San Pablo City Council
June 2, 2025

No
te: IT/IM directives are reviewed annually for content, relevance, and clarity Form Rev. 08/21/2023

IT/IM DIRECTIVE

STANDARD
Quality Assurance Project Plan Standard

1. PURPOSE
This Standard supports the implementation of EPA’s Environmental Information Quality Policy and Environmental Information Quality Procedure.

All EPA organizations performing environmental information operations and non-EPA or
ganizations performing environmental information operations on behalf of EPA are r
equired to participate in the EPA Agency-wide Quality Program. EPA’s Quality Program s
upports EPA’s mission to protect human health and the environment and to ensure env
ironmental information operations products and services are of known and doc
umented quality for their intended use(s).

All work performed by or on behalf of EPA involving environmental information operations shall be implemented in accordance with an approved Quality Assurance Proj ect Plan (
QAPP).

The QAPP is a formal planning document which describes how environmental informati on oper
ations are planned, implemented, documented, and assessed during the life cycle of a project. The QAPP describes in comprehensive detail the necessary Quality Assurance (
QA) and Quality Control (QC) requirements and other technical activities that must be i
mplemented to ensure that the results of the environmental information operations performed will satisfy the stated performance and acceptance criteria.

QAPPs must be approved in accordance with this Standard. EPA QA Managers (QAM), as defined by the organization’s Quality Management Plan (QMP), review and approve Q
APPs for all environmental information operations projects prior to any information gat
hering work, or use, except under circumstances requiring immediate action to protect human health and the environment or operations conducted under police powers.

2. SCOPE
This St
andard defines the minimum requirements for QAPPs for EPA and non-EPA or
ganizations performing environmental information operations. Environmental information operations is a collective term that encompasses the collection, production, evaluation, or use of environmental information by or for EPA and the design, construction, operation, or application of environmental technology.

3. AUDIENCE
The audience for this Standard is all Agency employees responsible for environmental information operations. This includes EPA Regions, Program Offices, and their sub- organizations hereafter referred to as EPA organizations.

Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

No
te: IT/IM directives are reviewed annually for content, relevance, and clarity Form Rev. 08/21/2023

IT/IM DIRECTIVE

STANDARD
This Standard also applies to non-EPA organizations performing environmental information operations in support of EPA’s mission or national program priorities as defined by and in accordance with:
• federal laws and legal requirements including administrative orders/enforcement actions,
• r
egulations,
• extramural agreements, or
• performing work on a voluntary basis under agreement with EPA.

This Standard will be applied to non-EPA organizations as described in the current version of the EPA organizations’ QMP that is sponsoring the work.

Non-EPA
organizations include but are not limited to:
• contractors,
• regulated parties,
• cooperative agreement holders,
• grantees,
• states, tribes, territories, localities, intergovernmental agencies, • educational institutions, hospitals, non-profits,
• ot
her federal governmental agencies, and parties to Memoranda of Agreement or Understanding,
• volunteer organizations, and
• other environmental information providers.

4. AUTHO RITY
T
hese citations are valid at the time of issuance of this Standard. Since these documents are subject to periodic review, users of this Standard should refer to the most recent version.
• U.S.C. App.; Pub. L. 98–80, 84 Stat. 2086 (Reorganization Plan No. 3 of 1970) • Information Quality Act, Se ction 515 of Treasury and Government Appropriations Act, 2001 (PL 106-554, 31 USC 3516) (Refer to Page 114 STAT.2763A-154) • 2 CFR 1500.12: U niform Administration Requirements, Cost Principles and Audit Requirements for Federal Awards, Quality Assurance
• 40
CFR Part 35: State and Local Assistance
• 48 CFR P
art 46: Quality Assurance
• 40 C FR Appendix A to Part 58 – Qua lity Assurance Requirements for Monitors used in Evaluations of National Ambient Air Quality Standards Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

No
te: IT/IM directives are reviewed annually for content, relevance, and clarity Form Rev. 08/21/2023

IT/IM DIRECTIVE

STANDARD

5. STANDARD
A. Q

APP OVERVIEW

1. GENERAL CONTENT
All work performed by or on behalf of EPA involving the collection, production, ev
aluation, or use of environmental information including the design, construction, operation, or application of environmental technology must be documented in a Q
APP.

The QAPP shall be composed of standardized, recognizable elements covering t
he entire project from planning, through implementation, to assessment, and final data use and reporting. Section 5.B QAPP REQUIREMENTS of this document describes requirements for QAPPs.

