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%W <br /> City of Stockton and County of San Joaquin Page 71 <br /> NPDES Permit CAS0083470 <br /> Response to Comments <br /> products, etc. Additionally,DeltaKeeper believes that where inspections identify violations, follow <br /> up inspections must be conducted with three months. <br /> Response: See response to Comment 39. <br /> 42. Comment: (DK Comment 5(1)) SWMP Industrial/Commercial Program 11(c)(iii)(b): Language <br /> should be revised to require investigation of all complaints (including unauthorized non-storm <br /> water complaints)within two days. DeltaKeeper has received numerous calls from Stockton <br /> residents expressing dissatisfaction that their complaints to the Permittees were not responded to or <br /> resolved in a timely manner. <br /> Response: See response to Comment 39. <br /> 43. Comment: (DK Comment 5(m)) SWMP Municipal Program 12(b)(v)(a), Storm Drains/Sumps <br /> Operation and Management: DeltaKeeper is puzzled why the more rigorous requirements contained <br /> in the previous tentative Permit were eliminated. Stone drains inlets, catch basins and sumps are, in <br /> many respects, the last line of defense in efforts to keep pollutants out of waterways. On numerous <br /> occasions, DeltaKeeper has informed Regional Board staff that localized flooding from clogged <br /> inlet or catch basins frequently occurs throughout the rainy season in Stockton. The previous <br /> tentative permit established minimum performance standards for cleaning catch basins. We urged <br /> that the previous tentative Permit be clarified to clearly require that this also applied to the regular <br /> removal of debris from storm drain inlet basins. The minimum performance standards in the <br /> previous tentative permit have been replaced in the present tentative permit by a requirement <br /> directing the Permittees to develop maintenance procedures based on prioritization efforts (and a <br /> minimum of once a year cleaning for prioritized catch basins). Please define prioritization efforts <br /> and how this relates to performance standards to ensure that debris is removed from the storm sewer <br /> system to the MEP. <br /> Response: We expect the Permittees to present a tiered prioritization system for catch basin inlets <br /> similar to the one proposed for street sweeping activities. Debris will be removed from all catch <br /> basins at least annually. The tiered system is intended to identify those catch basins that require <br /> cleaning more often than annually. We request that DeltaKeeper withholds judgment on this issue <br /> until the Permittees have had the opportunity to present their proposals in the SWMP. DeltaKeeper <br /> will have the opportunity to comment on the proposed SWMP. <br /> 44. Comment: (DK Comment 5(n)) SWMP Municipal Program 12(b)(v)(a), Storm Drains/Sumps <br /> Operation and Management: Permittees are required to inspect the legibility of catch basin <br /> stencils/labels and re-labeled within 180 days of inspection. This is a prime example of the lack of <br /> performance standards that we find throughout the Permit. There is no inspection schedule. <br /> Presently, there are a large number of catch basins that have illegible stencils/labels. The Permittees <br /> could wait until the end of the Permit cycle to inspect stencils/labels. Inspection and recording of <br /> catch basin stencils/labels that need to be re-stenciled/re-labeled should be tied to the regular <br /> inspection schedule. Six months is too long to wait for re-stenciling/re-labeling. This should occur <br /> before each rainy season. <br />