/3-31-13/SWDS &TDDS Use; 11-18-15/Section J.6
Please note City of Salinas Code Enforcement, Community Development Department (Planning/Building Plan Review/Building Inspection), DPW Inspection and other DPW staff members such as G.I.S. staff were provided the 11-18 & 12-10-15 training for a total of 31 participants. 2. Results of training assessments and summary of any implemented changes. The post-training assessment for the SWDS/TDDS training showed 1 attendee at 67% correct, 5 attendees at 83% correct and 5 at 100% correct. The question consistently found incorrect was which projects require both a preliminary and final stormwater control plan and most people who answered wrong were conservative and opined that all projects need both a preliminary and final SWCP when only projects meeting requirements 3, 4 and 5 require both. Future training will need to emphasize that fact more. Neither a post nor pre-training questionnaire was provided for the general Section J training. City staff are exploring providing web based training accompanied by pre and post training questionnaires as a requirement for each staff member based on their duties. A training matrix is currently being prepared to inform that effort. Each year each staff member would be required to take a pre and post training assessment and the applicable training by date certain. New staff will be required to take the same pre and post assessment/training upon induction as a prerequisite of employment with the City.
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Provision K - Construction Site Management K.13 – Reporting Requirements K.13.a.i: Criteria Established for High Priority Construction Sites The City developed the following flowchart containing the criteria to use to determine if a project is a High Priority Construction Site:
K.13.a.ii: Implementation of Minimum Construction BMPs at Construction Sites During the project application process, the applicant is given a copy of the Erosion & Sediment Control Plan checklist as well as the Construction Site Inspection checklist to ensure they are aware of the minimum BMPs K-1
required at their site. Both forms were created in Year 4 to facilitate proper construction site management and outreach to our project applicants.
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K.13.a.iii: Review of Erosion and Sediment Control Plans The City currently utilizes the checklist shown below for informing project applicants of our Erosion & Sediment Control Plan requirements and tracking of a project’s priority status.
K-4
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K.13.d.i: Construction Sites That Did/Did Not Implement the Minimum Construction BMPs The number of construction sites that did/did not implement the minimum construction BMPs was 7 that did and 0 that did not. This represents site developments and does not include all encroachment permit inspections. K.13.d.ii: Summary of Inspections (1) The percentage of High Priority Construction Sites that were inspected each week throughout the rainy season. There were 7 sites. 0% were inspected each week during the rainy season though the number of weeks that each site wasn’t inspected averaged 3 weeks through the rainy season. Please be advised there was an extended dry spell during the rainy season. Inspection forms and requirements were updated prior to the end of the Permit year to address the problem and inspection staff will be reminded of the requirement regardless of whether there is a dry spell or not. Data regarding High Priority Site Inspections is included in the Appendix K document titled “Section K: Storm Event Inspections-High Priority Projects” and/or below. (2) Inspection ratings were not given for each inspection until April 29, 2016. Each site was noted either compliant or non-compliant and, if non-compliant, a correction notice was issued for each site. Inspection ratings have now been implemented per Permit Attachment G and will be included in year 5 annual report since all inspectors have been trained in the use of the inspection checklist and are required to provide that information for construction sites. (3) Dates of ½-inch rain events are discussed under (5) below. (4) The number of active High Priority Construction Sites at the time of each ½-inch rain event are discussed under (5) below. (5) The number and percentage of High Priority Construction Sites ready for each rain event, determined according to Section K.6.d.i. (Inspection Procedures for High Priority Construction Sites) are shown in the table below.
½” Rain Event Date 11/2/15 11/8/15 11/15/16 12/11/15 12/21/15 1/6/16 1/18/16 3/5/16 3/11/16
Number of Active High Priority Sites 6 6 6 6 6 6 6 5 5
Number of/% of Sites Ready for Each Rain Event 5/83 4/67 4/67 6/100 5/83 5/83 5/83 5/100 4/80
(6) The following summarizes the City’s assessment of sediment discharges from sites deemed unready for a rain event, and of impacts to water quality resulting from these discharges.
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The deficiencies noted by the City inspector in one case (7 Harris Pl.) involved removing sediment from a bioretention basin being used as a temporary construction source control which did not release any sediment. The Inspector did not provide adequate information to determine the impacts of the deficiency for other sites which might have been found non-compliant nor did they rate each site except to call it “Compliant” or “Correction Notice”. This deficiency has been rectified by requiring all construction inspectors to utilize the Stormwater Construction Site Inspection Report (Checklist) which requires the inspector to provide this information including rating each site at each inspection. (7) A summary of the results of inspections conducted within 48 hours after a ½-inch rain event, is presented in (6) above. (8) The City continues to make improvements to its information management system. The current City stormwater team has instructed its GIS team in the data collection that is required and our GIS team is working on providing the tabular drop down screens required to collect the required data for these updates as well as supplemental software as required. The City is also modifying the Trakit data collection system to provide fields for all the data required and this will be implemented in year 5. One of the problems the City has in implementing/modifying data management systems is that the systems are utilized city-wide and changing the type/supplier/format normally requires consultation and buy-off from each user. K.13.e.i: Structural BMPs Constructed that are Owned/Operated by the Permittee and Privately Owned/Operated Refer to Section E for information on City owned facilities. 83are privately owned. K.13.e.i: Structural BMPs Constructed that are Owned/Operated by the Permittee and Privately Owned/Operated Refer to Section E for information on City owned facilities. The City inspects 83 privately owned structural BMPs K.13.e.ii: Summary of Structural BMPs Inspected During Construction See Appendix F for a Summary of Private structural BMP inspections. See Section E for City owned structural BMP information. K.13.e.iii: Summary of Structural BMPs Inspected After Construction Refer to Section E for City owned structural BMPs for City facilities. Refer to the attachment “Summary of Structural BMP Inspections” included in Appendix K for private facilities. The first item on the list is actually a City facility maintained by the City and is a duplicate of inspections covered in Section E. All noted deficiencies were corrected. K.13.e.iv: Enforcement Response Plan The Enforcement Response Plan and related notices to non-compliant sites are included in Appendix K. K.13.e.v: Referrals to the Central Coast Water Board for Noncompliance or Non-filers None. K.13.e.vi: Oversight Procedures The following is a summary of the oversight procedures the City implemented for all activities performed by staff not employed by the City. When the City uses outside staff for inspections it utilizes the services of a QSD, and they provide the construction inspection forms. See K.13.a.ii above for the form. Outside QSD consultants must complete the forms in accordance with Permit requirements. A member of the City project team checks the initial QSD consultant’s inspection form completion for completeness correctness and K-9
then during the project to verify the process is continuing to be followed. A notation is made in the file by City staff. K.13.e.vii: Training Report The City held a workshop for City construction inspectors, their supervisors and appurtenant staff including Permit Center Engineers who review permit applications, on 4/29/16. The training was developed to address section K requirements, and included content with regards to March 14, 2013 and December 2-3, 2014 construction-related Water Board audit findings. The course was developed to emphasize areas identified as knowledge gaps during the pre-training assessment that was required of all attendees. Those City staff attending the training included: 1. Heidi Niggemeyer, Stormwater Program Coordinator 2. Rob Russell, City Engineer (In charge of all CIP projects and private project review) 3. Frank Aguayo, Senior Engineer (in charge of CIP Projects) 4. Eda Herrera, Associate Engineer (CIP Projects) 5. Victor Gutierrez, Assistant Engineer (Traffic Division) 6. Adrianna Robles, Senior Engineer (in charge of Permit Center Engineering) 7. Lucila Ayala, Junior Engineer (Permit Center) 8. Maria Contreras, Junior Engineer (Permit Center) 9. Jamie Lipe, Junior Engineer (Permit Center) 10. Jesse Rivas, Senior Construction Inspector (CIP Projects) 11. Marcos Quintero, Construction Inspector (CIP Projects) 12. Marco Becerra, Construction Inspector (CIP Projects) 13. Howard Gustafson, Construction Inspector (CIP Projects) Other staff who are responsible for implementing the construction stormwater requirements of the Salinas Permit who did not attend that training include: 1. Rico Omictin, Construction Inspector (CIP Projects), was kept out of class to handle ongoing construction projects while the other construction inspectors were being trained. He will receive the complete training later in the current Permit year. He was instructed in the use of the inspection forms and requirements for priority projects and construction checklists separately from the class. Howard Gustafson did not complete the post-assessment, hence why the analysis was completed by only 12 attendees. 2. Walter Grant, Manager-Water, Waste and Energy Division of DPW, will take the Section K training with Rico Omictin. Mr. Grant covered engineering while the other DPW engineers were in the Section K training since Mr. Grant had more previous Permit compliance experience. 3. Building, Planning and Code Enforcement Departments were also trained during the past Permit year in Section J Requirements and a summary of that training is included in Section J.7a.vii. As shown in Figure 1, the self-reported confidence of section K requirements prior to the course was 1.42 on a scale of 0 (low) to 4 (high). Confidence in section K requirements rose by an average of 1.92 points, to 3.33, after the course.
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Figure 2 depicts the self-reported satisfaction of the course participant with the course relative to usefulness of the course, and whether the course was a good use of their time.
Most of the broad based questions in the pre-course assessment showed between an 18 and 76 percentile improvement in the post-course assessment. However, two questions reflected a decrease in understanding (by 2 percent). It is not clear if the reduced number of participants who took the afternoon test relative to the pretest skewed the results, or if there was an actual lowering of understanding for these two questions. However, in both areas where improvement was negative (lost), the majority of respondents answered correctly.
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The majority of the six scenarios provided showed improvement. The only area where additional training might be warranted was associated with scenario 1 (fiber rolls as perimeter controls). The variance in each of the scenario’s overall inspection ratings was notable. This is likely attributable to the limited view afforded by each picture (difficulty in determining pollutant discharge risk level), as well as group discussions which indicated that some deficiencies would be considered ‘minor non-compliant’ if it was an anomaly for the contractor, but that the same situation could be deemed ‘significantly non-compliant’ if the issue had been brought up previously and had yet to be addressed. Based on the post-course assessment performance and individual comments provided in the assessment regarding areas in which the respondent would like to see additional training, it is recommended that future courses be workshop-based to include the entire process (plan review to enforcement) with particular emphasis on completing forms properly. The Public Works Department hired an outside consultant QSD and trained it’s construction inspectors, their supervisors and appurtenant staff. The training was developed to specifically address Section K requirements, and included content with regards to March 14, 2013 and December 2-3, 2014 construction-related Water Board audit findings. The course was also developed to emphasize areas identified as knowledge gaps during the pre-training assessment that was required of all attendees. Refer to Appendix K for the training assessment.
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K.13.e.viii: Letters Sent to Construction Site Owners or Operators Pertaining to the Requirements of the Permit Two letters were sent. Refer to Appendix K.
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Provision L: Development Planning and Stormwater Retrofits L.4.a - Planning and Building Document Updates. L.4.a.i - Specific Plan Conditions for Future Growth Areas Inventory of Specific Plans for Future Growth Areas 1. On October 11, 2011, Resolution 20112 Adopted by the Salinas City Council Approved the Specific Plan for the Gateway Commercial Center which includes Lowes. This Specific Plan was approved prior to adoption of the current NPDES Permit (May 3, 2012). The applicant’s engineers requested a change to the Specific Plan reducing the amount of parcel-based LID in lieu of centralized treatment and infiltration ponds. This request was denied by the City. The denial was supported by Central Coast Water Board (CCWB) staff. 2. The City currently is reviewing the Specific Plans for the Central Area and West Area of the North of Boronda Future Growth Area for approval in conjunction with review by CCWB staff. Section 7 titled “Stormwater and Water Quality Management” has been included in each specific plan to address conformance with NPDES Permit requirements. There is not a developer for the East Area at this time and a specific plan application has not been submitted. L.4.a.iii - Urban Subwatershed-Scale Stormwater Planning 1. There have been no cumulative annexations within any urban Subwatershed greater than 40 acres for year 4. 2. There have been no land use actions that are projected to increase the total impervious surface area of an Urban Subwatershed by 5 percent of existing impervious area. L.4.a.iv - Riparian Protection Policies and Requirements 2. All applicable projects approved in this reporting year adhered to setback requirements as outlined in Permit Section L.1.d. including obtaining biotic resources studies for all projects encroaching into the 30 to 100-foot setback and requiring the project to comply with all mitigation measures identified therein. Project information for those projects which encroached into the 100’ setback was forwarded to CCWB staff as required for review 15 days prior to approval of new development within the setback. These projects included the following sites: 914 Acosta Plaza-B15-0324 Acosta Plaza Recreation Area Project Permit Issued 8/5/15-Not Finaled. 851 Work Street-B16-0030 Project Applied for 2/3/16. Permit Not Issued. Project not started. 722 La Guardia-B14-0412-Permit Issued 6/3/15. Finaled 2/9/16. 3. There were no modifications to the riparian protection policies/requirements based on the Watershed Physical Condition Assessments. However, the City will review the potential restoration goals for similar reaches of creeks identified therein if similar reaches of creek are included in a proposed project and include those potential restoration goals where possible as conditions of approval.
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An excerpt from the Gabilan Creek Assessment follows:
City maintenance staff have also targeted transient camps for clean-up within creek reaches within City limits to reduce the amount of trash/trash related pollutants, fecal coliform and excessive human visitation (homeless camps) and remove camps from the flood plain to protect the public safety. See the next page for sites where clean-ups occurred during this Permit year:
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s
Clean-up Sites in 2015 - 2016
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L.4.a.v - CEQA Process Update 2. CEQA process updates have already been accomplished as required in year 1 of the Permit. For projects which require CEQA review, the City’s CEQA questionnaire requires project proponents to address stormwater requirements, and in doing so, requires them to provide preliminary (conceptual) information showing adherence to flow control, treatment BMPs, incorporation of LID principals and water body setback requirements. L.2.b.i-iii: Retrofit Existing Development The City derived a list of five (5) candidate projects as required under Permit Section L.2.c “Pilot Retrofit Project Design”. All candidate projects must meet the requirements of Permit Attachment H. The list of projects in order of anticipated completion from first to last, description, status and ranking for anticipated benefit to watershed processes for each Project are as follows:
1. SKYWAY ROUNDABOUT PROJECT
Skyway Roundabout Project Description: Reconstruct/retrofit intersection of Skyway Boulevard and Alisal Street from standard 4-way stop intersection to a roundabout configuration complete with bioretention planter islands. Project Status: Project completed March 2016. Permit Attachment H Qualifying Retrofit Project Type/Performance Goal: Retrofits incorporated into road projects, provided that the retrofit treats the stormwater runoff from existing or replaced impervious surface (not new or additional impervious surface) resulting in a 20% reduction in volume of discharge generated by the 10year 24-hour storm, or 50% reduction in discharge, generated by the 10-year 24-hour storm of particular POC from at least 1,000 s.f. of existing impervious surface. Project Beneficial Impacts: Project reduced impervious surfaces by 36,304 s.f. and reduced the peak flow rate from the 10-year 24-hour storm event by more than 50% from an area of at least 10,000 s.f. of impervious surface to qualify as a retrofit project. Project Ranking by Anticipated Beneficial Impact: 5 L-4
2. EL DORADO PARK LID BIORETENTION/INFILTRATION PROJECT
El Dorado Park LID Bioretention/Infiltration Project Description: Remove and replace existing concrete landscape ponds with bioretention planters to treat the adjacent frontage half-street runoff. Project Status: Begin construction in July with construction completed in early autumn 2016. Project Beneficial Impacts: Project retains 16,180 c.f. of runoff from the 10-year 24-hour rainfall and can infiltrate 100% of the total 10-year 24-hour runoff from the project area. Permit Attachment H Qualifying Retrofit Project Type/Performance Goal: Retrofits to existing streets that reduce pollutants in discharges from a minimum of one Urban Subwatershed by a 50 percent minimum reduction in discharge generated by the 10-year 24-hour runoff from the project area. Project Ranking by Anticipated Beneficial Impact: 4.
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3. 66” SD Shunt (@ MRWPCA Pump Station)
66” SD Shunt (@ MRWPCA Pump Station) Project Description: Construct a shunt (diversion) of the existing 66” south Salinas storm drain pipe (drains SR designation on Existing Urban Subwatershed Map) dry weather flows to the MRWPCA treatment plant for treatment and re-use and also wet weather flows up to and exceeding the “first flush”. Wet weather stormwater in excess of what the MRWPCA pipeline/plant can carry/treat will be diverted to the existing Salinas Industrial Waste Treatment Plant ponds for storage to be pumped later to the MRWPCA pump station and then to their treatment plant when capacity allows. Project Status: Under design – design completion expected in September 2016. Permit Attachment H Qualifying Retrofit Project Type/Performance Goal: Retrofits to existing storm drain infrastructure that reduce the volume of stormwater discharges from a minimum of one Urban Subwatershed. The drainage area to the project site is approximately 3,000 acres. The project is not designed as a highflow reduction project, so it is not likely to have a significant impact on the 10-year 24-hour peak flow rate or total volume, which precludes it from qualifying for the majority of the performance goals listed in Attachment H.1. However, it represents a significant beneficial impact to the aquatic and riparian habitats as it will eliminate 100% of dry weather flows and the majority of the first flush runoff, which typically have the highest pollutant loads. The performance goals listed in Attachment H.1 do not match the functionality of this project. However, it meets the retrofit requirements listed in the permit, section L.2, namely:
Restoring watershed processes impacted by stormwater management to protect water quality and beneficial uses (L.2.i.1) Reducing pollutants in stormwater discharges; (L.2.i.2) Emphasizing controls that infiltrate, evapotranspire, or harvest/reuse stormwater discharges (L.2.i.3)
By capturing, treating, and re-using the first flush, this project may be able to remove 20 to 50% of the total pollutants found in a single storm event (See Caltrans, First Flush Phenomenon Characterization, 2005)1. Thus, the project would provide equivalent or better benefits to the watershed process than reducing the 10-year 24-hour peak flow by 50% or the 10-year 24-hour runoff volume by 20%. It is L-6
recommended that this specific project be discussed in more detail with the Regional Board so that the City may appropriately claim credit for its implementation as a retrofit project. Project Ranking by Anticipated Beneficial Impact: 2.