The EPA organization sponsoring the work has the authority to define any special requirements beyond those listed in this Standard. Each EPA organization shall def
ine their organization-specific requirements for QAPP documentation in their QMP. All applicable elements defined by the EPA organization sponsoring the work must be addressed.

2. LEVEL OF DETAIL: THE GRADED APPROACH AND QAPPs
A QAPP is unique to its specific project. Implementation of the Quality Policy and Procedure allows for the principle of the graded approach to be applied to the systematic planning, development, and approval of QAPPs.

The graded approach establishes the QA and QC requirements commensurate with the complexity and type of work, how the results will be used, , the available resources, and the unique needs of the organization or the customer (for contracts). The level of detail to be applied to activities listed in the QAPP are developed and then documented according to the intended use and the degree of confidence needed in the quality of the results.

The Graded Approach is not a mechanism to waive requirements. If an element is not applicable, an explanation as to why it is not applicable shall be provided in the QAPP.

3. QAPP PREPA

RATION RESPONSIBILITY
T
he QAPP is prepared by EPA and the organizations listed in Section 3. In most instances, the preparation of the QAPP is the responsibility of the organization per
forming the environmental information operations.
• EPA Organizations
The EPA organization’s senior manager having executive leadership authority for the organization is responsible for assuring the preparation and
approval of QAPPs as per the organization’s approved QMP to cover Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

No
te: IT/IM directives are reviewed annually for content, relevance, and clarity Form Rev. 08/21/2023

IT/IM DIRECTIVE

STANDARD
all environmental information operations to be performed under the Quality Program.

T
he actual
preparation of the QAPP may be assigned to managers of the environmental information operations (Operations Managers) and/or designees within the organization.
• Non-EPA Organizations
The senior manager of the non-EPA organization is responsible for assuring the preparation and appropriate approval of QAPPs that cover all environmental information operations specified by the applicable ex
tramural agreement(s) and for which the organization’s management is accountable.

The actual preparation of the QAPP may be assigned to Operations Managers and/or designees within the organization.

4. QAPP SUBMITTAL AND APPROVAL
QAPPs must be approved prior to the collection, production, evaluation, or use of environmental information including the design, construction, operation, or application of environmental technology except under circumstances requiring immediate emergency response action to protect human health and the env
ironment or operations conducted under police powers.
• EPA Organizations
QAPPs shall be submitted to the QAM or designee as specified in the or
ganization’s QMP and follow internal processes for review and appr
oval.

The EPA organization’s QAM or designee has authority to review and appr
ove QAPPs within their organization as stated in the organization’s approved QMP.

In emergency response cases, QAPPs shall be approved during the env
ironmental information operations in accordance with the sponsoring or
ganization’s QMP and other applicable EPA-approved QMPs (such as the contractor’s QMP).
• Non-EPA Org anizations:

The QAPP shall be submitted for review and approval to the EPA official responsible for the work, who will then follow the approval procedures listed in the sponsoring organization’s QMP. The EPA official may include t
he contracting officer’s representative (COR), the grant project officer (PO), and the EPA QAM in accordance with their organization’s overall approved QMP.

Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

No
te: IT/IM directives are reviewed annually for content, relevance, and clarity Form Rev. 08/21/2023

IT/IM DIRECTIVE

STANDARD
Non-EPA Organizations shall also consult with the EPA organization sponsoring the work for additional requirements for document submittal and approval.
• S
tates, Tribes, and Territories: If stated in the EPA sponsoring or
ganization’s QMP, approval of the state, tribal, or territory QMP may include delegated QA activities to include, but not limited to QAPP approvals and training. In these cases, states, tribes, or territories with del
egated approval for QAPPs, shall follow the QAPP approval processes as stated in their EPA-approved QMP.

5. PERIOD OF APPLICABILITY OF AN APPROVED QAPP
• EPA Organizations: QAPPs approved under this Standard shall be valid f
or no more than the lesser of five years or shorter duration as may be def
ined for the project.
• States, Tribes, Territories, and Other Federal Agencies: QAPPs approved under this Standard shall be valid for no more than the lesser of five years or shorter duration as may be defined in the extramural agreement.
• All other non-EPA organizations: QAPPs approved under this Standard shall be valid for no more than five years or shorter duration as may be
def
ined in the extramural agreement, contract, memorandum of understanding /agreement, or legal agreement.

If a QAPP no longer meets the requirements of this Standard, approving officials may rescind their approval prior to the period of applicability listed.

