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4. Provision C. 2: The Regional Boards has found that there is a reasonable potential <br />that municipal stormwater discharges may be causing or contributing to an excursion <br />above water quality standards for: a) copper, nickel, mercury, dioxin -like compounds, <br />DDT, dieldrin, chlordane, and PCBs into Lower and South San Francisco Bay; b) <br />sediment in Pescadero Creek, San Francisquito Creek, and San Gregorio Creek <br />basins; and c) diazinon in San Francisquito Creek, San Mateo Creek, and Lower and <br />South San Francisco Bay (Finding 12). Therefore the dischargers are legally required <br />to submit a report that describes BMPs that are currently being implemented and <br />additional BMPs that will be implemented to prevent or reduce the above listed <br />pollutants that may be causing or contributing to the exceedance of WQSs (see <br />provision C.2 for specific requirements for reporting). This provision is a narrative <br />water quality -based effluent limitation that will ensure that the discharges do not <br />cause or contribute to impairment of these water bodies. <br />5. Provision C.3 and CA: These provisions require the implementation of the... <br />Dischargers' Plan and Performance Standards and essentially incorporate the Plan, <br />including the Performance Standards, into the permit, thus making its implementation <br />enforceable. It also establishes, in conjunction with Provision C.1, the Plan and <br />Performance Standards as the focal points of the permit. As such, the Plan, including <br />the Performance Standards, is considered a living document that will change and <br />improve with time. Specifically, all other plans required by the permit are expected tc <br />be incorporated into the Plan. <br />6. Provision C.5 through C.7: These provisions require submittal of Annual and Mid - <br />Fiscal Year Reports. The information required in the Annual and Mid -Fiscal Year <br />Reports is equivalent to that required in storm water regulations pursuant to 40 CFR <br />122.41(1) and the Basin Plan. The elements of the Annual and Mid -Fiscal Year <br />Reports will ensure that programs and performance standards are developed and <br />implemented and will allow evaluation of compliance with permit conditions. The <br />Annual Report also provides a focus to review, update, or revise the Plan on an <br />annual basis. Provision C.5 establishes a process for submittal of two-year Work <br />Plans by the Dischargers that detail specific tasks and actions to be implemented on a <br />fiscal year basis. <br />7. Provision C.8: This provision requires the annual submittal and implementation of a <br />Monitoring Program Plan in accordance with 40 CFR Parts 122.44(n and 122.48 <br />which demonstrates the effectiveness of the Plan and accordingly, demonstrates <br />compliance with the conditions of the permit. Rather than requiring specific types, <br />locations, and frequencies of monitoring activities, this provision establishes <br />objectives for implementing the Monitoring Program Plan. This is intended to <br />provide flexibility and efficiency in determining specific monitoring activities while <br />establishing a basis for determining effectiveness of monitoring activities. <br />