Laserfiche WebLink
e,A6 L Cl M f2 <br /> California Regional Water Quality Control BoarQ <br /> Central Valley Region yr <br /> Robert Schneider,Chair <br /> Terry Tamminen Arnold Schwarzenegger <br /> Secretary for Sacramento Main Office Governor <br /> Environmental Internet Address: bttp://w .swcb.ca.gov/r gcb5 <br /> Protection 11020 Sun Center(hive#200 Rancho Cordova,CA 95670-6114 <br /> Phone(916)464-3291 <br /> 29 June 2004 <br /> Mr.Mark Madison, Director Mr. Thomas Flinn, Director <br /> City of Stockton County of San Joaquin <br /> Department of Municipal Utilities Public Works Department <br /> 2500 Navy Drive P.O. Box 1810 <br /> Stockton, CA 95206-1191 Stockton, CA 95201-1810 <br /> COMMENTS ON CITY OF STOCKTON AND SAN JOAQUIN COUNTY PATHOGEN PLAN <br /> This letter provides comments on the subject plan, which was submitted pursuant to the City and <br /> County's municipal storm sewer NPDES permit (Order No. R5-2002-0181). The requirements for this <br /> plan are provided in Provision D.18.b of the permit. In general, Regional Board staff found the plan to <br /> be thorough and well thought out; however,we have the following comments that we hope will improve <br /> the plan: <br /> • While we agree with the Permittees' methodical procedure of investigating the pathogen sources <br /> and developing appropriate BMPs, it is clear there are some BMPs that the Permittees can <br /> implement in the short-term to ameliorate the pathogen problem. For example, Section 2.4.5 on <br /> Page 22 discusses the Permittees' current activities for controlling pathogen contributions from <br /> domestic pet wastes. One BMP is ensuring that the animal holding areas of the Permittees' <br /> pounds are plumbed to the sanitary sewer. These facilities are periodically washed down and the <br /> rinse water certainly contains pet waste. Private kennels share these same conditions. Since the <br /> Permittees' MS4 permit requires inspection of kennels, these inspections should ensure that any <br /> rinse water being generated is properly managed. Additionally, Page 23 states that"pet waste <br /> bags have been made available in some parks." This is an inadequate description of this <br /> worthwhile BMP. Have you designated some threshold of dog walker traffic to justify dog waste <br /> disposal stations? Have you installed stations as quickly as practicable and developed a schedule <br /> for station installation? The plan should identify BMPs such as these that the Permittees intend <br /> to implement in the short-term and concurrently with the ongoing studies. You certainly know <br /> more about your municipalities than we do. Perhaps you can think of a few more BMPs (either <br /> new or improvements to existing ones) that fall into this category. <br /> California Environmental Protection Agency <br /> Q*Recycled Paper <br />