6. QAPP ANNUAL REVIEWS AND REVISIONS
Annual Reviews
All EPA and non-EPA organizations required to have a QAPP shall review their QAPP at least annually to confirm its suitability and evaluate its effectiveness for the project. Projects less than one year in duration will not be required to have an annual review.

The review shall be documented and made available to the QAM of the sponsoring organization if requested.

Non-EPA organizations shall contact the EPA organization sponsoring the work for additional requirements for QAPP annual reviews.

Revisio
ns
Although the approved QAPP should be implemented as approved, it is a flexible, living document. Because of the complex and diverse nature of environmental Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

No
te: IT/IM directives are reviewed annually for content, relevance, and clarity Form Rev. 08/21/2023

IT/IM DIRECTIVE

STANDARD
information operations, changes to original plans may be needed.

When necessary, the organization shall revise its QAPP to incorporate minor changes and notify the approving authority of the changes. In general, a copy of any QAPP revision(s) made during the year should be submitted to the approving authority (QAM or designee) in writing when such changes occur.

I
f significant changes have been made to the project, it may be necessary to re- submit the entire QAPP for re-approval. When significant changes occur, the approving authority (QAM or designee) shall determine if the change significantly impacts the technical and/or quality objectives of the project. The QAM may consult with the Operations Manager for this determination.

If it is determined that the QAPP must be revised and submitted for re-approval, the originator of the QAPP shall submit the revision for approval to the same organization with approving authority that performed the original review. The submission shall include a revision history page that briefly summarizes the changes made. No work under the changed condition shall be performed until the QAPP is reviewed and approved.

Signif
icant changes that may require the revision and resubmittal of an approved QAPP include: change in the scope of the project resulting in new or revised project objectives; changes in implementation such as how information will be collected, produced, evaluated or used; changes in the design, construction, operation, or application of environmental technology; change in the statement of work or workplan for extramural agreements; expiration of the QAPP; changes in the organization’s mission or structure, such as in the delegation status of QAPPs; or changes in performance criteria as to how results will be assessed for acceptance.

All personnel in the organization performing environmental information operations covered by the scope of the QAPP shall be notified of the changes. This practice shall also include contractors, sub-contractors, and grantees associated with the environmental information operations described in the QAPP.

B. QAPP REQUIREMENT
S
Q
APPs are required for all work performed by or on behalf of EPA involving the collection, production, evaluation, or use of environmental information and the design, construction, operation, or application of environmental technology.

Environmental Information includes data and information that describe environmental processes or conditions. Examples include, but are not limited to:
• direct measurements of environmental parameters or processes. • analytical testing results of environmental conditions (e.g., geophysical or hydrological conditions).
• information on physical parameters or processes collected usi ng
env
ironmental technologies.
• calculations or analyses of environmental information. • information provided by models.

Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

No
te: IT/IM directives are reviewed annually for content, relevance, and clarity Form Rev. 08/21/2023

IT/IM DIRECTIVE

STANDARD
• information compiled or obtained from databases, software applications, decision support tools, websites, existing literature, and other sources. • development of environmental software, tools, models, methods, applications; and
• design, construction, and operation or application of environmental technology.

E
nviro
nmental Technology includes systems, devices and their components applicable to both hardware and methods or techniques that measure and/or remove pollutants or contaminants and/or prevent them from entering the environment. Examples include but are not limited to:
• Pollution prevention: measurement, monitoring, reduction, control, and/or treatment processes, such as wet scrubbers (air), granulated activated carbon uni
t (water), filtration (air, water).
• Contamination: containment to prevent further movement of the contaminants, such as capping, and solidification or vitrification, and biological treatment. • Storage containers, methods, or facilities, such as drums, tanks, and ponds or lagoons.
• Remediation processes and their components, and/or technologies, such as soil washing (soil), pump and treatment, soil vapor extraction (soil), lan d
f
arming and other bioremediation processes.

Because environmental information operations can encompass many different types of projects, the EPA organization sponsoring the work has authority to define their organization-specific content requirements for QAPPs by project type. QAPP preparers shall contact the EPA organization sponsoring the work for additional QAPP guidance, tools, and templates specific to the type of project.

The QAPP shall be composed of standardized, recognizable elements covering the entire project. Elements of a QAPP may be described or cited. If the designated references are well documented and are readily available to all key personnel, citations may be adequate; however, because weblinks and web addresses may change over time, one official, controlled version (such as pdf) of the referenced documents should be placed on file with the appropriate EPA office and available for routine referencing when needed.