4. Boronda Road Widening Project
Boronda Road Widening Project Description: Widen approximately 9,000 linear feet of existing 2 lane roadway to 4 or 6 lanes. Includes potential installation of roundabout at existing Boronda Road/Natividad Road 4-way signalized intersection which facilitates reducing the overall ultimate cross section from 3 lanes each way to 2 lanes each way and removal of 1 existing paved lane to replace it with bioretention median island. Currently under design with construction tentatively to begin in spring of 2017 and completed fall of 2017. Permit Attachment H Qualifying Retrofit Project Type/Performance Goal: Retrofits incorporated into road projects, provided that the retrofit treats the stormwater runoff from existing or replaced impervious surface (not new or additional impervious surface) which result in a 20 percent reduction in volume of discharge, generated by the 10-year 24-hour storm, or 50 percent reduction in discharge, generated by the 10-year 24-hour storm, of particular POC from at least 10,000 ft2 of existing impervious surface. The City’s intent is to meet and/or exceed the performance goal. Project Ranking by Anticipated Beneficial Impact: 3
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5. Carr Lake Project
Carr Lake Project Description: Carr Lake consists of over 500 acres and receives storm runoff from over 100 square miles of tributary watershed which equals approximately 2/3 of the entire Reclamation Ditch Watershed. Carr Lake contains the upstream reaches of Reclamation Ditch No. 1665 (the Reclamation Ditch). The project consists of acquiring Carr Lake property currently used for agricultural purposes (row crops) in the center of the City and restoring the pre-existing wetlands for storm water filtering and infiltration. Project Status: Land Acquisition negotiations for approximately 72 acres underway by Big Sur Land Trust. Submitting for Prop. 1 grant funds. Permit Attachment H Qualifying Retrofit Project Type/Performance Goal: (1) Floodplain Acquisition and (2) Aquatic and riparian habitat enhancement projects. Acquisition of 5 acres of floodplain, currently zoned for development, and rezone to prohibit L-8
future development. The City’s intent is to far exceed the performance goals since part of the anticipated Project is to restore wetlands for stormwater treatment in Carr Lake that would treat runoff from 100 square miles or over 4 times the total 23.2 square miles currently within the City limits. Project Ranking by Anticipated Beneficial Impact: 1 Smaller projects which treat smaller volumes of runoff (i.e. Skyway Roundabout) are normally easier to fund and construct in a short amount of time versus larger projects (i.e. Carr Lake) due to reduced complexities. That is why a smaller project with less benefit was completed prior to larger projects with more benefit. The City of Salinas procedure for identifying potential retrofit projects with the purpose of restoring degraded watershed processes affected by urban stormwater discharges to protect water quality was as follows: 1. Review CIP (Capital Improvement Project) list for suitable projects which could meet the Attachment H Performance goals for the type of project and based on the criteria contained in L.2.a. 2. Determine which suitable projects will be done first in the queue of CIP projects (often determined through input by the City Council/City Manager). 3. Ensure that at least 1 project design schedule meets the 60% design criteria of L.2.c.iii for Permit year 5. 4. Ensure that ranking of projects meets the requirements of L.2.b.ii (Occurs year 5 with long-term retrofit plan). Preliminary ranking is based on total area retrofitted and level of potential beneficial impacts on water quality in the subwatershed it is located in and will be verified. Projects which treat the most storm water are ranked the highest. 5. Consider Priority Projects that qualify for the in-lieu fee compliance alternative for the list (none at this time). 6. Make sure design completed before the creation of the long-term retrofit plan follows the same protocols as Priority Development Projects for operation and maintenance plan development and maintenance protocols. The Permit requirement is to have one of the retrofit projects at 60% design level by year 5. The City has complied with and exceeded this requirement. Currently one retrofit project has been completed (Skyway Roundabout) and one will begin shortly (El Dorado Park). The 3 others (66” SD shunt, Carr Lake and Boronda Road Widening) are currently in design (66” SD Shunt/Boronda Road) or land acquisition (Carr Lake) and expected to meet and/or exceed the Attachment H performance goals. L.4.c - Aligning Stormwater Management with Related Planning Goals and Requirements- Following are revisions made to the City of Salinas Subdivision Ordinance related to stormwater in year 4 of the Permit: The City of Salinas Subdivision Ordinance (Chapter 31 of the Municipal Code) was updated to include City of Salinas Standard Specifications, Design Standards and Standard Plans, 2008 edition as Appendix A and City of Salinas Stormwater Standard Plans (adopted by the Salinas City Council per Resolution No. 20529 on April 8, 2015) as Appendix B. The following was added to Sec. 31-307.2 Notification Procedures (b)(2) requiring 10-day notice of hearing “…agencies include the Central Coast Regional Water Quality Control Board to confirm interpretation of NPDES permit regulations, as applicable;” L-9
The following was added to Sec. 31-401.3 Form and contents of tentative maps (k)(5): The width and location of the 100-foot setback required from riparian and wetland habitat in accordance with Section 37.180(h) of the Zoning Code “and City NPDES Permit requirements.” The following was added to Sec. 31-401.3 Form and contents of tentative maps (l)(4): The map shall show the approximate finished grading of each lot, the preliminary design of all grading, the elevation of proposed building pads, the top and toe of cut and fill slopes to scale, retaining walls as required, and the number of each lot “and the general layout of post-construction best practice management features to address storm water development standards with applicable easements; the development also requires a Preliminary Storm Water Control Plan (PSWCP)”; The following was added to Sec. 31-401.3 Form and contents of tentative maps (l)(10): “…include stormwater facilities to address City SWDSD and NPDES requirements.” The following was added to Sec. 31-401.4 Accompanying data and reports (b) Soils report (2): “The report is required to identify permeable soils to address NPDES requirements.” The following was added to Sec. 31-401.10 Required findings (h): “Storm drainage discharges must meet the city’s NPDES permit and SWDS at the time of Council consideration.” The following was added to Sec. 31-402.5 Other required submittals (f) Deeds for off-site easements or rights-of-way “…SWDS/NPDES/CBMF features…” or other purposes… The following was added to Sec. 31-704.a (CC&Rs) Ongoing Maintenance “…and other common area facilities “, and maintenance to meet NPDES/SWDS e.g. pavement sweeping and trash management”. The following was added to Sec. 31-902.3. Stormwater drainage and water detention/retention basins. “Stormwater detention and retention basins shall be dedicated to the City in fee unless otherwise approved by the city engineer.” The following was added to Sec. 31-903.7. Streets and Thoroughfares-Street pattern. “Street design emphasizes complete, green streets that accommodate all transportation modes that are sustainable, and meet City NPDES permit requirements.” The following was added to Sec. 31-1000.1. Form and content. “(k) The final form of all plans shall specifically include typical cross sections and proposed final finished grades of all roads and streets in the subdivision together with a profile showing the relation between the finished grade and existing elevations; proposed length, size and slope of any drainage pipes and culverts or structures necessary for drainage, erosion control or to insure public safety; elevations which shall be referenced to United States Geological Survey or other method approved by the City.”
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L.4.c.i - Salinas Participation in the Salinas Valley Integrated Regional Water Management (IRWM) Process The City of Salinas participated in the following Greater Monterey County Integrated Regional Water Management Program meetings during Permit year 4 with the following results: Meetings attended: 5/20, 8/19, 9/17, 11/16, 12/16, 2/17, 3/16 Results: The City in conjunction with its Pure Water Monterey principal partner, the Monterey Regional Water Pollution Control Agency, led discussions at the Greater Monterey County Integrated Regional Water Management Program meetings on meeting long-term water needs for the region. Among other projects, Salinas led the discussion on development of a water reclamation-water Pure Water Monterey reuse project that includes stormwater capture and reuse. It was decided Pure Water Monterey group would prepare a SWRP covering the area related to Pure Water Monterey in order to apply for Round 1 Storm Water Implementation Grant funds and the Greater Monterey County Integrated Regional Water Management Program would then use that SWRP to build upon and create their own comprehensive SWRP.
L.4.c.ii - Opportunities Examined by Permittee and IRWM for Stormwater Capture, Re-use and Infiltration for Aquifer Re-charge. The City of Salinas has participated in the IRWM but has also been one of the major contributors to the Pure Water Monterey Project. The project currently being considered will require 4,321 acre-feet per year of source water and provide 3,500 acre-feet per year of purified water.
The Pure Water Monterey Project shows benefits of cooperation as illustrated in a recent guest commentary in the Monterey Herald newspaper: By Dave Stoldt and Paul Sciuto, Guest commentary/Monterey Herald 05/21/16 L-11
With the close of the rainy season, the residents and businesses of Monterey County have breathed a small collective sigh of relief that the effects of four years of extreme drought have been mitigated ever so slightly. That relief could be short-lived, however, as it will take three consecutive years of above-average rainfall to return our region to its previous water levels. In addition, the deadline for the State Water Resources Control Board’s cease and desist order is only seven months away, and with that the specter of fines and rationing due to California American Water’s overpumping of the Carmel River are very real possibilities. The state has demanded progress on a replacement water supply and we are happy to report that important milestones have been reached allowing Pure Water Monterey (PWM) to continue its mission to bring a safe, sustainable and economically responsible water supply to Monterey County. The guest commentary goes on to state: The wide-ranging support for Pure Water Monterey can be found in our multiple project partners including the county of Monterey, the city of Salinas and the Marina Coast Water District, as well as project proponents the Monterey Regional Water Pollution Control Agency (MRWPCA) and the Monterey Peninsula Water Management District (MPWMD). The project is now completely under design and early examination shows a number of areas where costs can be reduced. This reduction in component costs equals greater savings to local ratepayers, a goal that Pure Water Monterey is extremely sensitive to and one that is a focus every step of the way. Currently, support for this project at the local, state and federal level is strong. Supporting groups and elected officials include Rep. Sam Farr, the Sierra Club, Sen. Dianne Feinstein, Sen. Barbara Boxer, the Surfrider Foundation, Assemblymember Mark Stone, the Monterey Business Coalition, Landwatch, state Sen. Bill Monning, the Monterey Peninsula Regional Water Authority and State Water Resources Control Board, as well as dozens of other public agencies and elected officials. Pure Water Monterey is more than just a water supply or water treatment project. It is a testimony to the cooperative nature of two distinct but equally important regions of Monterey County: the Salinas Valley and the Monterey Peninsula. Pure Water Monterey will play a significant role in providing a safe, diversified water portfolio to ensure we have a reliable and environmental friendly water supply into the future. Dave Stoldt is general manager of the Monterey Peninsula Water Management District. Paul Sciuto is general manager of the Monterey Regional Water Pollution Control Age
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Project Benefits for Pure Water Monterey participating agencies are anticipated as follows: Agriculture Industry & Monterey County Water Resources Agency (MCWRA) All tertiary treated wastewater is committed to the Castroville Seawater Intrusion Project (CSIP) Reduces groundwater pumping by over 2000 acre feet per year Creates additional water in the winter by reducing stormwater runoff into the ocean Treats impaired agricultural surface waters Reduces future capital improvement project costs Builds a drought reserve Shares water rights acquisition costs Improves water quality of the Salinas Valley Basin Monterey Regional Water Pollution Control Agency (MRWPCA) Receives priority additional incremental new source water Allows agency to pursue additional sources on behalf of all stakeholders Reduces discharge to the Monterey Bay National Marine Sanctuary Diversifies water supply options increasing reliability and security Shares capital costs of facilities and water rights acquisition Addresses Monterey Peninsula Areas of Special Biological Significance (ASBS) stormwater runoff concerns City of Salinas Addresses stormwater permitting issues Creates source of recycled water from Ag Wash Water (water used to wash bagged vegetables) Secures new economic development opportunities within city Reduces water and wastewater rates to industrial and agricultural customers Improves emergency sewage by-pass operations at no cost Marina Coast Water District (MCWD) Utilizes existing pipeline infrastructure Monetizes investment potentially reducing customer investment Allows for stormwater diversion Monterey Peninsula Water Management District (MPWMD) Creates up to 3500 acre feet of water for Monterey Peninsula Reduces stormwater runoff into Monterey Bay National Marine Sanctuary Allows for smaller components of Monterey Peninsula Water Supply Project Smaller carbon footprint and significantly less environmental impact than desalination Reduces discharge into the Monterey Bay ASBS Improves the water quality in the Seaside Groundwater Basin Combats seawater intrusion in the Seaside Groundwater Basin
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Specific projects being proposed by MRWPCA/City of Salinas in Pure Water Monterey related to stormwater include:
66” Salinas River Storm Drain Outfall Diversion/Re-use-The City is planning to divert the flow from the 66” storm drain, which drains approximately 30% of the City to the Salinas River, to the Industrial Waste Treatment Plant site where it can then infiltrate in the existing ponds and also be pumped back to the Hitchcock Pump Station and diverted to the MRWPCA plant during the winter when the agricultural wash L-14
water flows are reduced due to agriculture moving most of their operations to Yuma, AZ. The intent is to catch all of the first flush and divert it as well as additional winter flows as capacity will allow. Davis Road Reclamation Ditch Diversion-The City is planning to divert the first flush/dry-weather flows from the existing Reclamation Ditch at the westerly limit of the City to the existing sanitary sewer trunk line in Davis Road which then flows to the Hitchcock Road Pump Station and to the MRWPCA treatment plant. As water conservation has taken been successful, sanitary sewer flows have been reduced providing capacity in existing sanitary sewer trunk lines for stormwater diversions. The intent is to divert as much first flush/dry-weather flows as allowed by existing pipelines. The proposed location for the diversion is at a point in the Reclamation Ditch watershed which drains approximately 100 of the 157 acre total watershed. Carr Lake-The City, currently working with the Big Sur Land Trust, is acquiring 72+/- acres of the 500+/acre Carr Lake, a currently intermittently inundated lake bed that has been drained by the Reclamation Ditch since the 1920’s. The City’s vision is to acquire most, if not all, of Carr Lake. Part of the City’s intent is to restore natural wetlands which once existed within Carr Lake to facilitate groundwater recharge, infiltration and improve water quality through the use of beneficial wetlands for treatment of existing runoff. Funding for land acquisition is part of the Prop. 1 funds the City is requesting.
L.4.c.iii & iv - Salt and Nutrient Management Plan(s). Monterey County has rejected pursuit of grant funds to prepare a Salt and Nutrient Management Plan. In lieu of preparing a salt and nutrient management plan, the City has participated in the Pure Water Monterey Project which has the effect of providing sources of water for the MRWPCA Castroville Seawater Intrusion Project (CSIP) and Aquifer Storage and Recovery (ASR) project for the City of Seaside. Per the Pure Water Monterey EIR Section 4.10.3.3, for the Salinas Valley Groundwater Basin, which is part of the Greater Monterey County IRWM region, the Central Coast RWQCB is currently conducting a study that is assessing salt and nutrient surface and groundwater levels, sources, and pathways in the lower Salinas River and Reclamation Ditch watersheds under a grant from the EPA. This work will include development of a simplified salt and nutrient groundwater/surface water model of the lower Salinas River watershed and groundwater basins. The study is intended to support development of salt-related Total Maximum Daily Loads (TMDLs) and regional SNMPs. The Proposed Pure Water Project will be considered in this study as a potential future condition that would interact with the Salinas Valley Groundwater Basin. The study may provide additional data and information to support future management decisions related to use of recycled water. L.4.c.v - Identifying Areas in the Permit Coverage Area for Groundwater Recharge, Stormwater Management and the Location of Resources That Are Used for Groundwater Recharge and Stormwater Management. Please refer to Figure Q.3.5 on the following page titled “Potential Stormwater Recharge and Management Areas”. The figure delineates the surface soils ability to infiltrate stormwater runoff to underlying strata based on typical characteristics of National Resource Conservation Service hydrologic soils groups and contains the locations of existing stormwater detention/retention ponds operated and maintained by the City. Retention ponds hold stormwater runoff and infiltrate/evapotranspire the pond volume and do not release the design storm volume. Detention ponds hold the design pond volume meter the release of the stormwater runoff entering the pond for at a rate not exceeding the pre-existing rate of the site.
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Figure Q.3.5
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The exhibit also shows historical lake/”swamps” within or adjacent to the City of Salinas which are inundated during the rainy season once the capacity of downstream creeks/ditches/culverts have been reached and the underlying ground has been saturated to the point of the flow into the area exceeding the in situ infiltration rate. Carr Lake has been identified as an area suitable for groundwater recharge and stormwater management. It is also a historic wetlands that cleaned and detained stormwater runoff from the Reclamation Ditch watershed until the Reclamation Ditch was built in the early 1900’s and the Lake was drained and graded to facilitate raising agricultural rows crops. It is the City’s intent to acquire Carr Lake and restore natural watershed processes which pre-existed the current agricultural use as part of a multi-function project. The Carr Lake Project has also been included in the City MRWPCA Prop. 1 funding grant for land acquisition and is one of the City’s target retrofit projects under its Retrofit Plan detailed earlier in this section (L.2.b.iiii.- Retrofit Existing Development-Project 5-Carr Lake). The north of Boronda Future Growth Area will be required by the City of Salinas to provide site/parcel based Post-Construction Best Management Practices (PCBMPs) to the Maximum Extent Practicable (MEP). The PCBMPs will be supplemented by detention/retention ponds located along Gabilan and Natividad Creeks to enhance groundwater re-charge. These ponds will be located in the area best suited for infiltration (along both creeks). The ponds will restore watershed processes for base flow and groundwater re-charge and will be landscaped in a manner to promote water quality through filtering. Please see the following City of Salinas Stormwater Standard Plan No. 24 for an example of how the ponds will be constructed.
