CAP Category: Potential Source Reduction

Transcription

1 CAP Category: Potential Source Reduction BASELINE ACTIVITY: CB-1 Reduce copper discharges from vehicle washing operations: (1) outreach on residential car washing, (2) outreach and requirements for commercial & industrial vehicle washing, and (3) education of and implementation of BMPs by mobile cleaners. Include mechanisms to evaluate effectiveness of each of these 3 measures. Region of Applicability: South Bay. Concept potentially applicable Bay-wide. Linkage to Copper Reduction: Indirect. Assumes vehicle wash water contains copper that will be permanently captured/redirected away from storm drains. Performance Measure(s): Extent of outreach, training, retraining, inspection, and enforcement efforts by and Co-permittees Lead Party Report/Source Actions Effectiveness Evaluation Future Actions FY PROPOSED WORKPLAN ACTIONS CB-1(1) a. Continue to distribute Watershed Watch (WW) campaign brochures at public events and post information on the WW website. Include information on proper car washing. a. Track quantities of outreach material distributed and gross impressions of advertising (see Program s FY Annual Report). Ongoing activity. CB-1(2) Same actions as FY (see below). Ongoing activity. To reduce discharges from vehicle washing activities, Copermittees will continue outreach to businesses and residents on BMPs. FY Work Plan 3/1/05 F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\Base_CB01_final.doc

2 Palo Alto, Sunnyvale, San Jose CB-1(3) Same actions as FY (see below). Ongoing activity. All Co-permittees All CB-1 tasks Refer to individual Co-permittee Work Plans. FY Actions Accomplished in Period CB-1(1) Distributed Watershed Watch (WW) campaign brochures at three public events and through website and hotline requests. Worked with WW partner, Classic Car Wash, to do four promotional events in October and November Classic Car Wash offered fifty percent discounted car washes to patrons who mentioned the Watershed Watch Campaign at the event. The San Jose Mercury News provided free promotional advertisement for each event and KBAY conducted live remotes at all events. Ads provided information on how the use of a commercial car wash prevents stormwater pollution. The promotion was also posted on During the first half of FY 04-05, 1,512 English and 835 Spanish WW kits were distributed. Distribution occurred at public events, through web site and hotline requests and to neighborhood associations. During the first half of FY 04-05, approximately 800 WW kits have been distributed to patrons at Classic Car Wash. Approximately 169 kits were distributed during the four Classic Car Wash events. Approximately 231 WW kits were distributed at Classic Car Wash kiosks/cash registers. Staff talked to FY Work Plan 3/1/05 F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\Base_CB01_final.doc

3 the WW web site for one month. Copermittee and Program staff volunteered at these events and distributed WW kits and flyers describing the environmental impact of washing cars on paved surfaces to Classic Car Wash patrons. The WW kit included a discount coupon offering a $4.00 discount at all Classic Car Wash locations from August to December 31, This discount is also being promoted on the Watershed Watch web site. approximately 204 people at these events. Use of discount cards by repeat customers: 71 in August 2004, 61 in September 2004, 83 in October 2004, 83in November 2004 and 56 in December Track the following Co-permittee activities: CB-1(2) Palo Alto, Sunnyvale, San a. Required source control measures for Group 1 new development and redevelopment projects that will conduct vehicle/equipment washing and maintenance activities (consistent with Permit Provision C.3.k). b. Inspected vehicle washing facilities as part of stormwater inspections for industrial and commercial businesses. As Required: During the first half of FY 04-05, the City of San Jose responded to one training request Collect and review data submitted with Copermittee Annual Reports. Co-permittes inspected vehicle washing facilities in accordance with their planned commitments. Follow-up inspections were conducted for facilities out-ofcompliance. Co-permittee industrial/commercial inspection summary tables for FY will be provided within Section 10 of the Program s FY Annual Report. Will provide lists in Annual Reports. Ongoing- Consistent with Permit Provision C.3.k. Ongoing- Consistent with Permit Provision C.6.a.i Ongoing. Training will occur when FY Work Plan 3/1/05 F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\Base_CB01_final.doc

4 Jose CB-1(3) Lead Party Report/Source Actions Effectiveness Evaluation Future Actions from a mobile surface cleaner who desired initial BASMAA surface cleaning certification. A list of individuals and dates of training will be maintained. Biannual: Provided training information to Program staff for reporting purposes. Ongoing: Municipal staff (or encourage public parties) will select certified mobile cleaners (from the list) when contracting cleaning services. FY PROPOSED WORKPLAN ACTIONS requested. Local trainers will provide training information on a biannual basis CB-1(1) b. Continue to distribute Watershed Watch (WW) campaign brochures at public events and post information on the WW website. Include information on proper car washing in WW advertising. This task is an on-going P/IP activity. a. Track quantities of outreach material distributed and gross impressions of advertising (see Annual Watershed Watch Campaign Media Report). Ongoing c. Work with WW partner business, Classic Car Wash, to do promotional events in June/July b. Track number of participants in car wash events and repeat customers using the discount card at the car wash. Track the following Co-permittee activities: CB-1(2) a. Require source control measures for Group 1 new development and redevelopment projects that will conduct vehicle/equipment washing and maintenance activities. This activity is consistent with Permit Provision C.3.k. Results will be provided in Annual Report, per Permit Provision C.3.n Ongoing FY Work Plan 3/1/05 F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\Base_CB01_final.doc