The required QAPP elements have been arranged into four general groups. The four groups of elements are:
 GROUP A - Project Management and Information/Data Quality Objectives  GROUP B - Implementing Environmental Information Operations  GROUP C - Assessment and Oversight
 GROUP D - Environmental Information Review and Usability Determination
Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

No
te: IT/IM directives are reviewed annually for content, relevance, and clarity Form Rev. 08/21/2023

IT/IM DIRECTIVE

STANDARD

1. G
ROUP A ELEMENTS: PROJECT MANAGEMENT AND INFORMATION/DATA Q

UALITY OBJECTIVES
The elements in Group A (Table 1) address project management including project history and roles and responsibilities of the personnel involved in the project.

These elements document that the project has defined information/data quality objectives, that strategies are in place to help personnel understand the approach to be used, and that the planning has occurred. QAPPs should contain all of the G
roup A elements.

Group A: Project Management and Information/Data Quality Objectives Element Description
A1 Title Page
A2 Approval Page
A3 Table of Contents,
Document Control
Document Format, and
A4 Project Purpose, Problem Definition, and
Background
A5 Project Task Description
A6 Information/Data Quality Objectives and
Performance/Acceptance Criteria
A7 Distribution List
A8 Project Organization
A9 Project QAM Independence
A10 Project Organizational Chart and
Communications
A11 Personnel Training/Certification
A12 Documents and Records
Table 1
A1 – Title Page
The Title Page shall contain the name of the document to include “Quality Assurance Project Plan”; date of QAPP preparation; organization conducting the environmental information operations; name of organization that developed the QAPP (if different from organization conducting the work); period of applicability; and revision/version control information.

Non-EPA Organizations shall also specify:
• Grant or cooperative agreement number if the work is performed under an
EP
A assistance agreement
• Contract number and Task Order number (if applicable) if the work is performed under an EPA contract acquisition
• Interagency Agreement number if the work is performed under an I
nteragency Agreement
Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

No
te: IT/IM directives are reviewed annually for content, relevance, and clarity Form Rev. 08/21/2023

IT/IM DIRECTIVE

STANDARD
• Title and date of the Memoranda of Understanding/Agreement if applicable
• Citation of the regulatory requirement if applicable, or • Title and date of the enforcement or legal agreement if applicable A2 – Approval Page
Q
APP
s shall include signatures from the Operations Manager or designee and QAM or designee. Electronic signatures and equivalent electronic approval systems are acceptable. At a minimum, signatures shall include:
• E
PA Organizations:
- Operations Manager or designee, and
- EP
A QAM or designee as specified in the organization’s QMP. • Non-EPA Organizations:
- Operations Manager or designee for the project,
- Project QAM or individual with QAM responsibilities for the project - QAPPs requiring EPA approval shall also include:
 EPA signature from operations (COR or PO) and
 E
PA QAM or designee.

For specific signatures to include, contact the EPA organization sponsoring the work.

A3 – Table of Contents, Document Format, and Document Control T
able of Contents
The Tabl
e of Contents shall include location of sections, tables, diagrams, charts, worksheets (if used), and other deliverables.

Document Format
In general, the organization developing the QAPP should follow the format and section headings of this QAPP Standard to expedite review and approval.

QAPP preparers shall contact the EPA organization sponsoring the work for additional format requirements. The Environmental Information Quality Procedure authorizes the EPA organization sponsoring the work to determine guidance or tools suitable for QAPPs where projects do not readily fit in the structure or described contents of this Standard. National Program Offices may also provide program direction to the Regional Program Offices on National Program QA guidance and requirements.

Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

No
te: IT/IM directives are reviewed annually for content, relevance, and clarity Form Rev. 08/21/2023

IT/IM DIRECTIVE

STANDARD
Document Control
Document Control is used to identify the most current version of the QAPP and shall be included on every page.

D
ocument con
trol for the QAPP shall include at a minimum:
• The title of the document (abbreviations are acceptable), • The version number of the document (original or revision number), • The date of the version, and
• The page number in relation to the total number of pages.

A4 – P roject Purpose, Problem Definition, and Background The QAPP shall identify and address other QA planning documents that have relevant requirements such as QMPs.

The QAPP is the output or result of systematic planning. Its purpose is to document the purpose of the project, the environmental information operations needed to meet those goals, and the application of quality management strategies to those goals.

For additi
onal guidance on systematic planning, refer to the current version of EPA Guidance for the Data Quality Objectives Process.

Project Purpose and Problem Definition
The QAPP shall describe the purpose of the project’s environmental information operations (to include, but not limited to research, monitoring, environmental technology for clean-up, and use of existing data from other sources) and define the problem(s) to be addressed and question(s) to be answered.