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Provision M: Public Education and Public Involvement Introduction Salinas’ goal with Public Education and Involvement is to promote changes in behavior through increased knowledge that leads to greater responsibility and enhanced protection of local water resources. Salinas intends to achieve this goal through three principal strategies: First, implement and promote an integrated, watershed systems approach to address water quality, pursuing water quality protection through effective watershed management. Second, educate the public about local natural water systems, the urban communities in which they live and how their actions impact water quality thus affecting their quality of life. Third, seek active education and outreach partnerships and collaborations in promoting watershed health. M.2 – Collaboration The City continued to reach-out to stakeholder partners to develop and expand programs. The City continues collaborative efforts with on-going participation with the Greater Monterey County Integrated Regional Water Management Group (IRWM). Salinas continues to pursue stormwater capture and reuse as part of the multimillion-dollar Pure Water Monterey project. The City is collaboratively designing the project with the Monterey Regional Water Pollution Control Agency (MRWPCA) and will be pursuing Proposition 1 grant monies to supplement development of a project that will provide a clean, safe, and sustainable source of water for Monterey County. Among other collaborations, Salinas continued to participate in outreach programs with the Monterey Peninsula Stormwater Education Alliance (SEA)/Monterey Regional Storm Water Management Program (MRSWMP), the Salinas Valley Solid Waste Authority (SVSWA), Republic Services, CalRecycle, California Natural Resources Agency, California State University Monterey Bay (CSUMB), local school districts, retail stores and local residents. M.3 – Priority Stormwater Issues In Year 2, Salinas identified six stormwater issues as High Priority. Three were identified for residential and three for the business community: Residential: 1) Trash/Litter, 2) Garden and pet care, 3) Home auto repair Business Community: 1) Trash/Litter, 2) Construction site debris, 3) gas, oil and grease.
Based upon the results of a community-based social marketing campaign (“Community-based Social Marketing to Reduce Bulk Waste”, located in Appendix M), Salinas modified its residential High Priority storm water issues. Home auto repair activities were determined to not be a significant source of water pollution and was therefore dropped. Salinas replaced this activity with residential garden activities (urban pesticide/ fertilizer use). M.4 – Target Audiences Residential Target Audiences: 1) School children: School children remain the priority audience. Results of the in-school education program are included in Appendix M. 2) Residents who live in “high-priority areas” that pose a potential threat to 303(d) listed waterbodies:
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The High Priority residential areas were redefined in Year 4. A map of these areas is included in Appendix G. Residential BMPs for gardening activities and pet care were developed this year. These can be found on the City’s website. 3) Residents who may be disenfranchised from mainstream media through language or other barriers. Criteria: Audiences were identified by the Priority Stormwater issue selected, and by geographic area. For example, bulky waste was identified this year as a target pollutant and residents who live in areas where bulky waste has been most challenging was identified as a target audience. See M.7 CBSM for details on bulky waste program. Commercial Target Audiences: 4) For Litter: grocery stores/convenience food stores products) and food-to-go businesses, especially problem products. 5) For Construction Site Debris: All land development actions, including construction site management professionals and city staff (Engineering, Planning). 6) For gas, oil and grease: Auto mechanical repair, auto body shops and commercial food service providers. In 2015-2016, Salinas continued to implement programs around these target audiences. Later sections in the report provide details. M.5 – Outcomes In general, educational programs are designed and developed to be implemented iteratively. That is, program results drive program adjustments. Programs are designed, implemented, reviewed and results measured where feasible. The city has moved towards outcomes-based programming and away from an output-based approach. This approach is discussed a bit more later. That said, quantifying change in a social science is not always possible due to the nature of the field. However, concerted attempts are made to determine effectiveness when practicable and make improvements. In many cases assessments are program specific. Principal education programs are designed to have metrics. For example, in-school education remains a principal audience market. Student knowledge is measured via a survey a week or more prior to lessons being conducted and again after. Results drive program adjustments. A copy of the survey is provided in Appendix M. Results from the expanded in-class education program have been positive. Students in grades 3-6 showed an increase in their knowledge of basic watershed principles and their affects upon receiving water. Results from school programs are contained within the discussion on in-school education. This year Salinas expanded and refined its classroom program to nearly 50 classes (49 classrooms). New teaching materials and two additional teachers were trained. Planning is underway to expand the in-school education program next year. Another example of a designed-in outcomes-based programming is Salinas’ principal targeted pollutant (litter/ bulky waste). Litter abatement continues to be a focus. Last year Salinas conducted a CBSM program regarding abating litter in parks. This year, the City conducted follow-up measurements. Based upon positive results, the city determined that success of the pilot program warranted expansion. This year, Salinas expanded the program from the one pilot park site to over a dozen other parks. Further discussion of this year’s CBSM program is summarized in M.7. In addition to program specific metrics, this year Salinas also conducted efforts to further assess community knowledge, values and behaviors. Information will be used to establish benchmarks and determine quantifiable change. M-2
M.6 – Assessment Over the course of the permit, Salinas has conducted project assessments to determine project effectiveness. This includes the City’s in-school education, CBSM and other projects. This year, Salinas expanded its assessments to include an extensive assessment of community behavior, values and knowledge. The survey has 95% level of confidence, with a 5% margin of error. Results from this telephone survey are discussed below; the survey report is included in Appendix M. Survey results will guide next year’s program and further quantifiably measure program effectiveness. As one might expect program effectiveness varies from activity to activity. Some programs have been largely successful, others to a lesser extent. The City’s program is iterative in that results drive program changes. In terms of results, past City’s programs to eliminate problem products (carry-out food polystyrene and plastic bags) have proven successful. Styrofoam cups and plates have been drastically reduced to almost eliminated from food-to-go establishments. Due to the City’s plastic bag ban, single-use plastic bags have been substantially reduced from stores and streets. Positive results from these two programs continue. Voluntary projects have also had success in growing knowledge. Voluntary programs typically take more time to root and grow than regulatory ones (ex: plastic bag ban). In school education programs have shown success in growing understanding and awareness. In-school education continues to be a key program because classroom settings offer a formal place of learning, a captive audience and children once educated employ key learning into life-long habits. In addition, children are seen as an “education bridge” between the broad English-speaking community and the Spanish-speaking community (target audience) of their parents and families. Results from this year’s in-school program indicate the need to revise the assessment survey. Its length and wording have made it difficult for students to use. It will be revised in Year 5. That notwithstanding, the program continues to receive high marks from teachers and students. One-hundred percent of students demonstrated an increase in stormwater knowledge. Measuring effectiveness includes conducting an assessment several days prior to the lesson and giving a post-class assessment on the day of the lesson. Results showed a significant improvement with most students’ scores reflecting a doubling of the number of correct scores. Older students in grades five and six showed the greatest growth. Results from these assessments are being used to tailor future program improvements. The education component of the commercial and industrial inspection program continues to be effective. During the inspections, businesses are provided a review of required BMPs and any outreach materials the City has developed to support compliance from businesses. Businesses that achieve a “C” or less were rescheduled for a follow-up inspection. Changes were confirmed on-site. All businesses showed an increased knowledge and change in behavior and achieved full compliance with City BMPs either during the inspection or after the first follow-up visit by City staff. Salinas participates in a multi-media advertising collaboration with the Monterey Peninsula/Santa Cruz communities (~$3500/yr for Salinas). Measurement of the effectiveness of this collaboration has taken more time to determine effectiveness via outcomes. While past outputs have been impressive (nearly 2 million in gross impressions), questions regarding their effectiveness remained. Effectiveness results for the other MS4s included in the media collaboration are included in their Annual Reports. Results from a telephone survey of 400 people in Salinas indicate there is more work to be done.
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The stormwater media campaign has focused on basic stormwater information, e.g. stormwater flows downstream untreated, using the fun “rubber ducky” video created by San Diego. The City has employed the message from San Diego’s Think Blue innovative “Rubber Ducky” video in television and movie theater advertisements individually and in partnership with Monterey Regional. While the number of gross impressions from prior and recent past years has revealed that a lot of people are hearing messages, the message may not be effectively conveyed to the disenfranchised target audiences in Salinas. Results from the telephone survey revealed several interesting points. One is that 71% understand that storm water and sanitary sewer water are different, yet most don’t understand the difference. Key findings of the survey are shown below. Full results are available in the report in Appendix M. Results will be used this year as a benchmark to refine next year’s program. The survey was conducted to determine people’s behavior and awareness. Awareness and understanding are generally more revealing than the behavioral aspects. Here are a few key findings: 1. Regardless of language, the vast majority of residents rely on television to get information. There is a large disparity in getting news online, with English speakers far more likely to seek out online sources. 2. In the opinion of those surveyed, drought was the most important environmental issue facing Salinas. 3. Most residents have a basic understanding of what stormwater is, but the majority do not understand more detailed information, such as what the main pollutants are or whether or not stormwater is treated. 4. Many residents care for their own yard. 5. Dog owners regularly clean up their pet waste from public areas and dispose of it in the trash. 6. Very few residents change their own oil. Among those that do, most report regularly cleaning up spills and using drip pans. 7. Only a quarter of residents recall hearing recently about stormwater pollution in Salinas. 8. Younger residents and white residents are more likely to have heard a stormwater message. One potential reason for the inconsistency between having a high number of gross impressions yet inadequate understanding is that Salinas, the Monterey Peninsula and Santa Cruz share media markets, but they don’t share demographics. Stations popular in one area are not so in another. Watsonville in Santa Cruz County may be closest to sharing culture and demographics with Salinas. Results of the collaborative multi-media campaign in Salinas have been unclear. Number of gross impressions were promising, but whether changes occurred due to this media effort still remains to be determined. This year, the telephone survey revealed a sample of the Salinas community’s behavior, understanding and awareness. Salinas will continue to review results of this survey, increase sampling size to better represent the City population and discuss the survey results with its media partners. Below are the collaborative media campaign results from two partnership programs:
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Results from Partner Program #1--Monterey Region Stormwater Program: Bilingual TV Ad Campaign for 2015-2016
The regional campaign aired four bilingual storm water public service announcements (PSA) on the major television stations. The regional partnership was comprised of the following entities: Cities of Monterey, Carmel-by-the-Sea, Del Rey Oaks, Pacific Grove, Sand City, Seaside, Watsonville, Salinas, Santa Cruz, Capitola, Scotts Valley and the Counties of Santa Cruz and Monterey. The four PSA topics included: Fowl Water (about urban runoff sources), Storm Drains, Dog Doo, and Marine Litter. The Fowl Water PSA (in English and Spanish) can be viewed on the Monterey Regional Storm Water Management Program website: http://montereysea.org/take-action/ January 11, 2016-May 29, 2016 Bilingual TV Ads Station
Purchased Ads Per Station
Bonus Ads
Total Ads Bonus and Purchased
Gross Impressions
KMUV (Spanish)
227
75
302
828,000
FOX-KCBA
117
---
117
185,100
CW-NION
170
100
270
178,000
CBS-KION
127
61
188
724,000
TOTALS:
641
236
877
1,915,100
Results: 1. A total of 877 ads aired on four stations. Of those ads, 236 were bonus ads donated by the stations for the campaign. 2. KMUV (Telemundo-Spanish station) aired 302 ads. 3. The remaining three English language stations aired a combined total of 575 ads. The total Gross Impressions for the 877 ads equals 1,915,100. Evaluation: The funding was divided equally between the Spanish station and the combined English stations so that it was a 50/50 split of the budget. We purchased fewer, but more expensive ads on KMUV (Spanish station) in order to be in the prime time range when the Spanish soap opera aired in the evening. According to the station agent, their metrics have shown that during this time often the family (of all ages) will watch this program together. There are a total of 221,910 television households in Santa Cruz, Monterey and San Benito counties. Broadcast television is the only way to reach 100% of the TV households. Cable outlets reach only about 44% of TV households, and are shrinking each year. Broadcast TV is still the most consumed form of media on a daily basis. Announcements aired on Broadcast TV have a higher consumer retention due to shorter pod lengths. A pod is a cluster of commercials that air together. The regional TV investment continues to be one of the most cost-effective methods (with our partners) to reach the general public with storm water pollution prevention messages. M-5
Station Broadcast Updates: The News-Press Gazette (NPG) Broadcasting company is the owner of KION (CBS 46), The CW (NION The Central Coast CW), and KMUV (Telemundo 23). NPG has a local focus in the news coverage due to the separation of the Salinas/Monterey market and the Santa Maria market. The marketing and branding campaign for KION was revised for local news coverage for the Salinas, Santa Cruz and Monterey areas. One of the most significant areas of growth for CBS is the “CBS morning show” airing from 7A-9A. The show had the greatest viewer growth (up 16%) compared to Good Morning America (ABC) and Today (NBC). The uptick in viewers trickled down to the local morning news on KION. The morning news “Wake Up Central Coast,” is providing more useful information for local viewers on topics such as: home, career, and finance, and activities for exploring the central coast area. The CW (NION) Network expanded their demographic target to ages 18-49. CW no longer is tied exclusively to the teen and young adult or “tween” demographics. The program expansion is reaching a slightly older audience with an even distribution between male and female viewers. The KMUV (Telemundo) reaches the Spanish language viewers and has an audience that has remained steady. KMUV has a new competition show “Talento de Telemundo” which searches for the next great local face of Telemundo. This has brought additional attention to the station and the Hispanic community. The KCBA (Fox 35) station is owned by Entravision Communications Corporation. KCBA viewership is divided almost evenly between males and females with females being a larger viewership with 51.1%. The occupation of 33.9% of the viewers is listed as blue collar, followed by white collar workers at 25.6%. The education level of the viewers is as follows: 35.7% are high school graduates, 30% have some college education, and 20.6% have a college degree. Most of the viewers own their home (48.1%) and are employed full-time (41.2%).
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$86,000 Media Campaign Program #2. Central Coast Region Media Group: Focus is Stopping Litter and Reducing General Waste
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M.7 – Education Strategies and Methods: In the past year, consistent with its Permit, Salinas once again conducted a community-based social marketing (CBSM) campaign as part of its education strategies. In addition, Salinas analyzed results of last year’s CBSM Program to determine effectiveness. Last year, the City focused on litter abatement in parks as part of its initial CBSM program. This year, Salinas investigated results of last year’s Pilot Program and conducted an additional Pilot Program as well. As results from the City’s assessment of its Pilot were positive, Salinas expanded its pilot anti-litter park campaign from one park to over a dozen. An example of the campaign message is provided below. Banners like the one below are now installed in all of Salinas’ major parks and in most of the smaller ones. Big parks like Natividad Creek have multiple banners spread across activity areas. Each activity area has a unique banner for it with a unified theme.
Following-up on litter as a pollutant of concern, this year Salinas again studied a form of litter—one of the more pernicious pollutant. Initially, the City began a study on home auto repair—consistent with the City’s initial categorization of target pollutants. However, as researched was performed, home auto repair was determined to not be a pollutant of concern. Bulky waste was chosen as a more appropriate pollutant of concern. The complete 2015-2016 bulky waste pollutant CBSM study can be accessed in Appendix M. This program involved partnering with the Salinas Valley Solid Waste Authority and Republic Services. Through Republic Services, Salinas provides one bulky waste curb-side pick-up per year and six neighborhood drop-off events. Nevertheless, bulky litter continues to be an issue. Contributing factors to bulky waste litter include disposal cost and travel, among other findings. Results of this Pilot Program will be analyzed in the coming weeks and the program expanded as determined warranted.
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M.8 – Development Planning & Stormwater Controls for New Development and Redevelopment Projects: M.8.a – Development Standards Section 2 of the City’s 2013 Stormwater Development Standards (SWDS) was developed and covers all listed areas of concern. Within said section, a Threshold Determination Spreadsheet is made available for use by the developer’s designer to determine the SWDS requirement for the proposed development. The City’s 2013 SWDS are available through the City’s website and are also available at the Permit Center Counter. As part of the City’s Development Review Committee weekly meetings, staff informs the developer and/or applicant of the City’s SWDS requirements for Non-Priority and Priority Development. Information about the City’s SWDS is provided at the Permit Center counter, over the telephone or through e-mail. M.8.b – Design Requirements Section 2 of the City’s 2013 SWDS, outlines requirements 1 to 5. Section 3 of the City’s 2013 SWDS provides guidance to fulfill design requirements. Procedures for sizing BMPs are found in Section 4.0. General guidance for selecting and designing BMPs is in Section 6.0. The City’s 2013 SWDS are available through the City’s website and are also available at the Permit Center Counter. As part of the City’s Development Review Committee weekly meetings, staff informs the developer and/or applicant of the City’s SWDS and reviews strategies to incorporate LID measures. Information about the City’s SWDS is provided at the Permit Center counter, over the telephone and through email. Staff has a BMP Brochure for residential development regarding requirement no. 2 where the net new and/or replaced impervious area is 2,000 sf to 5,000 sf. M.8.c – Conceptual/Preliminary Stormwater Control Plan Section 2.2 of the City’s 2013 SWDS provides information of which SWDS requirement requires a Conceptual/Preliminary Stormwater Control Plan (PSWCP) for all projects subject to Requirements 2 through 5 and a Final Stormwater Control Plan for projects subject to Requirements 3 through 5. Section 2.3 of the City’s 2013 SWDS lists the required information and documentation to be included in both a PSWCP and a Final SWCP. A SWCP Template is also available at the City’s website: http://www.ci.salinas.ca.us/services/engineering/pdf/StormwaterControlPlantemplate.pdf. As part of the City’s Development Review Committee weekly meetings, staff informs the developer and/or applicant of the City’s stormwater control plan requirements. M.8.d – O&M Requirements Section 2.4 of the City’s 2013 SWDS provides information on the Operation & Maintenance (O&M) Plan Requirements. The 2013 SWDS also provides O&M checklists, by BMP, in Appendix K of the SWDS. As part of the building review process, the applicant is informed of the O&M requirements. Additional information, as required, is provided at the Permit Center Counter, over the telephone or via email. M.8.e – Maintenance Declaration Section 2.4.1.1 and Appendix I (Sample Maintenance Declaration) of the City’s 2013 SWDS provide the language which shall be completed and executed by the developer and/or his designee and filed with the Monterey County Recorded prior to issuance of final Certificate of Occupancy for any project. Section 29.15 of the Municipal Code outlines enforcement procedures for LID measures.
