10 City Council Approval of Method of Compliance “Track 1” of the Statewide Trash Provisions Ordered by the State Water Resources Control Board under Section 13383 to Meet the Statewide Water Quality Objective for Zero Trash Discharge from Storm Drain Systems.

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Meeting Date: August 15, 2017

STAFF REPORT

AGENDA ITEM: City Council Approval of method of compliance “Track 1” of the Statewide Trash Provisions ordered by the State Water Resources Control Board under Section 13383 to meet the Statewide Water Quality Objective for Zero Trash discharge from Storm Drain Systems.

MEETING DATE: August 15, 2017

PREPARED BY: Noe Martinez, Interim Public Works Director

REVIEWED BY: Jose Antonio Ramirez, City Manager

RECOMMENDATION:

It is recommended that the City Council approve the method of compliance “Track 1” of the Statewide Trash Provisions ordered by the Water Board under Section 13383 to meet the statewide water quality objective for a zero trash discharge from the City of Livingston’s storm drain system.

BACKGROUND:

On April 7, 2015 the State Water Resources Control Board adopted statewide Trash Provisions to address the impact trash has on the beneficial uses of our surface waters. The Provision establishes a statewide water quality objective for zero trash and a prohibition of trash discharge, or deposition where it may be discharged to surface waters of the State.

On June 2, 2017 the State and Regional Boards issued Water Code Section 13383 letters to all Municipal Separate Storm Sewer Systems (MS4) permittees not already subject to the Trash Provision. The letter the City received requires the permittee to choose between two compliance method Tracks.

Track 1 is full capture and Track 2 is full-capture equivalent including preliminary planning documents. The City must choose a Track by September 1, 2017 and submit their selection electronically to the Regional Water Quality Control Board as defined in the Order.

DISCUSSION:

The City of Livingston has been issued a Water Code Section 13382 letter requiring selection of one of two compliance Tracks by September 1, 2017.

Track 1

Track 1 consists of the following:

Install, operate, and maintain full capture devices to capture all trash 5mm and greater in the municipally­ owned storm drain network within priority land uses.

The installation of full capture devices would include a treatment control, or series of treatment controls, including, but not limited to a multi-benefit project or a low-impact development control that traps all particles that are 5mm or greater and has a design treatment capacity that is either capable of handling the peak flow rate from a one-year, one-hour storm; or appropriately designed to handle at least the same flow as the corresponding storm drain. Full capture devices must be certified by the Water Board.

The current certified list is comprised of small units (i.e. catch basin inserts) and high flow capacity devices (i.e. inline, end of pipe, and vault systems). Costs vary from $100’s (catch basin inserts) to $1,000 – $100,000s + for each “high flow” unit.

The main obstacles the City will face in achieving the State’s goals under Track 1 is the initial capital costs for the devices over the next 10 years, annual maintenance of the filters, and the cost of additional staff and staff time to monitor and maintain the storm water system for full capture.

Track2

Track 2, which is the Full capture equivalency involves installation, operations and maintenance of any combination of full capture systems, multi-benefit projects, treatment controls (LID), institutional controls (i.e. street sweeping, drain maintenance, enforcement, etc.).

The City would need to demonstrate that the MS4’s approach will achieve full trash capture. In order to demonstrate that the MS4’s approach will achieve equivalency the City would submit a jurisdictional map identifying Priority Land Uses (PLUs), corresponding storm drain network & associated drainage areas, and proposed locations for treatment controls.

The City would also be required to physically assess PLUs for existing levels of trash generation.

The City will also need to develop and submit an implementation plan that must be reviewed and approved by the Regional Water Quality Control Board that includes the rationale for how the selected combination of controls will achieve full capture system equivalency; the rationale for how full capture system equivalency will be demonstrated; a description of alternative methodology for the assessment and rationale for equivalency if the recommended approach is not used; and if selecting alternative locations or land uses then the PLUs, a rationale demonstrating that the alternative land uses generate trash at rates that are equivalent to or greater than the PLUs.

The main obstacles the City will face in achieving the State’s goals under Track 2 are the initial capital costs for full capture and other system improvements, on-going administrative costs, additional staffing to continually make assessments, develop plans, monitoring and plan implementation.

There will also be on­ going maintenance costs. The City would also need to submit the implementation plan to the Regional Board for review and approval.

After a thorough review of Track options 1 and 2, staff is recommending to the City Council that Track 1 be selected for implementation.

The City would have until December 2025 to fully meet the requirement of full trash capture.

Track 2 would require the same results by December 2025, but would involve more assessments, monitoring, and mapping, which would require additional staff to meet these requirements.

FISCAL IMP ACT:

There is no fiscal impact at this time. Costs will be incurred once the Track 1 measures are implemented. Staff will present recommended improvements for City Council consideration and approval prior to proceeding with the work. Staff will also investigate funding methods and mechanisms.

ATTACHMENTS:

1. Water Code Section 13383 Order to Submit Method to Comply with Statewide Trash Provisions; Requirements for Traditional Small Municipal Separate Storm Sewer System (MS4) Permittees.

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