The QAPP shall also document the environmental decision(s) that need to be made and the level of information quality needed to ensure that those decisions are based on sound environmental information.

The QAPP shall identify the type, quantity, and quality of information needed for its intended use and describe the acceptance and performance criteria.

The QAPP shall include the following as applicable:
• Identification of the applicable regulatory programs and standards, • conceptual site model(s), and
• a discussion that directly links the results of the environmental information operations to possible actions.

Project Background
The QAPP s
hall describe and/or cite background information, plans, and/or reports to provide the historical, scientific, and regulatory perspective for the project as well as identify the sources for existing information for the project.

Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

No
te: IT/IM directives are reviewed annually for content, relevance, and clarity Form Rev. 08/21/2023

IT/IM DIRECTIVE

STANDARD
A5 – Project Task Description
The QAPP shall include all project tasks and the schedule for accomplishing the tasks. The QAPP shall also include the following:
• description of work to be performed, and
• products to be produced.

A
6 – Information/Data Quality Objectives and Performance/A cceptance Criteria
The QAP
P shall describe the project’s information/data quality objectives, the performance and/or acceptance criteria to achieve those objectives, and the information/data quality indicators.

Performance criteria address the adequacy of information that is to be collected for the project. These criteria often apply to new information collected for a specific use.

Acceptance criteria address the adequacy of existing information proposed for inclusion in the project. These criteria often apply to information drawn from existing sources. Identifying the information/data quality objectives ensures that the quality goals of the project are clearly defined and communicated, guiding the conduct of environmental information operations to provide information of known and documented quality. For example, the QAPP shall describe performance and acceptance criteria for laboratory analytical methods (each matrix, each analyte or analyte group, and concentration level). Information/Data Quality Indicators (DQI) are qualitative and quantitative measures of information/data quality attributes associated with the environmental information.

The principal DQIs for environmental information projects are precision, accuracy (bias), representativeness, comparability, completeness, and sensitivity. However, depending on the type of project, other DQIs may be more appropriate. DQIs are typically applied to the laboratory measurement processes, but DQIs can be identified to capture the effects of other important processes and procedures on the overall quality of environmental Information.

The six standard DQIs are also referred to by the acronym PARCCS:
• Precisio
n is the measure of agreement among repeated measurements of the same property under identical, or substantially similar, conditions. • Accuracy (Bias) is a measure of the overall agreement of a measurement to a k
nown value.
• Representativeness is defined as the measure of the degree to which data ac
curately and precisely represent a characteristic of a population, parameter variations at a sampling point, a process condition, or an environmental condition.

Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

No
te: IT/IM directives are reviewed annually for content, relevance, and clarity Form Rev. 08/21/2023

IT/IM DIRECTIVE

STANDARD
• Comparability is the qualitative term that expresses the measure of confidence that two or more data sets can contribute to a common analysis.

Before pooling data, the comparability of data sets generated at different times or different organizations must be evaluated in order to establis h
w
hether two data sets can be considered equivalent in regard to the meas
urement of a specific variable or groups of variables.
• C
ompleteness is a measure of the amount of valid data obtained from a meas
urement system, expressed as a percentage of the number of valid meas
urements that should have been collected (i.e., measurements that were pl
anned to be collected).
• Sensitivity is the capability of a method or instrument to discriminate between measurement responses representing different levels of the variable of interest. The term "detection limit" is closely related to sensitivity and is oft en
us
ed synonymously.

Please contact the EPA organization sponsoring the work for additional information and requirements for performance and/or acceptance criteria, and information/data quality indicators.

A7 – Distribution List
The Q
AP
P distribution list shall include all individuals and their organizations who shall receive copies of the approved QAPP and any subsequent revisions. A lso, a complete copy of the original version and all revisions of the QAPP shall be maintained on file by the organization responsible for conducting the environmental information operations and made available to approval authorities upon request.

The distribution list shall include the following:
• Operations Manager
• QAM
• Other operations and quality personnel involved in environmental information operations for the project to include those working for th e
or
ganization responsible for conducting the environmental information oper
ations as well as contractors, subcontractors and grantees in key operations and quality roles.

A8 – Project O rganization
The QAP
P shall identify the individuals and organizations participating in the project or the environmental information operations and describe their roles and responsibilities. Specifically, the QAPP shall identify individuals with the following roles and describe their responsibilities:
• The approval authority for the QAPP.

Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

No
te: IT/IM directives are reviewed annually for content, relevance, and clarity Form Rev. 08/21/2023

IT/IM DIRECTIVE

STANDARD
• The senior manager having executive leadership authority for the or
ganization conducting the environmental information operations One r
esponsibility of the senior manager is providing resources. Resources are knowledgeable personnel, funding, materials, supplies, and time. • The project Operations Manager for the organization conducting the environmental information operations.
• The Project QAM for the organization conducting the environmental operations. The QAPP shall describe the Project QAM’s oversight authority and responsibilities for planning, documenting, coordinating. and assessing effectiveness of the QAPP. The QAPP shall also describe the QAM’s authority to access and discuss quality-relate d
i
ssues with their organization’s senior manager outside of their direct supervisory chain as necessary.
• The individual responsible for maintaining the QAPP.
• Titles, roles, and names (if determined during planning) of operations and quality individuals within the organization conducting or supporting env
ironmental information operations and their reporting relationships. • Identification of all contractors, subcontractors, sub-grantees, supporting environmental information operations and their project role and responsibilities.
• Principal environmental information or data users within the organization c
onducting the environmental information operations as well as outside of this organization.

A9 –
Project Qu ality Assurance Manager Independence
The Projec
t QAM shall be independent of environmental information operations.

The QAPP shall describe how the Project QAM’s independence is ensured. The Project QAM is not required to be independent of senior officials, such as corporate managers or agency administrators, who are nominally, but not functionally, involved in environmental information operations. The Operations Manager or designee will not have authority to sign QAPPs for the QAM or designee, nor will the QAM or designee have authority to sign QAPPs for the Operations Manager or designee.

The two functions, QA and operations, must remain independent; however, in small organizations outside of EPA and EPA contractors (e.g., small tribal departments), these two functions may be combined with approval from the EPA QAM.

A10 – Project Organization Chart and Communications

The Project Organization Chart
The Project Organization Chart shows both the lines of authority to include the reporting relationships and the lines of communication both within the organization Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

No
te: IT/IM directives are reviewed annually for content, relevance, and clarity Form Rev. 08/21/2023

IT/IM DIRECTIVE

STANDARD
responsible for the environmental operations and between the organization responsible for the work and all organizations involved in the project.

T
he Project Organization Chart shall also include the following:
• The name of the organization responsible for conducting the env
ironmental information operations.
• Identification of all contractors, subcontractors, and sub-grantees and t
heir reporting relationships to the organization responsible for conducting the environmental information operations.
• The individual in the senior manager role.
• The individual in the Project Operations Manager role for the or
ganization conducting the environmental information operations and their reporting relationship to the senior manager.
• The individual in the Project QAM role for the organization conducting t
he environmental information operations, their independence from env
ironmental information operations, and their reporting relationship to t
he senior manager. If the senior manager does not directly supervise t
he QAM, the QAM must have authority to access and discuss quality- related issues with the senior manager outside of their direct supervisory chain as necessary. The latter is demonstrated by a dotted l
ine on the organizational chart.
• Titles, roles, and names (if determined during planning) of operations and quality individuals within the organization conducting or supporti ng
env
ironmental information operations and their reporting relationships.

Lines of communication, communication pathways and communication mechanisms shall be determined during planning and documented in the QAPP.

Communication procedures including timing of communication shall be outlined in sufficient detail to ensure that users of the QAPP understand the processes and the roles and responsibilities associated with those processes when communication is necessary.

The QAPP shall describe or cite the standard procedures for communications to include elevating discrepancies and QAPP non-conformances; process improvements; and seeking concurrence and approvals between project personnel, and/or between contractors within the organization responsible for conducting environmental information operations.

Non-EPA Organizations - Shall also describe communication procedures to EPA to include elevating discrepancies and QAPP non-conformances.

A11 – Personnel Training/Certification
Personnel responsible for conducting env
ironmental information operations
identified in the QAPP shall have appropriate qualifications, education, training, experience, and knowledge of the requirements of the work activities to be performed.

Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

No
te: IT/IM directives are reviewed annually for content, relevance, and clarity Form Rev. 08/21/2023

IT/IM DIRECTIVE

STANDARD
The QAPP shall identify the individual responsible for ensuring personnel conducting environmental information operations are qualified, trained, and experienced.

The Q
APP shall identify the individual responsible for documenting personnel training.

The QAPP shall identify and describe any specialized t raining or certifications needed by personnel to successfully participate in the environmental information operations. Training may include on-the-job training as well as training on internal procedures. Additionally, the QAPP shall describe how the training will be provided, how the necessary skills will be assured, and the procedure or system that will document training records and skill evaluation.