5 Palo Alto, Sunnyvale, San Jose CB-1(3) b. Inspect automotive facilities (car washes are a subset of this category) as part of the Program s Industrial/Commercial Discharger Control Program. Inspection results are summarized in the Program s Annual Report submitted each September. This activity is consistent with Permit Provision C.6.a.i. Continue to respond to training requests from mobile surface cleaners who desire initial BASMAA surface cleaning certification. Maintain list of individuals and dates of training. Provide training information to Program staff for reporting purposes. Municipal staff (or encourage public parties) will select certified mobile cleaners (from the list) when contracting cleaning services. As applicable, Copermittees are inspecting automotive facilities in accordance with their planned IND inspection commitments. Follow-up inspections are conducted at facilities determined to be out-of-compliance. Provide lists in Annual Reports. Ongoing. This activity is part of the Program s enhanced reporting requirements. Training will be provided, as requested, by one of the three POTW cities. On a biannual basis, local trainers will provide Program staff with a list of individuals and dates of training. All Co-permittees All CB-1 tasks Refer to individual Co-permittee Work Plans. FY Actions Accomplished in Period CB-1(1) Distributed Watershed Watch (WW) campaign brochures at three public events and through website and hotline requests. During FY 03-04, 19,336 English and 854 Spanish WW kits were distributed. Distribution occurred at public events, through web Ongoing FY Work Plan 3/1/05 F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\Base_CB01_final.doc

6 site and hotline requests and to neighborhood associations. Worked with WW partner, Classic Car Wash, to do four promotional events in August 2003 and four in April/May Classic Car Wash offered fifty percent discounted car washes to patrons who mentioned the Watershed Watch Campaign at the event. The San Jose Mercury News provided free promotional advertisement for each event and KBAY conducted live remotes at all events. Ads provided information on how the use of a commercial car wash prevents stormwater pollution. The promotion was also posted on the WW web site for one month. Co-permittee and Program staff volunteered at these events and distributed WW kits and flyers describing the environmental impact of washing cars on paved surfaces to Classic Car Wash patrons. The WW kit included a discount coupon offering a $4.00 discount at all Classic Car Wash locations from August to December 31, 2003 and May 2004 through December 31, This discount is also being promoted on the Watershed Watch web site. During FY 03-04, approximately 1,600 WW kits were distributed to patrons at Classic Car Wash. Approximately 450 kits were distributed during the eight Classic Car Wash events. Approximately 1,050 WW kits were distributed at Classic Car Wash kiosks/cash registers. Use of discount cards by repeat customers: 40 in September 2003, 70 in October 2003, 41in November 2003, 51 in December 2003, 35 in May 2004 and 75 in June During FY 03-04, a total of 312 repeat customers used the discount cards. Track the following Co-permittee activities: CB-1(2) c. Required source control measures for Group 1 new development and redevelopment projects that will conduct vehicle/equipment washing and maintenance activities Collect and review data submitted with Copermittee Annual Reports. Ongoing- Consistent with Permit Provision FY Work Plan 3/1/05 F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\Base_CB01_final.doc

7 (consistent with Permit Provision C.3.k). C.3.k. d. Inspected vehicle washing facilities as part of stormwater inspections for industrial and commercial businesses. Co-permittes inspected vehicle washing facilities in accordance with their planned commitments. Follow-up inspections were conducted for facilities out-ofcompliance. Co-permittee industrial/commercial inspection summary tables for FY are provided within Section 10 of the Program s FY Annual Report. Ongoing- Consistent with Permit Provision C.6.a.i CB-1(3) a. On October 29, 2003, a planning meeting was held with the three POTW cities to review the Program s standardized mobile surface cleaner training program. All three POTW cities are now ready to conduct training when requested. b. Each of the three POTW cities conducted Program-sponsored training workshop to certify (and re-certify in some cases) mobile surface cleaners in proper surface cleaning techniques. The training workshops were conducted on December 17, 2003, February 11, 2004 and March 24, All three workshops attracted 137 participants. Approximately 84 of the 137 participants were mobile surface cleaners. All three workshops and subsequent trainings consisted of a standardized message. Each workshop was very well received. The vast majority of workshop participants reported that the training met their expectations. Recent changes at BASMAA may allow this effort to be conducted online in the future. FY Work Plan 3/1/05 F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\Base_CB01_final.doc

8 c. Distributed a list of 84 mobile surface cleaners to the Management Committee and BASMAA Executive Director (by electronic mail) on March 31, This list is provided within Appendix A-5 of the Program s FY Annual Report. Municipal staff (and other public agencies as appropriate) will use the list to select certified mobile cleaners when contracting cleaning services. Improves the likelihood that certified mobile cleaners are used when contracting cleaning services. BASMAA recertification will occur every two years. Palo Alto, Sunnyvale, San Jose CB-1(3) As Required: Respond to training requests from mobile surface cleaners who desire initial BASMAA surface cleaning certification. Maintain list of individuals and dates of training. Biannual: Provide training information to Program staff for reporting purposes. Ongoing: Municipal staff (or encourage public parties) will select certified mobile cleaners (from the list) when contracting cleaning services. Provide lists in Annual Reports. Ongoing. Training will occur when requested. Local trainers will provide training information on a biannual basis FY Work Plan 3/1/05 F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\Base_CB01_final.doc