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M.8.f – Water Body Setbacks Section 2.3.2 of the City’s 2013 SWDS addresses information on the required water body setbacks per Section L of the NPDES Permit and references Appendix A of said SWDS. Riparian setbacks are also covered in Salinas General Plan COS-17. Section 37-50.130(h)(1) of the Municipal Code outlines the required performance standards for new development adjacent to Riparian/Wetland Habitat. As part of the City’s Development Review Committee weekly meetings, planning and engineering staff inform the developer and/or applicant of setback requirements and possible impacts and constraints to the project. M.8.g – Planning Process Section 1.3 of the City’s 2013 SWDS outlines the planning process for a development. Section 2.2 (Project Requirements) provides the information and documentation that is required for each Requirement Threshold. As part of the City’s Development Review Committee weekly meetings, staff informs the developer and/or applicant of the process for project submittal and plan review. Inquiries about a potential development are addressed at the Permit Center Counter, over the telephone and via email. Projects routed for building permits are reviewed by the Development Engineering staff for compliance with post construction requirements as outlined in the SWDS. Projects requiring a Final SWCP (for Requirement 3, 4 and 5) are sent to the City Stormwater Consultant for review. M.8.h – Construction Requirements The City’s NPDES Permit is incorporated into the City’s 2013 SWDS as Appendix A (in the SWDS). The City’s Grading Ordinance is incorporated in the City’s 2008 Standard Specifications, Design Standards and Standard Plans. Said document also provides Standard Plans 58 (Slope Grading), 59A (Best Management Practices) & 59B (Concrete Waste Washout Management Plan). The document is available online and at the City’s Permit Center counter and at the Public Works Engineering and Transportation Department. City staff refers developers and their design professionals to the state’s website where the Construction General Permit is available. A copy is also available at the Permit Center Counter. City staff refers developers and their design professionals to the state’s website where the CALTRANS Construction Site BMP Manual is available. A copy is also available at the Permit Center Counter. The 2015 CASQA Construction Handbook is available for review at the Permit Center Counter. Any development adjacent to watersheds is reviewed by Planning staff for CEQA compliance and routed to applicable government agencies per Municipal Code Section 37-50.130(h)(1)(g). City of Salinas staff has developed the requirements, regulations and standards to satisfy the requirements of the MS4 Permit. Documents are available for review and design assistance at the Permit Center Counter and online. Further, staff has developed an Erosion and Sediment Control Checklist for applicants/designers to fully understand and address the required construction best management practices. Staff continues to educate the public on the SWDS, the thresholds for design requirements, LID strategies and design tools for achieving flow control and treatment control, the development of a Stormwater Control Plan, the preparation and implementation of Operation and Maintenance Plans, water body setbacks, governing rules, and regulations. Most local developers and design professionals are aware of the SWDS requirements and continue to better comprehend the requirements as the projects are submitted through the planning and building plan check process. The professional design community generally understand and comply with the stormwater requirements. Unlicensed designers, on the other hand, have not demonstrated a comprehensive understanding of the stormwater requirements and opt to not implement stormwater measures until required M-10
through plan check. Staff will continue to work directly with this specific group to accomplish compliance of the NPDES Permit. Further, staff has had mixed success with educating public schools with the City’s NPDES Permit and stormwater requirements. Public schools continue to bypass the city in construction indicating that the projects are reviewed at the State Architect’s Office (DSA) and not subject to city code. This information has been documented in previous Stormwater Permit Audits, and most recently in our meeting this May. Examples of a successful Planning Permit process and a successful Building Plan review process are located in Appendix M. Guidance is provided to project applicants took many forms depending upon the level of knowledge of the applicant, the type of project, complexity of the project and when in the project design process, the designer contacted the City. Following are descriptions of each guidance tool, who received the guidance and when in the process they received the guidance and guidance effectiveness: 1. Brochures- The City has several different brochures it provided to applicants depending on the inquiry (see next page for examples). For those interested in a site development project a general LID brochure (available in both English and Spanish) can be provided by either the initial planner the applicant meets with or a Permit Center (PC) engineer if the planner immediately refers applicants to an engineer. PC engineers will provide the appropriate brochure to the applicant if a planner has not already. For those who contact Planning for a simple car wash or some similar function to see if, and what type of, permits are required, we have brochures similar to the second brochure on the following page. For those that contact a planner to determine what the process is for reducing lawns or removing a pool, especially pertinent for the current drought, we have the third brochure (In Appendix M). The majority who receive the brochures are home/property owner applicants, design professionals representing the home/property owner as the applicant or contractors investigating what requirements they may need for a project. They receive the brochures normally on first contact with the Salinas Permit Center. They can also receive the brochures from the PC engineer upon review of projects for building permit projects which do not need to go through the planning process. As a side note the City Commercial/Industrial inspectors also utilize the brochures if deemed educational/informative for their contacts during those inspections. Most of the brochures are available in both English and Spanish. Effectiveness is difficult to judge on an applicant by applicant basis. Overall the brochures appear to be well received except for two exceptions: those applicants who balk at compliance whether it is to City codes in general or stormwater requirements in specific, and those applicants who insist the City do the compliance work for them. These applicants, in our experience, are either home/property owners who lack sufficient design experience/knowledge or “designers”. The term “designer” is used for unlicensed “design professionals” who have difficulty understanding design complexities that licensed professionals do. 2. Workshops- Workshops, when provided by the City, are normally held independent of the review process. Workshops are designed to inform licensed design professionals of Permit requirements. The City advises applicants who are not design professionals to obtain the services of a licensed design professional for more complicated projects. The City judged interest from the local engineering M-11
community the past Permit year through the American Public Works Association-Monterey Bay Chapter e-mail blast to members. The members were queried as to whether or not they would be interested in a free seminar on City of Salinas SWDS, and if so, to send the City an e-mail expressing interest and how many would attend if held. We received 2 e-mails of interest for 3 attendees. Most local engineers have been through the approval process so they appeared not to be interested. Those who responded are 2 firms the City would use to supplement staff for Permit compliance and would not be submitting applications on behalf of a client. The City decided it would be better to do individual training through the review/permitting process for all including local firms who may not have been through the process plus out of the area firms.
Salinas Stormwater Development Standards (SWDS) and Stormwater Standard Plans (SWSPs)
3. Manuals- The City has provided all applicants with the link to the City’s SWDS, Stormwater Standard Plans (SWSPs) through the City’s website or through brochures or face to face meetings early in the permit application process, either early in the planning process or early in the building permit process if the project is exempt from planning review/approval. The SWDS manual contains a Threshold Determination and Design Spreadsheet TDDS to assist applicants in determining the requirements that apply to their specific project through entering pertinent data on existing site surface status and proposed changes to the site surface. If an applicant has questions on the use of the TDDS, the applicants are directed to the City’s Stormwater consultant Michael Baker Inc., who will help them through the process free of charge. This also applies to review of the preliminary (conceptual) and final stormwater control plans and assistance in their preparation. This procedure maintains consistency from applicant to applicant. City staff will advise applicants on ways of improving their sites with pervious materials in the interest of being under the minimum design threshold (2,000 s.f. net new/replaced impervious area). The SWSPs are provided along with the SWDS to assist the applicants with conforming to the Permit. The SWSPs provide applicants with guidance on how PCBMPs and related improvements are to be constructed and also contain guidance on green streets. This process appears effective since it has been the City’s M-12
experience all applicants that go through this process become familiar with the SWDS and require minimal assistance upon subsequent project submittal/review processes. 4. Face to Face Meetings Including Phone Conferences- The City holds face to face meetings and/or phone conferences with applicants when requested by the applicant or as a result of referral by planning to answer any questions they may have regarding the permit approval process/Permit requirements. These occur early in the process (prior to application submittal) when the City is provided the opportunity by the applicant and the City encourages this. This opportunity is not always provided to the City as some applicants/design professionals do not do their research into the City’s requirements prior to producing a preliminary design and submitting an application. 5. The City’s effort to gain compliance is made more difficult with this process. Normally the design professional in these cases is reluctant to make the required changes since their design fee does not normally include revisions of a significant scale in order to be low bidder on the design process and retained by the developer/property owner. This normally occurs with out of area engineers and “designers”. However, once the review process has been completed, these applicants are well versed on how not to approach a project and the value of contacting the City early before designing a project. This process appears effective since it has been the City’s experience most applicants that go through this process become familiar with the SWDS and require minimal assistance upon subsequent project submittal/review processes. with the link to the City’s SWDS, Stormwater Standard Plans (SWSPs) through the City’s website or through brochures or face to face meetings early in the permit application process, either early in the planning process or early in the building permit process if the project is exempt from planning review/approval. The SWDS manual contains a Threshold Determination and Design Spreadsheet TDDS to assist applicants in determining the requirements that apply to their specific project through entering pertinent data on existing site surface status and proposed changes to the site surface. If an applicant has questions on the use of the TDDS, the applicants are directed to the City’s Stormwater consultant Michael Baker Inc., who will help them through the process free of charge. This also applies to review of the preliminary (conceptual) and final stormwater control plans and assistance in their preparation. This procedure maintains consistency from applicant to applicant. City staff will advise applicants on ways of improving their sites with pervious materials in the interest of being under the minimum design threshold (2,000 s.f. net new/replaced impervious area). The SWSPs are provided along with the SWDS to assist the applicants with conforming to the Permit. The SWSPs provide applicants with guidance on how PCBMPs and related improvements are to be constructed and also contain guidance on green streets. This process appears effective since it has been the City’s experience all applicants that go through this process become familiar with the SWDS and require minimal assistance upon subsequent project submittal/review processes. 6. Face to Face Meetings Including Phone Conferences- The City holds face to face meetings and/or phone conferences with applicants when requested by the applicant or as a result of referral by planning to answer any questions they may have regarding the permit approval process/Permit requirements. These occur early in the process (prior to application submittal) when the City is provided the opportunity by the applicant and the City encourages this. This opportunity is not always provided to the City as some applicants/design professionals do not do their research into the City’s requirements prior to producing a preliminary design and submitting an application. M-13
The City’s effort to gain compliance is made more difficult with this process. Normally the design professional in these cases is reluctant to make the required changes since their design fee does not normally include revisions of a significant scale in order to be low bidder on the design process and retained by the developer/property owner. This normally occurs with out of area engineers and “designers”. However, once the review process has been completed, these applicants are well versed on how not to approach a project and the value of contacting the City early before designing a project. This process appears effective since it has been the City’s experience most applicants that go through this process become familiar with the SWDS and require minimal assistance upon subsequent project submittal/review processes. M.9 – Public Involvement: The City’s website provides useful information that invites people to engage and participate in its Urban Watershed Management Program. Further, through their network of work associates through the community, City staff offer and encourage stakeholder collaboration. The City continued to conduct neighborhood public participation sessions called “Take-Part!” that it began last year. In five different neighborhood events, neighborhood residents and businesses were encouraged to participate in a multi-neighborhood program that included urban runoff management features such as reducing the amount of vehicle miles traveled; adding LID features and more street trees; reducing hardscape areas and other aspects to enhance environmental quality. This program included the public in the planning process and will ultimately include them in the implementation process as well. In collaboration with its stakeholder partners, Salinas continued its public engagement involving over 171 volunteer residents in creek/ watershed clean-up activities that included an educational component. Partners included college and high school students, California State University Monterey Bay and local residents. (See Appendix M- Public Involvement for details). The City noticed meetings in its website; conducted direct outreach to interested parties via email and phone call to those on its mailing list; and conducted other outreach efforts via partner activities. The City maintains a list of interested parties based upon various subject areas within the broad category of its Urban Watershed Management Program. While this list is small, a few parties are active and regular attend water board meetings. This year Salinas staff strived to personally and directly reach those residents who have been actively interested in watershed management. Meetings were arranged and conducted to discuss individuals’ ideas for the year. In one case, Salinas staff met with one individual on five to seven occasions to discuss her ideas and protocols. In this example, the result was the City has offered to contribute several hundred dollars to assist with producing a creek fair. This year City staff again conducted neighborhood meetings in specifically selected neighborhoods that represented a broad socio-economic and geographic spectrum of the community. City staff members actively conduct outreach to various sectors of the community to ensure broad representation. For example, her is a representative sample list of the diversity of groups city staff have been contacted: Salinas United Business Association, the United Artist Collaborative, Sustainable Salinas (environmental group), Building Healthy Communities, local property owners, Salinas Valley Memorial Hospital, Santa Rita and Bolsa Knolls Watershed Group, Citizens for a Sustainable Monterey County, the general public through outreach at city libraries, Save Our Shores and others. The City has developed programs that are conducted where residents live as well as at city hall. Litter programs, LID neighborhood designs, creek clean-ups, and in-school education are a few of the programs where public involvement was incorporated. A few of these events are captured in Appendix M. In 2015-2016 several public involvement events were conducted. Over 170 people participated in creek clean-ups, riparian planting, and M-14
other watershed programs—see the appendix for details. In collaboration with CSUMB, Salinas secured a Proposition 84 Habitat Conservation Fund Grant to provide additional nature/watershed educational opportunities. Below are a few examples of the public involvement activities that Salinas encouraged and supported in 20152016:
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City continues to update its website design and content to conduct a multi-faceted outreach program. City staff are known in the community. to encourage participation. In addition, the City listed programs and staff contact names and phones numbers on its Urban Water Management Program web page to make inter-action on stormwater topics convenient. Further, in participation with stakeholders, the City conducted several public workshops on stormwater/watershed management where public participation was emphasized. One such workshop focused on water management of the Gabilan Mountain Watershed. This facilitated workshop brought different interest groups together (agriculture, environmental and urban) to identify priorities and develop consensus-based proposals. The City published a notice in The Californian, the local newspaper, and sent meeting notices to its list of interested parties. The intent of the meeting was to introduce the community to the City’s new Permit, identify key staff, and discuss opportunities for public engagement. M.10 – Website: The City has updated its website for Environmental Resource Management that includes a revised Urban Watershed Management Program (stormwater) web page that meets the requirements of this provision. Additional website improvements will continue through summer of 2016. The webpage can be accessed through the City’s website: http://environmentsalinas.com/urban-watershed-management-program The City’s public involvement process includes two principal tracts: 1) For specific activities that have a start and end date, the City identifies stakeholders and notifies them of the up-coming event and how they can become involved. This is conducted using a multi-media approach based upon the stakeholder, event and timing. This may include public notices via PSAs, and advertisements where appropriate. Further, Salinas will notify people who are on an interested parties list. Lastly, people are notified through public meetings and M-16
networking. An example of this is the Take-Part! program where the City sent notices to people; posted signs in the neighborhood, contacted leaders and used their lists to reach people. For public hearings before the City Council, meetings are noticed in the paper and through other media outlets. 2) In addition to specific projects, the City employs its web site, and its public information outlet through the city clerk’s office to afford the public with an open portal to engage in the public’s business publically. M.11 – Annual Reporting: City of Salinas staff has developed the requirements, regulations and standards to satisfy the MS4 Permit requirements for development planning and stormwater controls for new development and redevelopment projects. Staff continues to educate the public on the SWDS, the thresholds for design requirements, LID strategies and design tools for achieving flow control and treatment control, the development of a Stormwater Control Plan, the preparation and implementation of Operation and Maintenance Plans, water body setbacks, and governing rules and regulations. Staff has also developed an Erosion and Sediment Control (E&SC) Checklist for applicants/designers to understand and address the required construction best management practices. The E&SC Checklist has a summary of the requirements and includes a watershed map of the city to assist and educate applicants of their project proximity and possible impact on City wide water quality. As part of the City’s Development Review Committee weekly meetings and everyday building permit reviews, staff informs the developer and/or applicant of the City’s SWDS requirements for Non-Priority and Priority Development in writing, via telephone, e-mail, or at the Permit Center counter. During the 2015-2016 reporting year, a total of 37 new projects were reviewed during the planning process. The applicants for these projects were provided information regarding the SWDS and methods to achieve compliance with stormwater quality and flow control. Approximately 220 projects were reviewed during the building plan check phase. Applicants and designers were provided the E&SC checklist along with constructive review of the proposed LID measures and SWCPs were reviewed for compliance with permit requirements. Approximately 450 people were provided stormwater compliance information at the counter by plan review or through a brochure. The Stormwater Best Management Practices (BMPs) Brochures outline laws and regulations applicable for water quality and BMP measures for each of the areas below. Automotive Maintenance and Car Care; Equipment Rentals; Food Service Industries; Fresh Concrete and Mortar Application; General Construction and Site Supervision; Heavy Equipment & Earthmoving Activities; Home Repair and Remodeling; Landscaping, Gardening and Pest Control; Mobile Washers and Cleaners; M-17
Painting; Replacing Lawns and Pools and Reconstructing Landscaping; Roadwork and Paving; and, Swimming Pool, Jacuzzi and Fountain Maintenance; and, Stormwater Development Standards (SWDS) Compliance for Single Family Residential Lots City staff provides the brochures to the public via digital or hard copy. Said BMP Brochures are both in English and in Spanish.