EPA Orga
nizations - QAPPs for EPA Organizations conducting environmental information operations involving field activities shall also include or reference all Personnel and Training requirements identified in the current version of the EPA Quality Assurance Field Activities Procedure (QAFAP).

A12 – D ocuments and Records
The QA
PP shall identify documents and records that will be produced for projects that involve environmental information operations. The QAPP shall also describe or reference the management of the documents and records, including the QAPP.

Management of project information is covered in the Group B Elements, Implementing Environmental Information Operations, B7 Environmental Information Management.

The QAPP shall include or reference all applicable requirements for the final disposition of records and documents, including location and length of retention period. The organization responsible for conducting the environmental information operations shall maintain a system for the control of all documents including preparation, review, approval, issuance, revision, and archiving documents.

EPA Organizations - QAPPs for EPA Organizations conducting environmental information operations involving field activities shall also include all Document Control and Records Management requirements identified in the EPA QAFAP.

2. G
ROUP B ELEMENTS: IMPLEMENTING ENVIRONMENTAL INFORMATIO N O

PERATIONS
Gr
oup B Elements identify and address all aspects of environmental information oper
ations to help to ensure products and services are of known and documente d q
uality and to evaluate the products and services delivered under the project.

This section of the QAPP describes in comprehensive detail the implementation of necessary QA and QC requirements and other technical activities to ensure that the results of the environmental information operations performed will satisfy the Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

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intended purpose, and the information/data quality objectives and performance/acceptance criteria in the Group A4 and A6 Elements.

T
he Group B elements in Table 2 shall be addressed in the QAPP. Most of the Group B Elements are unique to the type of environmental information operations in the project. The EPA sponsoring organization may have organization or project specific requirements for QAPP documentation in their QMP. If so, these elements also must be addressed.

If a Group B element is not applicable to the project based on the type of project, the QAPP shall 1.) state that the specific element “Does Not Apply” and why, or

2.) reference the project specific requirements provided by the EPA sponsoring organization that shall be used.

The QAPP shall describe all guidance, tools, and templates used to develop the QAPP.

EPA Organizations only - Conducting environmental information operations involving field activities shall also include all requirements identified in the EPA QAFAP.

Group B: Implementing Environmental Information Operations Element Description
B1 Identification of Project
Operations
Environmental Information
B2 Methods for Environmental Information Acquisition
B3 Integrity of Environmental Information
B4 Quality Control
B5 Instruments/Equipment Calibration, Testing, Inspection, and Maintenance
B6 Inspection/Acceptance of Supplies and Services
B7 Environmental Information Management
Table 2
In the Group B Section, if the Standard Operating Procedures (SOPs) and/or referenced materials are well documented and readily available to all key personnel, citations may be adequate; however, because weblinks and web addresses may change over time, one current, controlled version of the referenced documents (such as pdf) should be placed on file with the appropriate EPA office and made available for routine referencing when needed.

B1 – I
dentification of Project Environmental Information Operations The Q
APP shall describe in detail the environmental information operations to be Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

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conducted for the project and state how they will satisfy the project purpose, and the information/data quality objectives and performance and acceptance criteria in the Group A4 and A6 Elements.

B
2 – M ethods for Environmental Information Acquisition
The QA
PP shall identify and describe the methods and procedures for how environmental information will be acquired throughout the project including any implementation requirements. The acquisition of environmental information includes collection, production, evaluation and/or use as well as design, construction, operation, or application of environmental technology.

Methods shall be identified by number/identifier, version/revision date, and regulatory citation (if applicable). If a method allows the user to select from various options, then the method citations shall state exactly which option(s) are being selected.

The QAPP shall identify, describe or reference SOPs used for the acquisition of environmental information including the version/revision date of the SOP. If a SOP provides more than one procedure or option (for example, one SOP covers the use of several different types of field equipment for the same procedure) the QAPP shall note the specific option or equipment being used.

SOPs shall be available to personnel conducting the environmental information operations. The QAPP shall identify the individual responsible for updating and maintaining the SOPs. The QAPP shall describe any planned modifications to SOPs expected to occur during the project.

For additional information on SOPs, refer to the current version of EPA Guidance for Preparing Standard Operating Procedures.