9 CAP Category: Potential Source Tracking BASELINE ACTIVITY: CB- 2 Water Supplier Copper Sulfate Use Region of Applicability: South Bay and other Bay areas with open water reservoirs and conveyance facilities Linkage to Copper Reduction: Raw water copper sulfate applications to control algae could potentially increase treated water concentrations Performance Measure(s): Raw water copper sulfate dosage and treated water copper concentrations Lead Party Report/Source Actions Effectiveness Evaluation Future Actions FY PROPOSED WORKPLAN ACTIONS Palo Alto Same action as FY (see below). Ongoing activity. FY Actions Accomplished in Period Palo Alto Obtained State DWR copper sulfate dosage notices. The RWQCB sent a letter dated September 22, 2004 to San Francisco PUC requesting dosages applied to local reservoirs. Palo Alto will include this data in its 2005 Copper Action Plan Report (Appendix E of the 2005 Clean Bay Plan) in February This is an on-going activity. Copper sulfate usage is regulated by SWRCB Aquatic Pesticide Application General NPDES permit Order No DWQ. Annual monitoring and reporting required. Ongoing. FY PROPOSED WORKPLAN ACTIONS Palo Alto Obtain State DWR copper sulfate dosage notices. Obtain from San Francisco PUC dosages applied to Ongoing. DWR notices will be F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\Base_CB02_final.doc

10 local reservoirs. Palo Alto will include these data in its annual Copper Action Plan Report. This is an ongoing activity. obtained annually. SFPUC dosage will be requested more frequently. FY Actions Accomplished in Period Palo Alto Obtained State DWR copper sulfate dosage notices from SCVWD. This data was included in the City s Copper Action Plan Report (Appendix E of the 2004 Clean Bay Plan) dated February 25, Applied dosages are indirect indicators. The amount of concentration will increase in treated water is delivered to consumers. Ongoing. This activity occurs annually. F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\Base_CB02_final.doc

11 CAP Category: Potential Source Reduction BASELINE ACTIVITY: CB- 3: Measures to control copper in discharges of stormwater from targeted industrial sources: older printed circuit board manufacturers and metal plating facilities using copper. Region of Applicability: Primarily South Bay and City of San Jose. Linkage to Copper Reduction: Roof-top exhaust vents from etching equipment and acid plating baths can contribute copper and nickel to roof runoff from these industries. Performance Measure(s): Outreach to appropriate industries; use of recommended BMPs; future industrial inspection reports. Lead Party Report/Source Actions Effectiveness Evaluation Future Actions FY PROPOSED WORKPLAN ACTIONS As part of the Program s Industrial/Commercial Discharger Control Program, continue inspecting facilities which are potential sources of copper. Potential sources may include electric/electrical components, metal manufacturing and metal finishing facilities. Inspection results are summarized in Section 9 or 10 of the Program s Annual Report submitted each September. This activity is consistent with Permit Provision C.6.a.i As applicable, Copermittees are inspecting industrial and commercial facilities in accordance with their planned IND inspection commitments. Follow-up inspections are conducted at facilities determined to be out-ofcompliance. Co-permittees report evaluation of effectiveness of IND programs for target industries in Annual Reports. Ongoing. This activity is part of the Program s enhanced reporting requirements (Permit Provision C.6.a.i). Individual POTW Pretreatment Programs will continue inspecting categorical facilities in accordance with their NPDES permits. Results are reported in annual Pretreatment F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\edits\Base_CB03_final.doc

12 reports. Industrial facilities are also subject to Industrial Stormwater General Permit requirements. Sunnyvale, San Jose All Co-permittees with IND Programs Continue distributing stand-alone roof vent BMP information to applicable industrial facilities during routine IND inspections. Refer to individual Co-permittee Work Plans. Ongoing activity. FY Actions Accomplished in Period Status: Worked with the Industrial Inspection AHTG to update the IND Performance Standard. The updates were essentially administrative (e.g., incorporating enhanced reporting requirements and results of Co-permittee evaluations). The inspection frequency of industrial/commercial facilities was also updated to match the Program s NPDES permit. A final revised draft of the IND performance standard was approved by the Management Committee on February 17, Effectiveness of implementation is evaluated in Co-permittee annual reports. Possible update to URMPs of Copermittees with IND programs. Status: On May 20, 2004, Program staff provided the stand-alone roof vent BMP information (developed by the City of San Jose) to the Management Committee. The City of San Jose printed and mailed the BMP information to all permitted industrial users in the SJ/SC WPCP Obtain feedback from participants in San Jose s Industrial User Academy. F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\edits\Base_CB03_final.doc