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Provision N - Trash Load Reduction N.5.a: Reporting Requirements N.5.a.i: Verification of BMP Implementation The City implemented all designated BMPs at all applicable sites and sources that were required per the City of Salinas-Year 4 Requirements Trash Load Quantification and Trash Load Reduction-Technical Memorandum, May 2016, by Michael Baker Inc. included in Appendix N. The following is an excerpt: “The permit establishes requirements for the City to evaluate and control discharge of trash from the City. It requires the City to implement trash reduction best management practices (BMPs), develop a trash reduction plan, develop a trash reduction tracking methodology, and submit information and the status of trash related efforts in the City annual report. The City has implemented numerous BMPs to reduce the trash discharges to the Municipal Separate Storm Sewer System (MS4). This technical memorandum quantifies the City’s total trash load, presents a methodology to quantify the effectiveness of the City’s trash reduction efforts, and determines the trash load reduction achieved from the BMPs that have been implemented.” N.5.a.ii: Visual Inspection and Abatement Activities 1. See 4 below for the open channels inspected as part of the Trash Load Quantification. All surface drainage structures are inspected in excess of 3 times per year. See 5. below for the priority problem areas which are inspected more than 3 times per year, in exceedance of Permit requirements. The City Parks Division inspected and cleaned up parks, facilities, creek channels and detention basins, where any of these aforementioned areas are located in a park, on a daily basis. Homeless encampments (a majority of which are located in creek areas-see 5. below) were cleaned up when City notified of existence but on a schedule allowed per court order so belongings of each individual can be secured according to law. 2. See 4 below for the dates of all visual monitoring and inspection events. 3. City staff removes all trash and debris the day it is discovered if the site is accessible. The City may take in excess of a day if it is waiting for site conditions to change to allow access. In no instance is trash left more than 14 days unless it is due to a court order/existing law (Homeless (Marginally Housed) Encampment Clean-Up) that prevents the City from removing trash and debris. 4. See Section M “Public Education and Involvement” for a summary of results of visual inspection and cleaning events, including the amount of material removed on an Urban Subwatershed basis through community related clean-up events. The City commissioned the aforementioned report City of Salinas-Year 4 Requirements Trash Load Quantification and Trash Load Reduction-Technical Memorandum, May 2016, by Michael Baker Inc.” which contained the following trash assessments for the calculation of base trash load reduction:
N-1
Rapid Assessment Worksheet Totals and Dates for Dry and Wet Weather
Site 1 - Reclamation Ditch between Market St. and its confluence with Natividad Creek-Urban Subwatershed a. b. c. d. e. f.
9/23/13 Dry Weather- Trash score 82 - 135 pieces above and 93 below Total 228 3/24/14 Wet Weather-Trash score 86 - 70 pieces above and 36 below Total 109 9/17/14 Dry Weather- Trash score 90 - 26 pieces above and 40 below Total 66 3/25/15 Wet Weather-Trash score 112 - 24 pieces above and 20 below Total 44 9/22/15 Dry Weather- Trash score 98 - 66 pieces above and 55 below Total 121 3/17/16 Wet Weather-Trash score 98 – 13 pieces above and 0 below Total 13
Site 2 - Reclamation Ditch between Victor St. and N. Davis Rd a. 9/24/13 Dry Weather- Trash score 89 - 184 pieces above and 124 below Total 304 b. 3/24/14 Wet Weather-Trash score 81 - 167 pieces above and 42 below Total 209 c. 9/17/14 Dry Weather- Trash score 90 - 42 pieces above and 25 below Total 67 d. 3/25/15 Wet Weather- Trash score 101 - 70 pieces above and 7 below Total 77 e. 9/22/15 Dry Weather- Trash score 98 - 16 pieces above and 9 below Total 25 f. 3/17/16 Wet Weather- Trash score 98 – 41 pieces above and 0 below Total 41 Site 3 - Gabilan Creek between Constitution Blvd. and E. Laurel Dr. a. 9/23/13 Dry Weather- Trash score 87 - 143 pieces above and 196 below Total 339 b. 3/24/14 Wet Weather- Trash score 89 - 50 pieces above and 56 below Total 106 c. 9/17/14 Dry Weather- Trash score 94 - 41 pieces above and 20 below Total 61 d. 3/25/15 Wet Weather- Trash score 108 - 22 pieces above and 18 below Total 40 e. 9/22/15 Dry Weather- Trash score 98 – 43 pieces above and 83 below Total 126 f. 3/17/16 Wet Weather- Trash score 98 – 22 pieces above and 5 below Total 27 Site 4 - Natividad Creek between Garner Ave. and E. Laurel Dr. a. 9/24/13 Dry Weather- Trash score 81 - 60 pieces above and 234 below Total 294 b. 3/24/14 Wet Weather- Trash score 80 -159 pieces above and 146 below Total 305 c. 9/17/14 Dry Weather- Trash score 81 - 64 pieces above and 292 below Total 356 d. 3/25/15 Wet Weather- Trash score 107 - 30 pieces above and 86 below Total 116 e. 9/22/15 Dry Weather- Trash score 98 – 41 pieces above and 146 below Total 187 f. 3/17/16 Wet Weather- Trash score 98 – 150 pieces above and 13 below Total 176 The number of items of trash observed during the assessment has shown a consistent reduction over time. Using the number of items of trash observed as a proxy for total trash load, the rapid trash assessments indicate a reduction in trash at the four sites of about 40 to 80% over the last 3 years. Quantifiable data indicates that the actions implemented to reduce trash are having a noticeable impact on the amount of trash in the watershed that correlates to the estimated trash load reduction discussed in Section 4. Further assessment and evaluation is recommended to verify that the N-2
implemented structural and non-structural trash reduction BMPs are having the intended impact of reducing the total trash load. The estimated amount of material removed on an Urban Subwatershed basis is shown in Appendix C Baseline Trash Load Tables by Urban Subwatershed in the City of SalinasYear 4 Requirements Trash Load Quantification and Trash Load Reduction-Technical Memorandum , May 2016 by Michael Baker Inc.” contained in Appendix N. 5. The area known as “Chinatown” (concentrated homeless encampment), each individual/communal homeless encampment and dead end streets have been identified as the areas containing significant deposits of trash. See the exhibit below for homeless encampment locations cleaned of trash/debris and the agency that removed the trash/debris. See Appendix N for amounts removed on a Subwatershed basis.
N-3
The City also marks inlets with appropriate signage. The City maintains a list of high-density hot spots and updates it as necessary. The City defines hot spot locations as areas that: Sweepers cannot access (due to cars or other obstructions), and Areas with high trash and debris accumulation rates. N-4
In addition, the City Parks Department has increased maintenance activities at several locations identified as point sources for ongoing pollution and dumping hot spots: El Dorado Park, McKinnon Park, and Fairways Golf Course – daily detention basin litter, garbage, and landscape debris inspection and removal with an annual pre-storm season cleanup. Cesar Chavez Park – park staff completed a quarterly cleanup of litter and debris, including a pre-storm season cleanup in the three detention basins. Upper Carr Lake and Natividad Creek areas – park staff and community volunteer groups organized by the California State University at Monterey Bay (CSUMB) Return of the Natives Wetland Restoration Education organization continue to schedule clean up events at Natividad Creek Park and the Upper Carr Lake detention basin throughout the school year and summer months. Expo Park and PG & E site – monthly cleanup of the drainage ditch to control litter, garbage, and pollutants. Daily inspections of the site during the annual 10- day carnival held at the park in July to prevent illicit waste dumping or contamination from the equipment, activities, or personnel living quarters (RVs and Trailers). City of Salinas Inspectors, Monterey County Health Department, and Park and Wastewater Maintenance Supervisors along with the City’s Environmental Compliance Inspector inspected the site to ensure compliance with all laws and regulations, and NPDES policies that could affect the adjacent drainage ditch and stormwater system, or groundwater. N.5.d.: Progress in Implementing BMP Modifications i. The City has a comprehensive trash reduction plan in place that is having a noticeable impact on the trash that reaches the waterways. Several additional opportunities for trash/trash load reduction are available to the City. Several of the following implementation actions could be very expensive to implement, or be met with significant resistance from the public and business communities: Retrofitting existing detention basins to be full-capture devices, including regular maintenance and removal of trash Single-use food and beverage ware ban through municipal ordinance Enhanced street sweeping (increased frequency, enhanced parking enforcement) Installation of partial capture devices such as curb inlet screens, litter booms in the waterways Installation and retrofit of full-capture devices in existing storm drain inlets The City has made progress in implementing the recommendations as follows: Detention basins in parks are already inspected and trash removed on a daily basis. The dry weather and minimum first flush for the Salinas River Subwatershed will be diverted as part of the funding applied for under a Prop. 1 grant request for the Pure Water Monterey Project to the Blanco Detention Basin to improve trash capture as well as reduce pollutants entering the Salinas River. The tributary area to the Blanco Basin is 1,673 AC. The tributary area consists of mostly residential uses. The Trash Generation Rate is 5.98 lbs/AC/YR. The total amount of trash diverted at 100% capture would be 10,004 lbs during the rainy season. Since all of the flow up to the basin capacity would be retained and diverted, the trash capture rate will be 100%. Dry weather flow trash is currently screened at the existing 66” inlet to the storm water pump station. If more intense storms are experienced, some trash capture may be bypassed once the basin is full. However, intense storms which exceed the basin capacity are assumed to normally occur during rainy seasons which exceed the normal 13” rainfall and approximately 90 th percentile storm the basin can hold. N-5
Route Smart has been chosen to improve the routing and efficiency of the City’s sweepers and a parking enforcement plan including enforcement personnel is being assembled to reduce the impediments parked cars cause to trash/debris removal. This program is expected to be in place during year 5 of the Permit. Also, as part of the funding applied for under a Prop. 1 grant request for the Pure Water Monterey project, the City will be capturing a majority (estimated to be 90% based on BASMAA studies) of the trash for the City by installing a dry weather and first flush diversion on the Reclamation Ditch. The Reclamation Ditch diversion will have a screen on the intake sized to intercept anything ¾” and larger. The screen will capture the trash load which normally would be transported downstream with the Reclamation Ditch flow. The area drained by the Reclamation Ditch at the diversion includes the Reclamation Ditch East and West, Gabilan and Natividad Creek, Carr Lake and Chavez Park Subwatersheds. The tributary area being diverted is 5,896 acres. The Trash Generation Rate is 5.98 lbs/AC/YR. The total amount of trash diverted at 100% capture would be 35,258 lbs. The percentage by weight passing through a 3/4” screen size would depend on the trash constituents. Most trash which would pass through this opening would consist of cigarette filters/butts. Plastic drinking water/soda bottle caps would be retained and diverted. For the purpose of this analysis a capture rate of 90% by weight is used to be conservative. Therefore the amount captured would be 35,258x0.9=31,732lbs. Confirming the logic of a 10% cigarette butt composition for trash is BASMAA Technical Memorandum #1 “Method to Estimate Baseline Trash Loads from Bay Area Municipal Stormwater Systems” Table 2.3 “Trash Composition as Documented by Case Studies Reviewed” http://www.scvurppp-w2k.com/pdfs/1011/BASMAA_Tech_Memo_01Litter_Baseline_Load_FINAL_042111.pdf. The Caltrans Litter Management Study item contained in the table listed cigarette butts by weight as 10% and is supported by most other studies listed in the Table.
ii.
See i. above for a description of the City’s implementation of the Trash Reduction Plan.
iii.
For Permit year 4 the amount of trash removed from each source is as follows: Homeless Encampment Clean-up (See N.2.a.ii.5 above for exhibit): 165.2 tons (330,400 lbs.) Public Trash Clean-up events: 3,500 lbs. Public Watershed Clean-up Events: 1,300 lbs. City Council Clean-up Events (large/bulky items-large quantities which often are dumped to save disposal fees): 946 tons (1,892,000 lbs.) Street Sweeping: 1,200 cy City On-Land Trash Clean-ups: 100 cy General City Removal: 160 cy Storm Drain Maintenance: Refer to AR Section E Bioretention Basins: 800 lbs. Filtration Systems: 240 lbs.
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Following is the estimate of trash load reduction per the aforementioned study contained in Appendix N:
N.5.e: Verification of Implementation of BMP Modifications i. The number of items of trash observed during the assessment has shown a consistent reduction over time. Using the number of items of trash observed as a proxy for total trash load, the rapid trash assessments indicate a reduction in trash at the four sites of about 40 to 80% over the last 3 years. Quantifiable data indicates that the actions implemented to reduce trash are having a noticeable impact on the amount of trash in the watershed that correlates to the estimated trash load reduction discussed in Section N.2.a.ii.4. N-7
N.5.f: Trash Reduction Tracking Methodology The City commissioned the aforementioned report City of Salinas-Year 4 Requirements Trash Load Quantification and Trash Load Reduction-Technical Memorandum, May 2016, by Michael Baker Inc.” contained in Appendix N to meet this requirement. The tracking methodology is based on data collected from City staff and from a literature review of quantification methods used by other agencies. It should be noted that by its very nature, quantification of trash load and trash load reduction is imprecise and subjective. However, this methodology provides a comprehensive evaluation of all trash reduction activities implemented by the City. The report describes actions implemented by the City to reduce trash by means of these nonstructural and structural controls, and includes estimates of expected load reductions: Non-structural controls Municipal Ordinances and Regulations Single-use Carryout Bag Ordinance Polystyrene Foam Food Service Ware Ordinance Other Municipal Code Related Regulations: Cleaning lots that have excessive trash and debris Businesses that generate trash must provide trash receptacles on site New development should protect inlet from trash discharge Regular removal of trash and debris from building exterior premises Elimination of illegal discharge of litter, debris, and trash Public Education and Outreach Programs Clean-up Events Public Outreach Programs Public Notification and Signage Anti-Littering and Illegal Dumping Enforcement Activities On-Land Trash Clean-ups Street-Sweeping Storm Drain Maintenance Structural Controls Bioretention Basins Filtration Systems Bioswales Detention Basins
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Total Load Reduction Estimate Estimates were prepared of the load reductions that have been achieved by the City for the BMPs listed above. It was estimated that a 46% mass reduction and a 71% volumetric reduction had been achieved. The estimates were compared to field results by using data from the Rapid Trash Assessments that the City conducted semi-annually. Those assessments indicated that the actions implemented to reduce trash are having a noticeable impact on the amount of trash in the watershed, and correlated with the estimated trash load reductions described above.
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Provision O: TMDLs O.3 – Reporting Requirements O.3.a: Submittal of Wasteload Allocation Attainment Plan (WAAP) Within One Year or TMDL Approval by OAL – A WAAP was submitted in May 2015 to the Regional Board for the new Nutrient TMDL approved May 7, 2014. O.3.b: Annual Reporting of WAAP Implementation, Activities, and Monitoring Results The City has two WAAPs, the “Wasteload Allocation Attainment Plan for the Lower Salinas River Watershed Nutrient TMDL” and the “Wasteload Allocation Attainment Plan for the Lower Salinas River Fecal Coliform TMDL”. Refer to Appendix O. The “Progress Report Plan” contained in each document states the following in compliance with O.2.k: The Wasteload Allocation Attainment Plan (WAAP) for the Lower Salinas River Fecal Coliform TMDL proposed undertaking certain actions in accordance with an implementation schedule, as summarized below and the progress is included also: Action Implement initial BMPs Implement updated BMPs Salinas River outfall dry weather and first flush Diversions Develop prioritization schedule
Implement enhanced BMPs
Coordinate with other TMDL responsible parties on monitoring
Implementation Schedule BMPs On-going per Permit requirements Phased in 2012-2017 Planned for 2014 but dependent on securing Prop. 84 grant funds Pending availability of Salinas-specific monitoring data, prioritization anticipated to begin by December 2015 Per prioritization schedule
Monitoring January – June 2014
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Status Done In progress Applied for Prop.1 grants. Will hear if successful in October 2016. Reducing Fecal coliform sources from human and pet waste identified.
Marginally housed encampment clean-ups have expanded including removal of 165.2 tons of trash. The City is also opening its first dog park with proper source control BMPs. Other entities did not want to coordinate sampling.
Action Update Stormwater Monitoring Program QAPP or Create TMDL QAPP and TMDL Monitoring Program Implement current dryweather monitoring Implement current wetweather monitoring TMDL monitoring BMP pilot studies
Iterative runs of numeric analysis to assess progress to attain interim target(s)
Program Effectiveness Assessments Demonstrate progress implementing the WAAP
Implementation Schedule BMPs April 2014 – Pending approval of the TMDL monitoring plan July and September of each year, on-going throughout the permit term 3 stormwater events per year, on-going throughout the permit term As specified in TMDL Monitoring Plan Per pilot project implementation design
Status Updated
Implemented
Implemented
Implemented 66” SD low flow/first flush diversion, Rec. Ditch LF/FF diversion under design. Prop. 1 implementation grant applied for. Carr Lake was added by City.
