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City of Stockton'and County of San Joaquin Page 72 NPDES Permit CAS0083470 Response to Comments Response: The six-month deadline for re-stenciling drain inlets is intended to account for the large number of inlets in the Stockton urban area, which we estimate to be in the thousands. Where feasible,we expect re-stenciling to be accomplished more quickly;but we recognize that the potential volume of drain inlets requiring re-stenciling may preclude a shorter deadline. Although the deadline was not changed,we did modify the subject requirement and add one related requirement as follows: "As part of regular inspection and maintenance of storm drain inlets, each Permittee shall inspect the legibility of the drain inlet stencil or label nearest the inlet. Drain inlets with illegible warnings shall be recorded and re-stenciled or re-labeled within 180 days of inspection." "Each Permittee shall stencil or label (e.g., "No Dumping—Drains to Creek") drain inlets within its jurisdiction and the urbanized permit area. Permittees with legible stenciling at 95 percent of their drain inlets at the end of the term of this Order shall be deemed to be in compliance with this requirement." 45. Comment: (DK Comment 5(0)) SWMP Municipal Program 12(b)(vii),Detention Basin Construction and Maintenance: please describe how requirements to prepare and implement guidelines for maintaining detention basins correlates with establishing performance standards to ensure that the Permittees have a demonstratively effective detention basin maintenance program that rises to MEP. Response: These guidelines will be presented in the Permittees' revised SWMP. Once the SWMP is approved by the Regional Board, the guidelines will be an enforceable part of the Order. We expect the Permittees to propose performance standards along with their detention basin guidelines. We request that DeltaKeeper withholds judgment on this issue until the Permittees have had the opportunity to present their proposals in the SWMP. 46. Comment: (DK Comment 5(p)) SWMP Municipal Program 12(b)(viii)(a&b), Streets and Roads Maintenance: Even a casual observer cannot fail to appreciate that the present street sweeping efforts by the Permittees are grossly inadequate. Again, the performance standards contained in the previous tentative permit have been reduced in the present Permit (i.e., Priority C segments shall be swept"as necessary"has replaced"as necessary but in no case less than once a year"). There are no guidelines describing how Priority A,B and C street segments will be designated. Conceivably, the Permittees could arbitrarily select a few street segments as Priority A and dismiss the majority as Priority C. How much street debris or what volume of traffic separates a Priority A from Priority B or C? There are no performance standards to ensure that street maintenance efforts rise to an MEP level for street and road maintenance. There are vast differences in removal efficiencies between old and modern street sweepers. We have observed many of the older street sweepers leaving large quantities of fine particles in the streets. Modem street sweepers remove these fine particles. Please define the performance standard for street sweeping.