13 service area. The City of Sunnyvale has modified the original version to fit their local conditions and characteristics. It is being distributed to applicable industrial facilities within their service area. FY PROPOSED WORKPLAN ACTIONS Distribute the stand-alone roof vent BMP information (developed by the City of San Jose) to Copermittees. The City of San Jose will distribute this piece to circuit board and metal finishing facilities in FY Obtain feedback from participants in San Jose s Industrial User Academy. As part of the Program s Industrial/Commercial Discharger Control Program, continue inspecting facilities which are potential sources of copper. Potential sources may include electric/electrical components, metal manufacturing and metal finishing facilities. Inspection results are summarized in the Program s Annual Report submitted each September. This activity is consistent with Permit Provision C.6.a.i As applicable, Copermittees are inspecting industrial and commercial facilities in accordance with their planned IND inspection commitments. Follow-up inspections are conducted at facilities determined to be out-ofcompliance. Ongoing. This activity is part of the Program s enhanced reporting requirements. Co-permittees report evaluation of effectiveness of IND programs for target industries in Annual Reports. Begin working with the IND AHTG to develop model language for updating the IND Performance Standards. If necessary, continue update of language specifying the inspection frequency of industrial/commercial facilities suspected of discharging copper into stormwater. Effectiveness of implementation to be evaluated in Co-permittee annual reports. Possible update to URMPs of Copermittees with IND programs. F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\edits\Base_CB03_final.doc

14 San Jose Continue NOI Filers outreach project. All Co-permittees with IND Programs Refer to individual Co-permittee Work Plans. FY Actions Accomplished in Period Completed summary report on most effective targeted industry stormwater control measures. Distributed to Co-permittees, BASMAA and other Bay Area stormwater programs (Fall 2003). Update: There are relatively few pathways for copper to be released from industries in a manner that would contaminate stormwater. Potential sources may include electric/electrical components, metal manufacturing and metal finishing facilities. The primary potential source identified by San Jose s investigations was from roof vents in older printed circuit board and copper plating facilities. As a result, this action was addressed through the distribution of a stand-alone BMP information sheet which focuses on this potential source In addition, the inspection of industrial and commercial facilities has been incorporated into the Program s Industrial/Commercial Discharger Control Program. The approach for identifying potential sources of storm water pollution is described in the Program s memorandum entitled Continuous Improvement of Industrial Reporting (dated September 7, 2001). The approach was developed by the Industrial AHTG in As applicable, Co- Ongoing. This F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\edits\Base_CB03_final.doc

15 During FY 03-04, Co-permittees continued inspecting industrial and commercial facilities for illicit or other potential discharges/releases of constituents of concern. Inspection results for FY are summarized within the Co-permittee industrial/commercial inspection summary tables provided within Section 10 of the Program s FY Annual Report. This activity is consistent with Permit Provision C.6.a.i permittees inspected industrial and commercial facilities in accordance with their planned IND inspection commitments. Follow-up inspections were conducted at facilities determined to be out-of-compliance. Co-permittees reported evaluation of effectiveness of IND programs for target industries within their FY Annual Reports. activity is part of the Program s enhanced reporting requirements. Work with the IND AHTG to develop model language for updating the IND Performance Standards and a timeframe for implementation. Consider update of language specifying the inspection frequency of industrial/commercial facilities suspected of discharging copper into stormwater. Update: This task was originally scheduled for FY Due to higher priority Program issues, this task has been delayed until FY San Jose The City of San Jose committed to the additional production and distribution of stand-alone roof vent BMP information to circuit board and metal finishing facilities. During FY 03-04, BMP information was printed and mailed to all permitted industrial users in the SJ/SC WPCP service area. The continued distribution of roof vent BMP information is a follow-up action to San Jose s spring 2001 publication of roof vent F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\edits\Base_CB03_final.doc

16 information in the City s pretreatment newsletter entitled Tributary Tribune. On May 10, 2004, the City of San Jose distributed the stand-alone roof vent BMP information to the Management Committee by electronic mail. On May 20, 2004, Program staff provided a paper copy of the BMP information to the Management Committee. Continued NOI Filers outreach project. Tasks completed in FY include the following: Collected educational materials relating to General Permit requirements, NOI, BMPs and/or SWPPPs. Provided NOI filing information to San Jose Watershed Enforcement inspectors. Currently determining NOI status and needs as part of Inspection SOPs. Posted NOI filing information on the City of San Jose ESD web site. Distributed an all-purpose BMP brochure entitled Preventing Storm Drain Pollution to facilities as part of routine storm water facility inspections. It details general storm water BMP information. Began translating Preventing Storm Drain Pollution into Spanish and Vietnamese. Both documents will be printed and distributed, as resources allow in FY Provided NOI filing information to sixty industrial representatives at the San Jose Industrial User Academy Trainings on April 28-29, Information provided included: regulatory background and requirements, actions needed to achieve compliance, and details on determining exposure. The success of the NOI Filers outreach project is tracked by the following methods: Checking the State database periodically to observe changes in the number of NOIs filed. Tracking the number telephone calls received by the City of San Jose s telephone number. Approximately 25 attendees at the Industrial User Academy Trainings submitted evaluations. Approximately 60 percent of the respondents indicated that their knowledge of NOI has F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\edits\Base_CB03_final.doc

17 All Co-permittees with IND Programs Other tasks to be completed during FY include: Obtaining an updated list of industries requiring NOI filing from San Jose s IND Database. Letters were mailed in June 2004 to companies who may need to file NOIs. Letters included information on how to achieve compliance with the GIASP. Continue providing NOI filing information to industrial representatives at future San Jose Industrial User Academy Trainings. Refer to individual Co-permittee FY Annual Reports. increased. F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\edits\Base_CB03_final.doc