Assessment Using Salinas monitoring Requires effective analysis data as it becomes available of sampling data which cannot be done due to sampling regime required by Permit. Annually as required by See Below Stormwater Permit Reporting Updates provided annually Implemented-See above in the Stormwater Permit annual report
The program effectiveness assessment identified in the nutrient WAAP consisted of answering the following management questions. We have included the responses to the questions for Permit Year 4: Management Questions 1. Are the impacted waterways meeting the TMDL targets for fecal coliform? [Environmental – OL6] No. However, the fecal coliform load from areas upstream of the MS4 is worse than when leaving the MS4. 2. Is urban stormwater discharger a significant source of fecal coliform to the receiving waters? Impossible to tell with current sampling regime. Are there other sources that are major contributors? [Environmental – OL5] Flows from upstream of the MS4 and possibly homeless encampments. 3. Is the City meeting the WLAs for fecal coliform? [Environmental – OL5] No. 4. Is the City effectively implementing BMPs that target indicator bacteria? [Programmatic – OL2-4] a. Identify specific BMPs Yes. The City continues to implement marginally housed encampment clean-ups to reduce the amount of human waste discharging into the MS4 system. The stormwater line into which the Chinatown O-2
catch basins poured into was plugged to prevent fecal coliform from being discharged into waterbodies. LID features are required as part of project reviews. The City will be opening its first dog park which will include proper source control BMPs. The City is also considering PCR testing of certain samples taken to determine if fecal coliform is derived from humans or from animal as the Agriculture industry which surrounds the City does apply manure to its fields which runs off into City waterbodies during irrigation. b. Prioritize BMPs for pilot scale implementation Source control BMPs 1. Carr Lake (will treat 100s.m.+/-); 2. Rec. Ditch LF/FF Diversion; 3. 66” Storm Drain LF/FF diversion; c. Evaluate the performance of implemented BMPs for fecal coliform load reduction. LID installation is incremental and affects a small amount of source pollutant. Source Control (Marginally housed encampment clean-ups, plugs in lines, pet waste BMPs), diversion and treatment provide a much higher level of source control and treatment. d. Implement BMPs that are effective in reducing fecal coliform loads Done. See above. 5. Is the general public aware of the need to properly dispose of pet waste, and are they doing so? Yes [Programmatic – OL2-3] a. Identify the source(s) of information for the residents (pet waste signs, PSAs, brochures, community events, dog tag licensing, etc.) Refer to Provision M. b. Evaluate changes in awareness and behavior. Refer to provision M. 6. Are the industrial and commercial sites that use, store, or could generate pathogens aware of the BMPs that they should be implementing on site, and are they implemented and maintained? [Programmatic – OL2-3] Maintenance staff inform sites of the proper BMPs during inspections and provides brochures where applicable and have sent packets out to industry and comm. food in the past with the appropriate BMPs. Staff has recently included BMP packets with the NOV for them to add to SOPs that they lack. posters are used as well for compliance with sanitation that have been provided by the MRWPCA. When asked for educational materials staff has always provided them with materials or a web site reference like CASQA for BMP info. In Year 5, potential pathogens coming from Ag manure will be investigated. a. Evaluate changes in awareness of appropriate BMPs. BMPs addressing the proper methods for pressure washing are continually the most asked about. The public thinks that it is illegal to pressure wash but the City informs them it’s not illegal, they just have to be aware the water used is considered process water and needs to be cared for in a manner that it is not allowed to enter a storm drain system. They are instructed to properly dispose of waste water in the sanitary sewer if possible or in near-by landscape if it is just clean water. Staff has a continual problem with commercial food in that the dumpster lids should be closed and they are often found open and overflowing. Staff instructs businesses of potential exposure to fog and rain because of the chance of a hole in the dumpster and leachate reaching a storm drain or creating waste fluid tracking problems. Staff will work with the trash service provider as to how to remind drivers/owners to keep the lids down. b. Evaluate changes in BMP implementation at industrial and commercial sites. The use of water on the outside of the facilities has virtually been eliminated because of our inspections and education as well as the tremendous drought. More service contractors are becoming aware of the proper ways to clean facilities and the trucks used for cleaning are properly equipped to capture the water used for cleaning. Industry within the city that used to discharge water to storm, have for the most part, been educated and all discharges to storm have virtually been eliminated. Water is diverted to the sanitary sewer or the industrial waste line. 7. Are the reported sanitary sewer overflows (SSOs) potentially impacting the storm drains and/or receiving waters? [Programmatic – OL3-4] No SSOs impacted receiving waters. If storm drains were affected they were plugged and cleaned before any contact with receiving waters occurred. a. Evaluate changes in Fats, Oils, and Grease, (FOG) management practices. Monterey County Department of Health is responsible for the FOG program in Monterey County and do FOG related inspections. City staff continue to clean sanitary sewer mains of grease on a scheduled basis. O-3
b. Evaluate reduction of sewage discharges that resulted from implementing an SSO response plan. No discharges occurred to receiving waters. Nutrient Wasteload Allocation Attainment Plan The Wasteload Allocation Attainment Plan (WAAP) for the Lower Salinas River Watershed Nutrient TMDL (refer to Appendix O) proposed undertaking certain actions in accordance with an implementation schedule, as summarized below and the progress is included also: Action Implement initial BMPs
Implementation Schedule BMPs On-going per Permit requirements
Status Ongoing catch basin cleaning, street sweeping, trash removal, requiring LID for redevelopment and development projects. Funding for stormwater diversion projects through a Prop. 1 implementation grant has been applied for. These projects include 66” SD Diversion and Rec. Ditch Diversion at Davis Road. Lining the 66” SD outfall from the Hitchcock Road site to the Salinas River has been removed from consideration due to its cost and source (agricultural infiltration to SD). Street sweeping program is being supplemented by making the routes more efficient through RouteSmart and the City is moving forward with plans to require cars to move during sweeping times/dates (parking enforcement). Carr Lake property procurement is proceeding.
Implement updated BMPs
Phased in, per Permit requirements and following model iterations with Salinas-specific information as monitoring data becomes available
Evaluation of potential nutrient BMPs identified in WAAP
2015-2017
Requires effective analysis of sampling data which cannot be done due to sampling regime required by Permit.
Develop prioritization schedule
Pending availability of Salinas-specific monitoring data.
See above.
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Action Implement new BMPs
Coordinate with other TMDL responsible parties on monitoring Update Stormwater Monitoring Program QAPP or Create TMDL QAPP and TMDL Monitoring Program Implement current dryweather monitoring Implement current wetweather monitoring TMDL monitoring
BMP pilot studies
Iterative runs of numeric analysis to assess progress to attain interim target(s) Program Effectiveness Assessments Demonstrate progress implementing the WAAP
Implementation Schedule BMPs Per prioritization schedule to be developed as monitoring data becomes available.
Monitoring June 2015 – May 2016
Status RouteSmart and parking enforcement expected to be implemented by end of Permit year 5.
Other entities did not want to coordinate sampling.
June 2015
Done.
July and September of each year, on-going throughout the permit term 3 stormwater events per year, on-going throughout the permit term As specified in TMDL Monitoring Plan and outlined in this WAAP Per pilot project implementation design
Ongoing.
Ongoing.
Ongoing.
66” SD low flow/first flush diversion, Rec. Ditch LF/FF diversion under design. Prop. 1 implementation grant applied for. Carr Lake was added by City.
Assessment Using Salinas monitoring Requires effective analysis of data as it becomes available sampling data which cannot be done due to sampling regime required by Permit. Annually as required by See below. Stormwater Permit Reporting Updates provided annually Implemented-See Above. in the Stormwater Permit annual report
The program effectiveness assessment identified in the WAAP consisted of answering the following management questions. We have included the responses to the questions for Permit Year 4: O-5
Management Questions 1. Are the impacted waterways meeting the TMDL targets for nutrients? [Environmental – OL6] No. However, the nutrient load from areas upstream of the MS4 is worse than when leaving the MS4. 2. Is urban stormwater discharger a significant source of nutrients to the receiving waters? Impossible to tell with current sampling regime. There have been orthophosphate “hits” during dry weather screening and illicit discharge response but the effect of that on the overall waterbody is indeterminable at this time. Are there other sources that are major contributors? Flows from agricultural operations upstream of the MS4. [Environmental – OL5] 3. Is the City meeting the WLAs for nutrients? No. [Environmental – OL5] 4. Is the City effectively implementing BMPs that target nutrients? [Programmatic – OL2-4] Yes. The City continues to implement education and outreach regarding pressure washing, car washing and restaurant cleaning activities. The City has also issued NOVs due to orthophosphate hits detected during dry weather screening events. a. Identify specific BMPs In order of priority, education and outreach regarding proper landscaping and pesticide/fertilizer application, education and outreach regarding proper restaurant and pressure washing activities, rapid response to dry weather screening “hits”, 66”SD and Rec. Ditch Diversions, Carr Lake acquisition, street sweeping and requiring development/re-development projects to use LID and City LID retrofit projects are specific BMPs in order of priority. b. Prioritize BMPs for pilot scale implementation See above. c. Evaluate the performance of implemented BMPs for nutrient load reduction. See nutrient WAAP (Appendix O) for evaluation of typical BMPs. d. Implement BMPs that are effective in reducing nutrient loads. Education and outreach by inspectors during commercial and industrial inspections has been quite effective, LID has been implemented in accordance with the City Stormwater Development Standards for LID related BMPs for all re-development/development projects, inlet cleaning, trash reduction and street sweeping efforts continue. If City receives the Prop. 1 implementation grant the stormwater diversion will be completed within the next 2-3 years. 5. Is the general public aware of the need to properly dispose of lawn waste, and are they doing so? [Programmatic – OL2-3] Through the City’s Public Outreach/Public Education Program the public has been made aware and, through the curbside yard waste recycling program, can and are disposing of yard waste properly. a. Identify the source(s) of information for the residents (lawn and pet waste signs, PSAs, brochures, community events, dog tag licensing, etc.) Sources for the public information include: a multi-media public education campaign, Republic Services Quarterly newsletters, six district clean-ups, and web site information and annual general education and outreach activities from Salinas’ solid waste partners: Republic Services and the Salinas Valley Solid Waste Authority. b. Evaluate changes in awareness and behavior. Not analyzed. Not enough data. 6. Are the industrial and commercial sites that use, store, or could generate nutrients aware of the BMPs that they should be implementing on site, and are they implemented and maintained? [Programmatic – OL2-3] S Fertilizer companies within the City, Wilber Ellis, CPS and the old NH3 Service Co., are well aware of stormwater BMPs. They retain all rain water and process water and put it back into their production. If they have too much and cannot store it or use it they look to the MRWPCA for a discharge permit to the sanitary sewer for disposal.
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a. Evaluate changes in awareness of appropriate BMPs Several of the facilities the City has inspected over the past 4 years have made significant improvements to improve water quality through diversion valves to the appropriate sanitary sewer systems (domestic or industrial) as well as investing in storm drain protection. Netting material, filter inserts, sump pumps, berming areas etc. have been installed to be sure all process water is diverted to the appropriate system. The word has definitely been heard that only rain water goes down the drain. Locals get it but we still have those that work out of the area that play dumb when caught doing the wrong thing. Common! b. Evaluate changes in BMP implementation at industrial and commercial sites. See above. The monitoring reports and data analysis can be found in Appendix P. In July it was determined that the monitoring protocol in the Nutrient WAAP is incorrect and has been revised to meet the monitoring program requirements of the Nutrient TMDL. Below is the current monitoring program requirement from the Nutrient TMDL – Receiving Waters 1. Subwatershed scale receiving water monitoring for all the impaired waterbodies assigned TMDLs (see Table 7-5). 2. a) Waterbodies with Biostimulatory Impairments: This TMDL established seasonal targets for nitrate and orthophosphate in reaches identified as having biostimulatory impairments Wet Season: Nov. 1 through May 31: Two samples from receiving waters to establish progress and achievement of the wet-season single-sample maximum target for nutrients. Dry Season: June 1 through October 31: Monthly sampling to establish progress and achievement of the dry-season geomean target for nutrients. b) Waterbodies with Drinking Water (Nitrate) Impairments Quarterly: One receiving water sample, quarterly. c) Waterbodies with Unionized Ammonia Impairments Quarterly: One receiving water sample, quarterly. Pacific Ecorisk was instructed to modify sampling as follows: 309ALD will be monitored at the same frequency as GAB and NAD sites (receiving waterbodies) 309-NAD/309-GAB/309-ALD/309-UCO: Wet season (Nov 1 – May 31) – Two samples from Receiving waters Dry Season (June 1 – Oct 31) – Monthly sampling Two samples during wet season at all 4 sites during the same rain event. Field assessments for algae cover, floating mats, % coverage for all 4 sites each sampling event. Constituents for Analysis: Total Ammonia Unionized ammonia Total Phosphorus Dissolved Orthophosphate Dissolved Oxygen Total Nitrogen Nitrate+Nitrite (as N) TKN O-7
TSS has also been added to all sampling at urban catchment sites. The Nutrient TMDL WAAP is currently being revised to reflect the information above.
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Provision P: Monitoring, Effectiveness Assessment, and Program Improvement P.8 – Reporting Requirements Many of the reporting requirements in this section have been reported out in the applicable permit provision section they pertain to (i.e. information on the effectiveness of various commercial/industrial section program requirements are reported in Provision F with Supporting Documentation in Appendix F). P.8.a.i – Pesticide, Fertilizer and Herbicide Use A summary of all pesticide/fertilizer/herbicide applications by the Parks and Streets Depts. and Contractors is located in Appendix P. 130 oz of Speedzone (Herbicide), 80 oz of Pendulum (Pre-emergent weed control), 1330 oz of Ranger Pro (Herbicide), and 856 oz of Roundup were applied within 7 days prior to a rain event. Most applications were performed by Contractors. One of the “gaps” identified was the fact that Contractors were not checking the weather forecast prior to chemical application. Documentation required from application contractors is being revised to include confirmation that the weather forecast has been reviewed and the % chance of rain and date of last 0.5” rain event are included on each application report. P.8.a.ii – Riparian Protection Data The information required in this item is included in Appendix P. P.8.a.iii – Stormwater Discharge Trend Monitoring and Pollutant Loading Assessments Water Quality data from Year 4 sampling events is included in the Year 4 Monitoring Report in Appendix P. Trend analyses for sampling data for the entire permit term, reflecting comparisons of various water quality parameters between background sites and the receiving water site, are included in this report. P.8.d.i – Structural BMPs Municipal structural BMPs were the only BMPs assessed via the BMP RAM tool during permit Years 3 and 4. A discussion of the results of these assessments is included in Provision E, Municipal Maintenance. P.8.d.ii – Pesticide, Herbicide, and Fertilizer Use An assessment of changes in amounts of pesticides, herbicides, and fertilizers applied within 7 days of a 0.5” rain event, as well as changes in the overall total usage amounts is included in Appendix P, Part 1. The process used to measure the effectiveness of efforts to reduce the quantity of chemicals applied within 7 days of a 0.5” rain event is obviously the final reporting totals at the end of the year. According to the Pesticide Use Summary located in Appendix P, Part 1, contractor training has been ineffective and needs to be revised. The chemical applicator training will be revised in Year 5 to address the importance of 1) checking and documenting the % chance of rain on a daily basis and 2) the importance of not applying chemicals within 48 hrs of a 0.5” rain event. That said, research into the herbicides applied within the 7 day window indicated that SpeedZone is rainfast 3 hours after application. .Pendulum, a pre-emergent, actually needs rainfall within 30 days for activation for effective weed control. The efficacy of Pendulum is actually increased “if the application is followed by onehalf inch of rainfall or its equivalent in sprinkler irrigation”. Due to water conservation efforts by the City, timing the application of Pendulum closer to a rain event is the preferred method of application. Conversely, P-1
heavy rainfall soon after application of Ranger Pro may wash it off of foliage and therefore require reapplication. Several studies have been published regarding the potential groundwater and surface water hazards of glyphosphate in RoundUp. According to the Permaculture Research Institute, “Roundup decreased the survival of algae and increased toxic bloom-forming cyanobacteria, hence accelerating the deterioration of water quality especially in small water systems.” New Roundup products have however been shown to be quite rainfast. Studies at North Carolina State University have determined that Roundup PowerMAX and Roundup WeatherMAX are rainfast after 1-2 hours and 30 minutes after application respectively. The City’s pesticide, fertilizer, and herbicide application processes will be reviewed in Year 5 to determine 1) if there are more environmentally-friendly products that could be used, 2) how to implement integrated pest management IPM within the City, 3) if chemical application and documentation requirements need to be incorporated into the contract language, and 4) if the contractor training program needs to be modified to become more effective. P.8.d.iii – Industrial Facilities Information regarding the industrial facilities that reported monitoring data in SMARTS, the exceedances noted, and the average number of exceedances per industrial facility is reported via the Brown & Caldwell Technical Memorandum located in Appendix F. During the 2015-2015 reporting period for the Industrial General Permit (IGP), 33 of the 40 facilities within the City limits submitted annual reports within monitoring data. The Target Pollutant chosen by Salinas is TSS. There were 23 exceedances of TSS with the average number of exceedances per industrial facility being 0.69. A complete summary of industrial facility monitoring data specific to each individual facility, is also located in Appendix F, “Industrial Facility Monitoring Data (Brown & Caldwell)”. P.8.d.iv – Urban Catchment Action Level Pilot Projects Tabular summaries of the monitoring data from the four urban catchments is located the Salinas Stormwater Monitoring Report in Appendix P, Part 1. There was very little data to report; the way the current monitoring program is set up, sampling only occurs when it rains. No rain, no data. P.8.d.v – Trash Action Level A summary of the trash assessment results is included in Provision N as well as the “Salinas Baseline Trash Load Level” report located in Appendix N. All visible trash was removed during each assessment; the City did not remove any trash from within the trash assessment location boundaries except for trash collection. P.8.f.i – Inspections 1. The inspection program for High Priority Municipal Facilities, Operations, and Events is currently being revised to 1) re-evaluate which facilities, operations and events meet the criteria for “High Priority” determination, 2) develop new and revised current SWPPPs and SOPs to incorporate current inspection sheets and implement the inspection rating system per Attachment G in the Permit. 2. Although the initial inspection rating system used for commercial and industrial inspections was according to a numeric system (1 – 5) with all facilities receiving lower than a 3 requiring a follow-up inspection, it was still effective in determining the status of both facility stormwater BMP implementation and trash management. Inspection forms have been revised to coincide with Attachment G and all inspectors have been trained in using the new forms. An analysis of industrial inspection ratings as well as overall facility inspection results are included in Appendix F. There are no other categories within the commercial/industrial inventory that can be analyzed because each facility is inspection once every 5 years, unless a follow-up inspection was warranted. P-2