18 CAP Category: Potential Source Tracking BASELINE ACTIVITY: CB- 4(3) Potential Copper Sources, Loadings, and Impact Indicators Region of Applicability: Mainly South Bay; some indicators (brake pad content and BPP) applicable Bay-wide Linkage to Copper Reduction: Measures of copper sources, indicators of potential release to the environment, and monitoring of impacts on indicator aquatic organisms Performance Measure(s): Relative change in specified indicator measurements Lead Party Report/Source Actions Effectiveness Evaluation Future Actions FY PROPOSED WORKPLAN ACTIONS Same action as FY (see below). Ongoing activity Palo Alto 2006 Palo Alto CAP Report FY Actions Accomplished in Period FY PROPOSED WORKPLAN ACTIONS Palo Alto 2005 Palo Alto CAP Report Palo Alto will prepare fourth annual Copper Action Plan Report in Feb/Mar Influent, effluent and loading data from Sunnyvale, San Jose will also be included within the report. This is an on-going activity. Report will include DWR copper sulfate dosage (to the South Bay Aqueduct) data and SFPUC dosage data (to local East Bay reservoirs) F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\Base_CB04-3_final.doc

19 FY Actions Accomplished in Period Palo Alto 2004 Palo Alto CAP Report The City of Palo Alto prepared its Copper Action Plan Report (Appendix E of the 2004 Clean Bay Plan) dated February 25, Influent, effluent and loading data from Sunnyvale, San Jose and the amount of copper sulfate applied to the South Bay Aqueduct from 1996 through 2002 was also included within the Copper Action Plan Report. Discussed approach to consolidate related task reporting in this annual report during the April 6, 2004 South Bay CAP/NAP Semiannual meeting. It was agreed that to reduce redundant reporting, POTW baseline activities could be reported by reference within the Program s Cu/Ni Work Plan. This approach would eliminate reporting out the same activity in multiple regulatory reports. It was noted that the reporting on most if not all other baseline activities within the current Cu/Ni Work Plan could likely be similarly done. Since most of these activities are on-going and have been incorporated into other existing programs, they could be reported on by referencing where the information is found within the appropriate sections of the Annual Report. Continue to participate in efforts to develop/implement a Bay-wide CAP that will replace the South Bay CAP. F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\Base_CB04-3_final.doc

20 CAP Category: Potential Source Reduction (and uncertainty reduction) BASELINE ACTIVITY: CB-5 Local support for Brake Pad Partnership (BPP): (1) research on brake pad wear debris & content; (2) involve other local state and federal players, (3) assist in making research data accessible Region of Applicability: Bay-wide CB-4(1) Quantification studies of copper in vehicle brake pads (Other quantification studies reported under corresponding baseline activity) CB-4(2) Quantification studies of brake pad copper debris fate and transport CB-4(4) Issue paper on feasibility of monitoring brake pad copper fate and transport Linkage to Copper Reduction: Brake pad debris is apparent dominant non-point source. Relative fate, transport, and bioavailability uncertain. Performance Measure(s): Comprehensive assessment proceeding under Prop. 13 project to address all baseline activities. Lead Party Report/Source Actions Effectiveness Evaluation Future Activities FY PROPOSED WORKPLAN ACTIONS via BASMAA CB-5(1) CB-4(1, 2, 4) Same action as FY (see below). Participation in BPP is an ongoing effort through BASMAA. Should transition to BPP participation and reporting as part of Bay-wide CAP effort. BPP Prop. 13 grant funded project is addressing most aspects of CB- 4(1)(2)(4) and CB-5. CB-4(4) moot since fate and transport studies are included in BPP Prop 13 project. F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\edits\Base_CB05-CB _final.doc

21 Lead Party Report/Source Actions Effectiveness Evaluation Future Activities Same action as FY (see below). CB-5(3), CB-16 Same action as FY (see below). CB-4(1, 2, 4) Continue discussions regarding the identification of additional funding sources for clearinghouse. Determine the future coordination of web-page maintenance activities as part of Bay-wide CAP development effort. Funding and coordination decision needs to be made by December FY Actions Accomplished in Period via BASMAA CB-5(1) CB-4(1, 2, 4) BASMAA liaison to BPP (Kelly Moran, TDC Environmental) Same accomplishment as FY (see below). CB-5(3), CB-16 Same accomplishment as FY (see below). Completed development of prototype P2 clearinghouse in December The clearinghouse is available on the Program s website at The website has been designed as a bay-wide resource. The Program has committed to maintain the website through calendar year Intended to be a complementary resource to the BACWA Pollution Prevention Guidance and Tools for POTWs project and the CEP Copper Sources in Urban Runoff and Shoreline Activities Identification of additional funding sources (after 2005) is required. The Program may transition from program coordination to an oversight role. F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\edits\Base_CB05-CB _final.doc

22 Lead Party Report/Source Actions Effectiveness Evaluation Future Activities report. SFEI/RMP completed development of webbased copper uncertainty studies research tracking project (see description under CB- 17(1)) in December This web-portal is available on the Program s website at FY PROPOSED WORKPLAN ACTIONS via BASMAA CB-5(1) CB-4(1, 2, 4) BASMAA liaison to BPP (Kelly Moran, TDC Environmental) Continue to actively track activities of BPP (and other efforts under the Proposition 13 grant) through BASMAA Monitoring Committee monthly meeting notes and BASMAA BPP liaison notes and communications. Continue contributing portion of BASMAA baseline funding allocated to BASMAA BPP liaison and BPP support. Continue attending BPP Annual Stakeholder Meetings and share results with Management Committee. Bay-wide stakeholders will need to identify this project s on-going priority, level of support and source of future funding as part of the Bay-wide CAP development effort. The BPP is a standing item at the monthly BASMAA Monitoring Committee meetings. The Program will continue monitoring and supporting all ongoing BPP activities. The City of Palo Alto will continue to report on BPP activities within their Copper Action Plan Report prepared every February. CB-5(3), CB-16 Continue providing links at Program website ( to websites which contain BPP Proposition 13 information. Continue posting technical documents relevant to the BPP and other brake pad information on Ongoing. Update as needed. Ongoing. Update as F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\edits\Base_CB05-CB _final.doc

23 Lead Party Report/Source Actions Effectiveness Evaluation Future Activities the website. needed. CB-5(3), CB-16 Continue providing resources (for a two year period) to develop a prototype P2 clearinghouse. Development of the clearinghouse will be coordinated with the Pollution Prevention Menus Project (see CB- 16). Links/information to be posted to the prototype P2 clearinghouse during FY Finish establishing links/information relating to Bay copper impairment research data posted to a prototype SFEI-based web portal during CY Track project timeline and interface with contractor regarding project status and completion. Future funding source(s) after 2004 to be determined. CB-4(1, 2, 4) Continue tracking quantification studies as they relate to brake pads as sources. Other source quantification studies in addition to brake pads will be tracked and presented in the appropriate Copper/Nickel baseline activity tables. FY Actions Accomplished in Period SFEI/RMP completed development of web-based copper uncertainty studies research tracking project Program staff actively tracked activities of BPP and efforts under the Proposition 13 grant through BASMAA Monitoring Committee monthly meeting notes and BASMAA BPP liaison notes and communications. Contributed portion of BASMAA Proposition 13 grant contract with SFEP, Sustainable Conservation and the Sate of California signed in late Ongoing F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\edits\Base_CB05-CB _final.doc

24 Lead Party Report/Source Actions Effectiveness Evaluation Future Activities (see description under CB-17(1)) in December This web-portal is available on the Program s website at baseline funding allocated to BASMAA BPP liaison and BPP support. Attended BPP Annual Stakeholder Meeting on May 21, Provided link ( at Program website ( which contains the meeting s agenda, presentations and handouts. Shared meeting results with Management Committee. CB-5(2) CB-5(3), CB-16 CB-5(3), CB-16 Program staff will reevaluate if this task is politically and economically realistic. Program staff will again request that BASMAA approach CASQA to consider funding to support State-wide involvement with BPP. Request Regional Board assistance in making this a priority in other regions with copper impaired waterbodies. Provided links at Program website ( to websites which contain BPP Proposition 13 information. Current websites include: Sustainable Conservation, and TDC Environmental (technical reference library) Technical documents relevant to the BPP and other brake pad information have been posted on the Program s website. In November 2003, the Program executed a contract with the Clean Water Fund to provide resources for a two year period to develop a P2 clearinghouse. In May 2004, the Program decided to design and implement the prototype P2 clearinghouse due to the Clean Water Fund not being able to fulfill their contract obligations. In June 2004, the Program developed a strategy for F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\edits\Base_CB05-CB _final.doc

25 Lead Party Report/Source Actions Effectiveness Evaluation Future Activities completing website design and implementation. Links/information relating to copper research data will be posted to the web portal during the remainder of CY F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\edits\Base_CB05-CB _final.doc

26 CAP Category: Potential Source Reduction BASELINE ACTIVITY: CB-6 Measures to Reduce Traffic Congestion: Review appropriateness of transportation control measures, prioritize reasonable measures and identify potential efforts for further development CB-7 Measures to Reduce Traffic Congestion: (1) Establish transportation/impervious surface forum, (2) Consider results of Vehicle Miles Traveled (VMT) and imperviousness load estimates and control effectiveness evaluation; identify potential further control efforts Region of Applicability: South Bay focus. Potential to become regional. Linkage to Copper Reduction: Reductions in VMT and congestion may reduce generation of brake pad debris. Performance Measure(s): VMT and congestion measurements are indirect indicators; the BPP wear debris characterization test is a more direct indicator (see CB-5). Lead Party Report/Source Actions Effectiveness Evaluation Future Actions FY PROPOSED WORKPLAN ACTIONS Continue messages from the Watershed Watch Campaign promoting protection of water quality by reducing automobile use. Messages promoting protection of water quality by reducing automobile use will continue to be posted on the Watershed Watch website. Provide updates regarding transportation issues at SCBWMI LUS meetings. This task will occur at least once a year. The establishment of a transportation/ impervious surface forum CB-7(2)) is on hold indefinitely due to a lack of resources. F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\Base_CB06-CB07_final.doc