3. See 2 above. 4. The Construction Site Management program was revised in Year 4 to align the program with the permit program requirements in Section K. Criteria for “High Priority” construction sites were developed and new inspection forms including the inspection rating system were implemented. Construction inspectors and engineering staff attended construction site management training to reinforce the correct implementation of the new program elements. There were no inspection ratings for “High Priority” construction sites in Year 4; additionally, incorrect criteria were used to determine which sites were “High Priority” which resulted in the inspection frequencies being incorrect for the dry and rainy seasons. This has been corrected and the program is now according to permit requirements. Work continues on the development of the Information Management Systems for all permit-required data and reporting. 5. The inspection program was not fully implemented. There was no data to analyze for this item. 6. A discussion of the re-inspection of low-performing facilities is included in Provision F and within the inspection summaries provided in Appendix F. 7. The City is completing the inspection of Commercial Food facilities in Year 5 and has not begun commercial retail centers yet. Inspections of commercial and industrial facilities began in Year 3. All categories of facilities on the commercial and industrial inventory will not be complete until Year 2 of the next permit (May 2019). P.8.f.ii – Catch Basin Cleaning A discussion of the catch basin inspection and cleaning program is included in Provision E with supporting documentation in Appendix E. The new catch basin cleaning prioritization program of designation of catch basins with debris levels of > 2 inches was implemented in Year 3. All catch basins were cleaned in Years 1 and 2 to get an idea of the debris levels in each of the cleaning zones. The City cleans 20% of all catch basins each year in addition to the high priority catch basins designated as such from previous years. The City has over 3500 catch basins. Developing a process to determine the effectiveness of catch basin cleaning activities is complicated. Merely comparing the volume of debris removed from a catch basin from one year to the next is not really representative of effectiveness of the cleaning program. There are many factors that vary continuously; traffic, weather, locations of special events, number of leaves shed by trees each year, population in the area of individual catch basins each year, tourism population, amount of fast food sold in the area, etc……..These factors vary so greatly that is it not really possible to determine catch basin cleaning program effectiveness other than the fact that a catch basin gets cleaned on the date it gets cleaned and the volume of debris that is removed cannot make it to a waterbody. The data collected from the catch basin cleaning program, such as amount of trash removed, can inform public outreach and education programs, which can be used to modify behavior. P.8.f.iii – Street Sweeping The data required in this section is contained in Appendix F. P.8.f.iv – Pesticide, Herbicide, and Fertilizer Application - BMP Modifications The assessment of chemical applications and usage is included in Appendix P, Part 1. An evaluation to implement program modifications to decrease chemical usage is being performed in Year 5. P-3
P.8.f.v – Urban Catchment Action Level Pilot Projects A summary of the water quality monitoring data for the urban catchments is located in Appendix P, Part 1, Salinas Stormwater Monitoring report. Because of the structure of the current monitoring program, very little data was collected over the permit term to date. Therefore, items 1 – 7 could not be evaluated and answered. P.8.f.vi – Trash Action Level A discussion of trash reduction efforts, trash assessment results, and the trash reduction methodology are included in Provision N and Appendix N. Items listed in this section are being further addressed in Year 5 as the City modifies its programs to meet the new trash amendments incorporated into the Basin Plan and the Ocean Plan. P.8.g.i – Catch Basin Cleaning The process used to analyze the volume of solids removed from catch basins is discussed in Provision E. Since the City will not have completed cleaning of all catch basins until Year 2 of the next permit, currently the subwatershed with the most solids removed cannot be determined. P.8.g.ii – Trash Quantification The “Salinas Baseline Trash Load” report is included in Appendix N. Many of the items in this section are addressed within that report. Since the trash assessment areas were limited to four areas, the urban subwatershed that are significant sources of trash have not been completely identified. The City is working to develop a map of “Priority Land Uses” per the new trash amendments. From that map, trash assessment locations throughout all subwatersheds will be determined to evaluate 1) if the areas indicated in the trash amendments are truly areas of significant trash generation and 2) what areas are significant trash generation areas. From this information, the City can determine where to consider installation of trash capture devices that will maximize the trash removal throughout the permit coverage area. P.8.h.i – Inspections Please see responses to P.8.f.i. P.8.h.ii – Catch Basin Inspection and Cleaning Please see discussion in Provision E and P.8.f.ii. P.8.h.iii – Verification the City progress in Reduction of Target Pollutant Exceedances in Industrial Discharges The City inspected all Industrial facilities each year in Years 1 – 4. In Year 5, program changes were made to only inspect industrial facilities that were either new, were determined to be “High Priority” due to criteria used for evaluation, or required follow-up inspections in the previous year. The City’s Environmental Compliance Inspector informs industrial facilities each year of the exceedances reported in the Brown & Caldwell report. If the facility has continual exceedances or has many exceedances in one year, it will receive an inspection to evaluate stormwater BMP implementation and how and where the monitoring samples are being taken. It has been found in the past that the sampling locations for some industrial facilities actually contributed to their exceedances in TSS. Many industrial facilities within the Salinas permit coverage area are not even aware of the State’s Industrial Permit, how to determine if it’s applicable to them, and how to enroll or apply for NEC certification. Better outreach to these facilities by the State is recommended. The City’s NPDES Program Manager as well as the Environmental Compliance Inspectors provide assistance to the industrial community in this area. P-4
INDUSTRIAL GENERAL PERMIT ISSUES Through an Agreement with Brown and Caldwell the City evaluated industries located within its jurisdiction for a variety of issues pertaining to the State’s Industrial General Permit (IGP), and water quality issues pertaining to the storm water discharges from these industries. This summarizes the scope and findings of that work. The works appears to fulfill the City’s Permit requirements under Section F.5, but may not fulfill the Effectiveness Assessment requirements in Section P.1.b.iii (Monitoring, Effectiveness Assessment, and Program Improvement: Industrial Facilities). Permit Section F.5 of the City’s Permit reads as follows: Facility Monitoring Data Reported under the General Industrial Permit - The Permittee shall obtain, track, and analyze parameter results reported by industrial facilities within the Permit coverage area enrolled under the General Industrial Permit each year. The Permittee shall obtain the data using the Stormwater Multiple Application and Report Tracking System (SMARTS) as well as by requesting from the Central Coast Water Board any additional data submitted by enrollees in the General Industrial Permit. The Permittee shall use this data to assess the effectiveness of the Permittee’s BMP designation, education, inspection, and enforcement activities for industrial facilities according to Section P.1.b.iii (Monitoring, Effectiveness Assessment, and Program Improvement: Industrial Facilities). Scope of Work: * 2014-2015 Annual Reports submitted by industries under the State’s SMARTS system (as required by the IGP) were reviewed * Industrial stormwater discharge water quality data was examined and a Target Pollutant was selected * Water quality results were evaluated and exceedences were identified * BMPs were recommended to address target pollutant exceedences Findings: * Based on information provided by Dun and Bradstreet (D&B) there are approximately 1,600 facilities within the City that have an SIC Code which is applicable to the IGP. * Of these 1,600, research by B&C provided data identifying 493 facilities, which were ranked into six categories, ranging from facilities that are considered not to be a threat to water quality (those facilities that are currently in the SMARTS system) to facilities that need further investigation to determine their potential threat to water quality. * Currently there are 79 facilities within the City that are considered to be industrial in nature and that are included in the City’s Commercial and Industrial Inventory. * Of these 79 facilities, 64 were identified as being subject to the IGP * Of these 64, only 39 were found to be registered under the State’s SMARTS data reporting system, as required by the IGP. 25 were not registered under SMARTS. 32 of these 39 had submitted Annual Reports under SMARTS 5 of these 39 had not submitting Annual Reports under SMARTS (their reports were overdue) 2 of these 39 had their industrial status either terminated or expired * Total Suspended Solids (TSS) was determined to be the Target Pollutant since this parameter had by far the greatest number of exceedences of the limits established by the IGP. * In Year 4 (2014-2015 reporting period) there were a total of 45 exceedances for the parameters of BOD, O&G, pH, and TSS. Of these 45 exceedances, 23 were for TSS. * A review of data over the four reporting years (2011-2012 through 2014-2015) indicated `that 19 of the 39 facilities that were registered under SMARTS had chronic exceedances, i.e. had one or more exceedances in every year for which they reported data. P-5
* A review of the data over these same 4 reporting years found that TSS exceedances in each of these 4 years were as follows: 2011-2012: number of TSS exceedances = 23 2012-2013: number of TSS exceedances = 18 2013-2014: number of TSS exceedances = 18 2014-2015: number of TSS exceedances = 23 This suggests that some improvement in TSS exceedances was occurring in years two and three, but that this lapsed in year four. * B&C’s report dated May 2016 titled “Final Industrial Facility Monitoring Data Technical Memorandum” contains a detailed review of the data submitted by the 39 registered facilities in their 2014-2015 SMARTS Annual Reports. The report provides a rating for each of these facilities in one of three categories: (1) Information showed the facility to be within the 1997 IGP standards, (2) Information showed the facility to be within compliance, but some additional attention is required, or (3) Information showed the facility to be out of compliance. The report also provides recommendations of things that could be done at each of these facilities to improve their compliance status and/or to improve the water quality of their stormwater discharges. * The B&C documents do not mention anything about Exceedances Response Actions taken by any of the industries.
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STORMWATER MONITORING PROGRAM: ANNUAL REPORT 2015-2016 In accordance with Sections P.4 and P.5 of the City’s Stormwater Discharge Permit (Order No. R3-2012-0005, NPDES Permit No. CA0049981), in 2012 the City prepared a Quality Assurance Project Plan (QAPP). This QAPP describes the City’s monitoring program to collect and analyze water quality data as required by the Permit. The original QAPP was subsequently revised to incorporate monitoring requirements associated with the Wasteload Allocation Attainment Plans (WAAPs) for the Lower Salinas River Fecal Coliform and Nutrient TMDLs. The Stormwater Monitoring Program Annual Report for 2015-2016 describes the design of the monitoring program, discusses and analyzes the data that was obtained, provides pollutant loading information, and presents a summary of findings and conclusions. It also contains a description of the quality assurance/quality control procedures that were used in gathering the data, as well as well as the raw laboratory analytical data itself. Monitoring Program Design The City’s Stormwater Monitoring Program (SSMP) is a comprehensive program to monitor stormwater discharges from the City, and when practicable, establish and implement best management practices (BMPs) that reduce the discharge of stormwater pollutants into water bodies and protect and improve water quality. The SSMP involves the collection of samples for analyses and evaluation of conventional water quality constituents, aquatic toxicity, sediment toxicity, and benthic invertebrates. The City uses the water quality monitoring data to: Determine concentrations of constituents in the City’s stormwater discharges and in receiving waters upstream and downstream of the City’s discharges Determine mass emission rates (loads) of these constituents in the City’s stormwater discharges Identify the sources of these constituents Assess the effectiveness of existing BMPs to identify improvements that can be made to make these BMPs more effective, and new BMPs that could be added. The monitoring data is compared to existing Basin Plan Water Quality Objectives (WQOs) or Central Coast Ambient Monitoring Program (CCAMP) Action Levels to identify exceedances of these standards. ammonia, water column toxicity, and sediment toxicity occurred only at the receiving water site (Reclamation Ditch); it is important to note that un-ionized ammonia and toxicity samples are not collected at the background sites. Monitoring Data Water quality data was obtained at 16 monitoring sites, in the following categories:
City background sites which provide data from upstream of the City’s stormwater discharges) Agricultural background sites which provide data from upstream of the City’s boundaries in locations where agricultural activities occur Receiving water sites which provide data in the water into which the City’s storm drainage is discharged Urban Catchment sites which provide data on typical urban land use types including residential, industrial, retail, and mixed use Stormwater discharges which provide data that can be used to develop trends the in water quality of these discharges Pollutant load reduction monitoring which provides data that can be used to evaluate the pollutant removal effectiveness of the BMPs the City employs to achieve compliance with its Stormwater Discharge Permit P-7
WAAP monitoring which provides data that can be used to evaluate the effectiveness of the BMPs the City employs to achieve compliance with its TMDL wasteload allocations
The monitoring data is presented in both tabular and graphical forms for a large number of constituents: Conventional parameters Temperature pH Dissolved oxygen Turbidity Nitrogen species Orthophosphate Metals Fecal coliform Aquatic toxicity Sediment toxicity Bioassessment data o Physical habitat o Benthic community The graphical presentations include discrete data plots and box and whisker plots. For certain of the constituents, trend analyses are presented in graphical form to aid in assessing the effectiveness of BMPs in achieving Permit compliance. All of the graphical presentations show the applicable WQOs for ease in identifying exceedances. The findings from the data are discussed in the text of this section of the Report. Pollutant Load Data Pollutant concentrations and annual pollutant loads (mass emission rates) for each monitoring site are presented in tabular form and are broken down by monitoring year over the four monitoring years to date under the current Permit. The WAAP monitoring data for both the fecal coliform and nutrient WAAPs is similarly presented in tabular form. Summary of Findings and Conclusions There were no exceedances of Basin Plan Water Quality Objectives (WQOs) or Action Levels for temperature. Exceedances for pH, dissolved oxygen, turbidity, nitrate, orthophosphate, total copper, total zinc, and fecal coliform occurred at both Background Sites and Receiving Water Sites. Exceedances for un-ionized ammonia, water column toxicity, and sediment toxicity occurred only at the Receiving Water Site. The presence of exceedances in incoming Background Site waters limits the interpretation of the impact of Salinas’ stormwater on the Receiving Water Sites, as it is unclear if the exceedances in the Receiving Waters are due to background (i.e., upstream) conditions or inputs occurring from within the City, or a combination of both. Bioassessment monitoring at the Receiving Water Site led to a classification of this site as very poor. This is generally consistent with the previous 8 years of sampling. A trend analysis of pollutant loads for TSS, orthophosphate, fecal coliform, total nitrogen, total copper, and total zinc produced varying results: Fecal coliform, nitrogen, and orthophosphate loads increased Copper and zinc loads were reduced P-8
There were routine exceedances for a number of parameters including pH, nutrients (nitrogen and phosphate forms), fecal coliform, Perhaps the most significant conclusions are: The monitoring program does not provide the data necessary to identify the impacts of the City’s stormwater discharges on water quality in the receiving waters. This is because the upstream Agriculture and City background sites contribute to pollutant concentrations at the downstream receiving water site, and there are few sampling points along the way to identify pollutant sources from the City. It is difficult to directly correlate exceedances observed at background sites with those observed at the receiving water sites because the monitoring frequencies and constituent requirements for the various sites are not the same. Perhaps the most significant recommendation is that a more cost-effective and informative monitoring program should be used in conjunction with the new five-year permit which the RWQCB intends to adopt for the City in 2017. Quality Assurance/Quality Control Plan The laboratory quality control results are presented (in an attachment to the Report). A critical evaluation of all the quality control data was performed and it was found that all the data collected in the current monitoring year (2015-2016) met the requirements of the QAPP. Laboratory Analytical Data All of the raw data is contained in a series of attachments. These include reports from several firms that analyzed the samples or performed other analyses of the data collected under the monitoring program, including APPL Labs, Caltest Analytical Laboratory, Calscience Environmental Laboratories, Physis Environmental Laboratories, Pacific EcoRisk, and EcoAnalysts. The attachments also include photos taken at various locations while the monitoring work was being performed.
P-9
TRASH REDUCTION TRACKING METHODOLOGY AND QUANTIFIED TRASH LOAD REDUCTION REPORT In accordance with Section N.4 of the City’s stormwater discharge permit (Order No. R3-2012-0005, NPDES Permit No. CA0049981) the City prepared a report containing a Trash Reduction Tracking Methodology and a quantification of trash load reductions. This report quantifies the City’s total trash load (baseline trash load), presents a methodology to quantify the effectiveness of the City’s trash reduction efforts, and determines the trash load reduction achieved from the BMPs that have been implemented. Baseline Trash Load The City’s baseline mass generation rate for trash was calculated based on trash generation rates and the five land use categories required by the City’s stormwater discharge permit: Commercial, Industrial, Low Density Residential, High Density Residential, and Open Space/Parks. The City’s baseline volumetric generation rate for trash was calculated based on trash generation rates and land use categories contained in the 2012 Bay Area Stormwater Management Agencies Association (BASMAA) Baseline Trash Generation Rates study. To do this, the City’s land use designations were allocated into the land use categories used in that study. The City’s baseline trash load was estimated to be 135,084 pounds per year or 156,441 cubic feet per year. The total baseline trash load includes trash loading from all areas within the City, including but not limited to City facilities. Trash Load Reduction Tracking Methodology The tracking methodology is based on data collected from City staff and from a literature review of quantification methods used by other agencies. It should be noted that by its very nature, quantification of trash load and trash load reduction is imprecise and subjective. However, this methodology provides a comprehensive evaluation of all trash reduction activities implemented by the City. The report describes actions implemented by the City to reduce trash by means of these non-structural and structural controls, and includes estimates of expected load reductions: * Non-structural controls * Municipal Ordinances and Regulations * Single-use Carryout Bag Ordinance * Polystyrene Foam Food Service Ware Ordinance * Other Municipal Code Related Regulations: * Cleaning lots that have excessive trash and debris * Businesses that generate trash must provide trash receptacles on site * New development should protect inlet from trash discharge * Regular removal of trash and debris from building exterior premises * Elimination of illegal discharge of litter, debris, and trash * Public Education and Outreach Programs * Clean-up Events * Public Notification and Signage * Anti-Littering and Illegal Dumping Enforcement Activities * On-Land Trash Clean-ups Street-Sweeping * Storm Drain Maintenance * Structural Controls * Bioretention Basins * Filtration Systems * Bioswales * Detention Basins P-10
Total Load Reduction Estimate Estimates were prepared of the load reductions that have been achieved by the City for the BMPs listed above. It was estimated that a 46% mass reduction and a 67% volumetric reduction had been achieved. The estimates were compared to field results by using data from the Rapid Trash Assessments that the City conducted semi-annually. Those assessments indicated that the actions implemented to reduce trash are having a noticeable impact on the amount of trash in the watershed, and correlated with the estimated trash load reductions described above.
P-11
Provision Q: Watershed Characterization Q.1 – Watershed Data Information Management See following updates by section. All information is available for review by Central Coast Water Board staff upon request. Revised maps are located in Appendix Q. Q.2-Watershed Delineation Q.2.a Map of Features i.) Existing Urban Subwatersheds-The Permittee shall delineate developed areas grouped into Existing Urban Subwatersheds according to Attachment F-Salinas Existing Urban Subwatersheds. ii.) Future Urban Subwatersheds-The Permittee shall delineate all areas within the Permittees sphere of influence not captured by Existing Urban Subwatersheds based on NHDPlus Catchments (USEPA and United States Geological Survey [USGS]. Figure Q.2.1 has been revised to show the information required per i.) and ii.) above.
The Tembladero Slough and El Toro Creek-Salinas River Subwatersheds have been removed and the Salinas Existing Urban Subwatersheds as required/described in Permit Attachment F have been added. The Future Urban Subwatersheds have been delineated based on extension of Existing Urban Subwatershed Boundaries, existing topography more accurate than USGS topographic survey and knowledge of Future Growth Area Specific Plan submittals. This is a more accurate ground level view informed by development proposals than the NHDPlus Catchment data. The Auto Center and Monte Bella Existing Urban Subwatersheds have been added to supplement the Attachment F subwatersheds as separate subwatersheds based on where the flow leaves the City limits. The general direction of surface flow, existing storm drain lines, catch basins, inlets, outfalls, streets, retention/detention basins, waterbodies have been added to each Subwatershed area to make the map a more useful composite tool.