27 Co-permittees Refer to individual Co-permittee Work Plans. FY Actions Accomplished in Period Status: The memorandum is currently being drafted and is scheduled to be completed by June In addition, LUS is reviewing the SCBWMI s Public Vision Survey (which includes the same transportation-related subjects) and will provide feedback to the SCBWMI COS on the best way to use this information. Status: The transportation agencies awareness task is currently underway and is scheduled to be completed by June FY PROPOSED WORKPLAN ACTIONS SCBWMI LUS Approach: Collaboration with the agencies and organizations (e.g., VTA) that are better poised to take the lead on transportation-related tasks will increase the likelihood of successful, efficient implementation. Prepare a memorandum that summarizes the current status of projects and activities of the main players involved in traffic congestion reduction and alternative transportation promotion; and provide recommendations on how the Program and SCBWMI LUS may best assist in these efforts. Memorandum will summarize the current status of projects listed in Table 1 of the Program s document entitled The Role of Stormwater Agencies in Regional Congestion Management Planning and Implementation (dated March 13, 2002); and strategize best avenues for collaboration with lead agencies. CB-6&7 issues appear to have been adequately addressed for CAP purposes. This issue is now in the hands of municipal transportation planners, and congestion management and transportation agencies (i.e. VTA), and is not a high priority of F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\Base_CB06-CB07_final.doc

28 Ensure that the lead transportation agencies (e.g., VTA) are aware of and promote the transportation-related analysis in the Development Policies Comparison report. Continue messages in the Watershed Watch Campaign promoting protection of water quality by reducing automobile use. Memorandum transmitting section of Development Policies Comparison report along with municipal responses to transportationrelated questions of Site Design review (dated September 13, 2003) to appropriate staff. Messages promoting protection of water quality by reducing automobile use will continue to be posted on the Watershed Watch website. Co-permittees Refer to individual Co-permittee Work Plans. FY Actions Accomplished in Period SCBWMI LUS Update: Encouraged Co-permittees to update development rules to promote better transportation-related design practices and alternative modes of transportation, as recommended in the Development Policies Comparison Project Report (see Section VI., Policies to Limit Auto Use/Promote Alternative Transportation, in the Policy, Code, and Ordinance Worksheet). During FY 03-04, Copermittees revised development site design standards related to transportation (per Permit Provision C.3.j) based on analysis and recommendations made in the Development Policy Comparison report (April 2003) and described in the Site Design Review submittal (September 15, 2003). These revisions are summarized within Co-permittee Annual Reports submitted September 15, Complete. F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\Base_CB06-CB07_final.doc

29 Facilitated updates via periodic discussions at LUS meetings (Site Design Dialogues) on transportation and land use issues and documented in LUS meeting (dialogue) summaries. During FY 03-04, VTA completed the Community Design and Transportation Manual and participated in the Program s/scbwmi LUS s site design dialogues. On January 29, 2004, conducted a workshop on Overcoming Hurdles to Using Better Site Designs, with presentations on development design that encourages alternative transportation and reduces sprawl (e.g., presentations on Village Homes in Davis, CA and the concept of new urbanism). This workshop was very well received. The vast majority of attendees gave the workshop high marks. Watershed Watch Campaign Messages promoting water quality by reducing automobile use have been posted on the Wateshed Watch website. The message is included on the Watershed Watch website under Caring for Your Vehicle and the Environment at vehicle_care.htm F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\Base_CB06-CB07_final.doc

30 CAP Category: Watershed Assessment BASELINE ACTIVITY: CB-8 - Measures to classify and assess watersheds and to improve institutional arrangements for watershed protection: (1) Ensure that watershed protection is considered in all applicable elements of Dischargers General Plans, (2) seek appropriate changes in State General Plan Guidelines, (3) ensure that watershed protection is considered in the CEQA process, and (4) continue to implement watershed classification and assessment efforts of SCBWMI. Region of Applicability: South Bay Linkage to Copper Reduction: No specific linkage to copper; actions apply to watershed protection in general. Performance Measure(s): Changes in General Plans and CEQA process documents; results of and SCBWMI assessments Lead Party Report/Source Actions Effectiveness Evaluation Future Actions FY PROPOSED WORKPLAN ACTIONS Continue implementing the Multi-Year Receiving Waters Monitoring Plan (see Section 4 of the FY Work Plan). Track and/or participate in the Water Resources Protection Collaborative and working groups, as appropriate. Water quality data will be reported within the Program s Annual Watershed Monitoring and Assessment Summary Report provided within Section 4 of the FY Annual Report. CB-8 activities have been incorporated into the Program s and Co-permittees watershed management activities (Permit Provision C.10). On-going activity. / SCBWMI Continue to support the efforts of the SCBWMI Watershed Assessment and Monitoring Subgroup (WAMS) in planning or conducting future The results of watershed management measures; and collaboration with WMI F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\Base_CB08_final.doc

31 assessment-related work. and other applicable organizations will be reported within Section 5 of the Program s Annual Report. Co-permittees See individual Co-permittee Work Plans. FY Actions Accomplished in Period Continued implementing the Multi-Year Receiving Waters Monitoring Plan (see FY Work Plan). Monitoring results will be provided within the Program s FY Watershed Monitoring and Assessment Summary within Section 4 of the FY Annual Report. Continue implementing the Multi-Year Receiving Waters Monitoring Plan (see FY Work Plan). Tracked and/or participated in the Water Resources Protection Collaborative and working groups, as appropriate. / SCBWMI Continued to support the efforts of the SCBWMI Watershed Assessment and Monitoring Subgroup (WAMS), formerly WAS, in planning or conducting future assessment-related work. F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\Base_CB08_final.doc

32 FY PROPOSED WORKPLAN ACTIONS Continue implementing the Multi-Year Receiving Waters Monitoring Plan (see Section 4 of the FY Work Plan). To be provided within Section 4 of the FY Annual Report. Track and/or participate in the Water Resources Protection Collaborative and working groups, as appropriate. / SCBWMI Continue to support the efforts of the SCBWMI Watershed Assessment Subgroup (WAS) in planning or conducting future assessment-related work. Co-permittees See individual Co-permittee Work Plans. FY Actions Accomplished in Period CB-8 (1) Permit Prov. C.3.l. See individual Co-permittee annual reports and work plans for progress on updating their General Plans. Update progress in annual reports Revise General Plans at next scheduled update after 10/15/04 CB-8 (2) Action not needed now that Provision C.3.l. provides guidance for water quality and watershed protection principles and policies that should be included in General Plans. None F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\Base_CB08_final.doc

33 CB-8 (3) Permit Prov. C.3.m. Program staff worked with City of San Jose staff to prepare an analysis of the C.3.m. example questions and how they were addressed by the CEQA Guidelines. This analysis is provided in the memorandum entitled Recommendations for Addressing Provision C.3.m, Water Quality Review Processes (final version dated December 4, 2003). This memorandum includes a list of the CEQA guidelines questions, in order, and guidance for addressing C.3.m. in responses to each question. All Co-permittees have been encouraged to use this guidance internally and to provide it to their environmental review consultants, thus ensuring a consistent approach to evaluating water quality and watershed impacts throughout the Santa Clara Valley. The CEQA guidance is also provided in the C.3. Stormwater Handbook. None-task completed. CB-8 (4) Continued implementing the Multi-Year Receiving Waters Monitoring Plan (see FY Work Plan). Monitoring results are provided with the Program s FY Watershed Monitoring and Assessment Summary within Section 4 of the FY Annual Report. Continue implementing the Multi-Year Receiving Waters Monitoring Plan (see FY Work Plan). Consultants under contract to the SCVWD collected channel cross-section data and measured bed and bank material as part of the HMP geomorphic assessment in Ross and San Tomas Aquino Creeks. Modeling and stability assessment work for Field work, modeling and stability analyses were effectively used to demonstrate the application of the erosion potential F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\Base_CB08_final.doc

34 Ross and San Tomas Aquino Creeks were also completed in FY Assessment results are provided within the Program s Hydromodification Management Plan Report (Public Review Draft) June methodology in these creeks and to set management criteria for the HMP. Distributed Program s Assessment of Watershed Assessment Methods by electronic mail (on August 12, 2003) to the following parties: Program s Management Committee, Program s Ad Hoc Monitoring Committee and SCBWMI Watershed Assessment Subgroup. Distributed hard copies to the Management Committee on August 28, F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\Base_CB08_final.doc

35 CAP Category: POTW Actions BASELINE ACTIVITY: CB- 9 Continue Current Efforts and Track Corrosion Control Opportunities Region of Applicability: South Bay and Bay-wide Linkage to Copper Reduction: Corrosion of copper piping is dominant source of loading to POTWs Performance Measure(s): Increased use of alternatives to copper pipe. Outreach to plumbers. Water purveyor corrosion control program effectiveness. Lead Party Report/Source Actions Effectiveness Evaluation Future Actions FY PROPOSED WORKPLAN ACTIONS Palo Alto RWQCP Sunnyvale San Jose/Santa Clara WPCP Continue scheduling and providing outreach to local pipe fitters unions and other plumbing associations. Presentations will be provided at their sites. A post presentation will be used to gauge increase in awareness. Palo Alto RWQCP Sunnyvale San Jose/Santa Clara WPCP Track and report status of water purveyor corrosion control programs as part of their POTW NPDES Permit Pollutant Minimization Programs. The City of Palo Alto will also provide this information in its annual Copper Action Plan Report (February/March 2006) Corrosion control is regulated under the Safe Drinking Water Act Lead and Copper Rule, not the Clean Water Act. The DHS is the regulatory authority rather than the Regional Board. F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\edits\Base_CB09_final.doc

36 Palo Alto RWQCP Continue distributing Palo Alto RWQCP guidelines for proper design, installation and maintenance of copper piping to local plumbers. Ongoing. FY Actions Accomplished in Period Obtained and distributed (to Co-permittees) the following materials developed by BACWA s Bay Area Pollution Prevention Group- Copper Pollution Prevention Subcommittee: Preventing Corrosion Protects San Francisco Bay: A Fact Sheet for Designers and Good Plumbing Practices Protect San Francisco Bay: A Fact Sheet for Installers/Plumbers. Both fact sheets are available on the Program s website at Note: The guidelines distributed by the Palo Alto RWQCB are the two fact sheets developed by BACWA s Bay Area Pollution Prevention Group- Copper Pollution Prevention Subcommittee. Palo Alto RWQCP Continued distributing Palo Alto RWQCP guidelines for proper design, installation and maintenance of copper piping to local plumbers. Ongoing Palo Alto RWQCP Sunnyvale San Jose/Santa Clara WPCP Status: The Palo Alto RWQCP hired a consultant for coordinating presentations at plumbing agencies. During the first half of FY 04-05, six presentations have been provided (by POTW staff) to local pipe fitters unions and other plumbing associations. Additional presentations are planned for FY A post presentation survey has been developed to gauge increase in awareness. F:\Sc47\Sc47.04\FY0506_WP_CAP Tables\Drafts_Finished\pdf\edits\Base_CB09_final.doc