Q.2.b. MS4 System Map The MS4 System Map (Figure Q.2.2) has been updated to show storm drain pipes within the Monte Bella and Auto Center Subwatershed areas including those subwatershed limits, detention/retention basins and water bodies to provide a clearer understanding on how the system functions. The scale of the map in the report does not allow for us to show it but all identifiers have been included and an inlet or outfall can be “picked’ in GIS to obtain that information. The large scale map is used in tandem with the 2004 Storm Drain Master Plan by CDM “Modeled Existing Storm Drainage Subarea City of Salinas Storm Water Master Plan April 2004” to assist field personnel in identifying tributary areas for tracking illicit discharges. Figure Q.2.3 “Salinas Sphere of Influence” has been revised to show only sphere of influence outside of the City limits and deleted the legend item “Sphere of Influence Inside City Limits” since that the definition of sphere of influence includes only areas outside of City limits. Q.3. Water Body Identification: a.) Figure Q.3.1 “Salinas Water Bodies” has been updated to remove the Tembladero Slough and El Toro CreekSalinas River Subwatersheds. A note has been added as a mean of explanation “Straight riverine segments Q-1
within Future Growth Areas and Sphere of Influence areas are predominantly agricultural drainage ditches. This note was added since the term “riverine” is used and the casual observer may misinterpret some segments as natural water courses due to the term. b.) Figure Q.3.2 “Surface Percent Impervious” has been revised to add the Monte Bella and Auto Center Existing Urban Subwatersheds. Figures Q.3.3 and Q.3.4 addressing infiltration suitability have also been updated in the same manner; future subwatershed boundaries were also added. Figure Q.3.5 “Potential Re-Charge and Management Areas” was added which contains existing urban subwatersheds, current detention/retention basins, open channels, dry lake beds and hydrologic soil groups from the 2004 CDM Storm Drain Master Plan. All can be used to determine potential infiltration sites together with site specific soils infiltration testing. Q.4. Watershed Physical Condition Assessment Riparian Vegetation and Habitat Condition Assessments: Gabilan and Natividad Creek Riparian Vegetation and Habitat Condition Assessments were completed May 2014 (submitted in 2013-2014 Annual Report, Vol 2). Santa Rita Creek Riparian Vegetation and Habitat Condition Assessment was completed in June 2015 (submitted in 2014-2015 Annual Report, Vol. 2). The Salinas Reclamation Ditch, which includes a portion of Alisal Creek, was not assessed within the City limits. The City’s consultant, EOA, Inc. in the Executive Summary of the Santa Rita Creek Assessment stated the following: “The Salinas Reclamation Ditch, which is a highly modified section of Alisal Creek that flows through the City, was not assessed due to the extensive management of the creek and riparian area, and low restoration potential.” Please note that although the consultant refers to it as the “Salinas” Reclamation Ditch, the Reclamation Ditch is operated by the Monterey County Water Resources Agency.
Percent Developed Imperviousness: Refer to Figure Q.3.2 in Appendix Q which was updated to include all existing urban subwatershed boundaries and future urban subwatershed boundaries.
Q-2
Dominant Watershed Processes: Refer to Figure Q.1, unchanged for 2015-16 Annual report, provided in 20122013 annual report). Over 98% of the City lies within watershed management Zone 1—see map. A sliver of land lies within Zone 4. Zone 1: Characteristics: drains to stream or to wetland; underlain by Quaternary and Late Tertiary deposits 0-40%; Early to Mid-Tertiary sed. 0-10%. With regard to the City of Salinas, drainage is to four creeks and then to the Reclamation Ditch. Attributes and Management Approach: This single WMZ includes almost two-thirds of the urban area of the Region, and over 98% of the City; it is defined by low-gradient deposits (Quaternary and Tertiary in age) together with the moderately sloped areas of these younger deposits that drain to a stream or wetland. The dominant watershed processes in this setting are infiltration into shallow and deeper soil layers; conversely, overland flow is localized and rare. Management strategies should minimize overland flow and promote infiltration, particularly into deeper aquifers if overlying a groundwater basin in its recharge area. For WMZ 1, the key processes are listed as: Overland flow, Infiltration and Groundwater recharge, and Chemical/biological transformations; those of secondary concern are Interflow and Evapotranspiration. Zone 4: Characteristics: drains to lake, large river, or marine nearshore; underlain by all types 0-10% and Quaternary and Late Tertiary deposits 10-40%. With regard to the City of Salinas, drainage is to the Salinas River. Attributes and Management Approach: This WMZ covers those areas geologically equivalent to WMZ’s 1 and 3 but draining to one of the receiving-water types that are not sensitive to changes in flow rates. The dominant watershed processes in this low-gradient terrain are those providing chemical and biological remediation of runoff, but a specific focus on infiltrative management strategies is only necessary for those parts of this WMZ that overlie a groundwater basin (which, for this WMZ, constitute in total about 10% of the Region’s urban areas). The dominant watershed processes are filtration and Groundwater recharge and Chemical/biological transformations; those of secondary concern are Interflow and Evapotranspiration. Q.5. Meteorological Information The sources the City of Salinas currently uses for the meteorological data are as follows: The City uses NOAA NWS Forecast for daily forecasts: http://forecast.weather.gov/MapClick.php?w0=t&w3u=1&w5=pop&w7=rain&AheadHour=0&Sub mit=Submit&FcstType=graphical&textField1=36.6778&textField2=-121.654&site=all&unit=0&dd=&bw= The City uses NOAA National Climatic Data Center, Station Data for Salinas Municipal Airport for rainfall totals. http://www.ncdc.noaa.gov/cdo-web/datasets/GHCND/stations/GHCND:USW00023233/detail The City saves these files on our network in the Public Drive at: P:\Permit\DevEng\NPDES\NWS Forecast\
Q-3
Provision R: Fiscal Analysis R.2 – Annual Reporting Requirements The City of Salinas is responsible for paying for services required by its NPDES Permit, to provide for the health, safety and welfare of its residents and for protecting the City’s natural resources. In FY 2015 – 2016, These costs total $13.1 million in operating costs that include management and community outreach, (Table R-1) and another $1.4 million in capital outlay. The cost of the NPDES Permit program is funded through various sources of revenue, including the General Fund (16%), Developer fees (26%), Assessment District fees (6%), the NPDES Fund (32%), Bonds (1%) and Gas Tax (13%). In November 2016, residents approved a one-cent sales tax measure and that is helping restore lost services due to employee furloughs and fund capital needs. Water recycling is being accomplished through diversion of the Industrial Waste Water to replenish ground water. Additionally, staff is working with various agencies to explore the possibility of water recycling that would generate revenues to offset these costs over the next two to five years (Pure Water project). Fiscal Year 2016-2017 is funded at higher levels than in the past, and the Capital Improvement Program(CIP) has increased to $1.6 million. The Capital project funding sources are shown in Figure R-2. Keeping Salinas safe and healthy while remaining in compliance with the NPDES permit is a process that falls upon all City departments, the City Council, Planning Commission and Salinas’ citizens. Due to the realignment of City Departments and the creation of a new Department (Water, Waste, and Energy), all of the NPDES Permit program tasks are now performed by the Public Works Department. Fiscal Year 2015-2016 The City spent $12.7 million addressing the thirteen compliance component categories in the Permit during FY 2015-2016. Three different Divisions participated in the work. The bulk of the direct expenses associated with the thirteen cost categories defined in the Permit, span seventeen different divisions of the Public Works Department. Of the estimated $12.7 million in operations expenses, Public Works spent $4.9 million using some or all its 66 employees. Roughly 7% or $324,000 paid for administrative costs, and the bulk of the costs was spent on operations directly associated with permit compliance efforts.
R-1
Table R-1 Operational Expenses Costs to meet Permit Requirements FY 15-16
Cost
Municipal Maintenance Commercial and Industrial Facilities Residential Illicit Discharge Parcel Scale Development Construction Site Management Development Planning and Storm Water Retrofits Public Education and Public Involvement Trash Load Reduction Monitoring effectiveness and Program Imp Watershed Characterization
$ 4,915,532 $ 415,987 $ 13,100 $ 3,433,388 $ 1,009,306 $ 770,913 $ 902,721 $ 206,971 $ 1,142,057 $ 225,000 $ 139,650 $ 13,174,625 The majority of the costs ($4.1 million) are attributable to street sweeping and illicit discharge response/dry weather screening. The City owns numerous buildings, libraries, five fire stations, 48 parks, golf courses and an airport. The operation of these facilities has been completely upgraded to improve the health and welfare of the community and the region in compliance with the NPDES Permit. Fiscal Year 2016/2017 With the passage of the new Sales Tax, the City is rebuilding its maintenance and operations programs after enduring severe cuts over the past seven to eight years. The approved budget will allow the hiring of three positions directly affecting NPDES operations: 1 Construction Inspection Supervisor, 1 NPDES Permit Manager; and 1 Environmental Compliance Officer. These positions increase the budget allocations to NPDES activities, particularly maintenance and operations of City facilities 20% annually in comparison to last year. CAPITAL IMPROVEMENT PROGRAM The Capital Improvement Project budget for FY 16/17 increased 120%, from $1.4 million to $1.65 million, due the passage of a new revenue source Measure G. Sixteen different projects outlined in the CIP include work that ranges from public education and outreach, compliance, new equipment and City facility work, rebuilding existing old infrastructure, watershed enhancements to the Salinas River and Gabilan Creeks, and other new public works storm drains. The CIP is a six-year document, and the forecast through 2019/20 is $105 million for NPDES. However, one project, the restoration of the Carr Lake wetlands area, assumes receipt of $91.2 million in a yet-to-be established assessment district to accomplish this critical task. If these funds are not received a more conservative number is $14 million over the next six years. This is the accepted adjusted total used for this analysis. Funding for the CIP comes from six different sources as shown in Figure R-2 below and Table R-2 on the next page.
R-2
FIGURE R-2 5-YEAR CIP FUNDING SOURCES: $14 MILLION TOTAL 13%
5% 6%
Ass Dist
1%
MG General Fund NPDES Fund 16%
Bonds Gas Tax
32%
The focus of the General Fund is to improve existing City facilities and help acquire equipment used in daily maintenance activities (like acquiring street sweepers). Measure G is a new sales tax measure, which is basically a subset of General Funds (bringing its total share to 22%) Gas Tax revenue is targeted towards street run-off and storm catch-basins. The NPDES Fund is targeted to mostly MS4 infrastructure needs, so it has the largest share. Developer fees are collected as new development occurs to build systems to accommodate it. Of the $14 million in CIP funds, 33% ($4.7 million) are set aside for management system improvements and sustainment. These include compliance monitoring, inspections, public information, staff training and system mapping. The breakdown of these costs is shown in Table R-3 below. Table R-3 Professional Services $ Permit Implementation $ Permit Monitoring $ Public Education $ Compliance Inspections $ System Mapping $ $
R-3
790,000 4,915,532 2,155,000 660,000 940,000 150,000 9,610,532
FIGURE R-3 System Support 49% of NPDES CIP = $4.7 million Compliance Public Inspections Education 10%
System Mapping 2%
7%
Permit Monitoring 22%
Permit Implementation 51%
R-4
Professional Services 8%
TABLE R-4
5-YEAR CAPITAL IMPROVEMENT PROGRAM Prior Years
ID
Description
9058
NPDES Professional Services
NPDES
9027
Natividad Creek Detention Basin
Assessment District
9075
Dry Weather Storm Water RunOff Det.
NPDES
9086
Natividad Crk Silt Removal
NPDES
9127
Gabilan Crk Silt Removal
Assessment District
9138
Corp Yard Storm Drain
Gas Tax
50,000
50,000
Gen Fund
50,000
50,000
330,000
FY 15-16 180,000
235,000
Storm Sewer Repairs
Gas Tax
9175
Santa Rita Storm Drain
Gas Tax
9365
Street Sweeper Acquisition
NPDES Gas Tax
9436
SW Monitoring
Gen Fund NPDES
9512
NPDES Pub. Ed
NPDES
180,000
FY 17-18
FY 18-19
19-20
125,000
790,000
200,000
200,000
385,000 400,000
525,000
582,000
582,000
100,000
604,500
250,000
100,000
250,000
250,000
1,354,500
100,000 118,000
100,000 110,000
110,000
110,000
60,000
60,000
408,600
685,000
265,000
265,000
265,000
225,000
225,000
Storm System Mapping
NPDES
9670
El Dorado Park Storm Wtr Retention
Measure G
9735
Priority 1 St Sewer Lines
Dev Fee
9935
Misc. Storm Drain Imps.
Dev Fee
9938
Fairview Park St Drain
Gas Tax
9959
NPDES Comp. Insp.
NPDES
TOTAL
2,155,000 475,000
76,000
84,000
80,000
80,000
80,000
Measure G 9513
568,000
408,600
475,000 180,000
Total
180,000
150,000
Measure G 9139
FY 16-17
FY
Funding Source
660,000 300,000
50,000
50,000
50,000
150,000
500,000
1,513,400
100,000
500,000
180,000
650,200
420,000
2,213,400
670,000
1,320,200
1,315,800
1,315,800
340,000
100,000
100,000
100,000
100,000
100,000
840,000
6,326,100
1,381,000
1,654,000
3,237,000
775,000
525,000
14,343,100
R-5
Provision S: Legal Authority S.5 – Reporting requirements: S.5.a: Revisions to Regulations Refer to Section L.4.c for this information. S.5.b: Certification Statement The Certified statement from year 1 is included in Appendix S. S.5.c: Inventory of Illicit Discharges and Actions Taken Refer to Provision H and Appendix H for this information. S.5.d.i: Enforcement Response Plan Refer to Appendix S for construction inspection Enforcement Response Plan and Appendix H for IDDE/Commercial/Industrial Enforcement Response Plan. S.5.d.ii: Enforcement Tracking Refer to Sections F and K for this information. S.5.d.iii: Recidivism Reduction There were no chronic violators over the past Permit year for construction inspection. For industrial/commercial inspections refer to Appendix S “New Star”. S.5.e: Training Report Refer to Sections/Appendices E, J and K for training information.
S-1
Table of Contents for Supporting Materials Appendix E
F
G
Description of Appendix Materials
Page
MUNICIPAL MAINTENANCE
AE-1
Inventory of Municipal Facilities
AE-97
Assessment of Pollutant Discharge Potential for Municipal Operations
AE-170
Roster of Special Events May 2015 – May 2016
AE-172
Key to CASQA Source Control (SC) BMPs
AE-175
Municipal Facilities, Maintenance Operations, and Events and Minimum BMPs
AE-176
City of Salinas Requirements for Public Events
AE-181
COMMERCIAL AND INDUSTRIAL
AF-1
Commercial/Industrial BMP Handouts
AF-2
Letter Sent to Industrial Facilities
AF-6
Notification Letter Sent to Businesses
AF-8
Commercial/Industrial Business Inventory
AF-10
Industrial Inspection Guidance Manual
AF-39
Inspection Meeting Kickoff Materials
AF-69
Year 4 Food Service Facility Inspection Assignments
AF-74
2015/2016 Commercial Food Facility Inspections
AF-82
2015/2016 Industrial Facility Inspections
AF-89
Summary of Industrial Facility Monitoring Data for Years 1-4
AF-91
Industrial Facility Monitoring Data Technical Memorandum
AF-97
SMARTS Industrial Facility List
AF-167
Master IGP SIC Code Ranking
AF-169
RESIDENTIAL
AG-1
TOC-1
H
ILLICIT DISCHARGE DETECTION AND ELIMINATION
AH-1
High Priority IDDE Analysis Map
AH-2
Nighttime Quarterly Inspections
AH-3
Drive-by Inspections
AH-9
NOV Actions
AH-13
Dry Weather Screening Locations
AH-21
Dry Weather Sampling Data
AH-22
NOV Letters
AH-32
Illicit Discharge Investigation Process Illicit Discharge Reports and Actions Taken Storm Drain Inlet Markers
K
AH-75 AH-92
NOV Letters J
AH-72
AH-155
PARCEL-SCALE DEVELOPMENT
AJ-1
Project Tracking Information
AJ-2
Project Review and Approval Document Examples
AJ-4
Staff Training Documentation
AJ-32
CONSTRUCTION SITE MANAGEMENT
AK-1
Storm Event Inspections - High Priority Projects
AK-2
Structural BMP Inspections
AK-6
Maintenance Declarations
AK-7
Enforcement Response Plan
AK-11
TOC-2
K
Non-Compliance Letters
AK-15
Inspector Training
AK-18
M
PUBLIC EDUCATION AND PUBLIC INVOLVEMENT
AM-1
N
TRASH LOAD REDUCTION
AN-1
Trash Load Quantification and Trash Load Reduction Technical Memorandum
AN-2
Marginally Housed Response Team Action Log
AN-56
TMDLs
AO-1
Fecal Coliform TMDL WAAP
AO-2
Nutrient TMDL WAAP
AO-41
O
P
MONITORING, EFFECTIVENESS ASSESSMENT (IN TWO PARTS)
AND PROGRAM Riparian ProtectionIMPROVEMENT Implementation
Q
AP-1 AP-2
Pesticide Application Reports
AP-3
Monitoring Annual Report (Body Only)
AP-16
Citywide Pollutant Load and Runoff Quantification
AP-124
Monitoring Annual Report (Part 2 - Attachments Only)
AP-149
WATERSHED CHARACTERIZATION
AQ-1
Watershed Management Zones Map
AQ-2
Existing Urban Subwatershed Map MS4 System Map
AQ-4 AQ-6
Sphere of Influence Map
AQ-7
Water Bodies Map
AQ-8
Surface Percent Impervious Map
AQ-9
Infiltration Suitability Map
AQ-10
Infiltration Suitability Map (Land Use Independent)
AQ-11
Potential Stormwater Recharge and Management Areas Map
AQ-12
TOC-3