Field Activities En
vironmental Measurements
If
the environmental information operations include field activities such as environmental measurements of parameters or processes, the QAPP shall also describe or reference detailed descriptions of procedures for all field activities, including, but not limited to information derived from tools, instruments, observational results, investigations, and sample collection. The QAPP shall also describe or reference maximum holding times for sample extraction and/or analysis; selection and preparation of sample containers; sample volumes; preservation methods; sample handling and custody. For field activities involving emergency responses, QAPPs shall be approved during the environmental information operations as per the timelines specified in the EPA sponsoring organization’s QMP and other applicable EPA-approved QMPs (such as the contractor’s QMP).

Tribal Primary Quality Assurance Organizations (PQAO) conducting air monitoring should contact the EPA regional office sponsoring the work for additional information on B Elements.

Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

Not
e: IT/IM directives are reviewed annually for content, relevance, and clarity Form Rev. 08/21/2023

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Laboratory Analyses
If the environmental information operations involve laboratory analyses, the QAPP shall identify the analytical methods by number/identifier, version/revision date and regulatory citation (if applicable). Also, the QAPP shall describe or reference SOPs that address procedures to be conducted when a non-compliance or failure in the analytical system occurs, who is responsible for corrective action, and how to determine and document the effectiveness of the corrective action. The QAPP shall specify the laboratory data package turnaround time needed, if important to the project schedule. If a laboratory method allows the user to select from various options, then the method citations should state exactly the selection of option(s).

For non-standard method applications, such as for unusual sample matrices and situations, appropriate method performance study information is needed to confirm the performance of the method for the matrix. If previous performance studies are not available, they shall be developed during the project and included as part of the project results.

Ex
isting Information
For
envi
ronmental information compiled or obtained from databases, software applications, decision support tools, websites, existing literature, and other sources, the QAPP shall describe the information to be obtained, the collection process, and the intended use of that information together with criteria for acceptance and evaluation for suitability for the current project. If the information is to be combined with new environmental information, the criteria to ensure compatibility shall be described.

Environmental Technology
For
envi
ronmental information operations involving environmental technology, the QAPP shall identify whether the technology is primarily for pollution prevention, contamination containment, storage, or remediation. The QAPP shall also describe the physical parameters or processes collected using environmental technologies as well as the specific systems, devices, and their components applicable to both hardware and methods or techniques that measure and/or remove pollutants or contaminants and/or prevent them from entering the environment. For additional advice on QAPPs for design, construction, and operation or application of environmental technology refer to the current version of EPA Guidance on Quality Assurance for Environmental Technology Design, Construction and Operation.

B3 – Integrity of Environmental Information
The QAP
P shall describe or cite the procedures for ensuring the integrity of the environmental information operations.

If the environmental information operations include field sampling, the QAPP shall describe or cite procedures and requirements for sample handling and custody to include but not limited to field logs, packaging, transport and/or shipment from the Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

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site, and storage at the laboratory. The QAPP shall also contain examples of sample labels, and chain of custody forms/sample custody logs.

If
the environmental information operations include laboratory analyses, the QAPP shall identify each laboratory to be used as well as a back-up laboratory if identified as required in systematic planning, contract statements of work, or workplans. The QAPP shall also describe the processes for ensuring the laboratory maintains current accreditation and/or certification for applicable analytes and matrices.

B4 – Quality Control
The QA
PP shall identify and describe the QC activities needed for each environmental information operation to meet project environmental information/data quality objectives and performance/acceptance criteria.

The QAPP shall describe or cite the frequency of each type of QC activity, corrective actions, and how the effectiveness of the corrective action shall be determined and documented. The QAPP shall describe or reference the procedures to be used to calculate applicable statistics (e.g., precision and bias).

For environmental information operations involving field sampling, measurements, and laboratory analysis, QC activities include, but are not limited to, the use of blanks, duplicates, matrix spikes, laboratory control samples, and surrogates.

For environmental information operations using existing data, QC activities include, but are not limited to, the use of systematic review, independent secondary review of studies in the open literature, and QC of constructed databases or spreadsheets.

For environmental information operations using models or modeling, QC activities include, but are not limited to model calibration and model validation (sensitivity analyses).

B5 – Instrument/Equipment Calibration, Testing,
Inspection, and
Maintenance
The QAP
P shall identify instruments/equipment, to include, but not limited to tools, gauges, and pumps used for environmental information operations. The QAPP shall describe all procedures and documentation activities that will be performed to ensure that the instruments/equipment are available and in working order when needed. The QAPP shall describe or reference how calibration will be conducted , documented, and be traceable to the instrument.

The QAPP shall describe or reference procedures and documentation activities on how instruments and equipment will be tested, inspected, and maintained. The QAPP shall also discuss the availability of critical spare parts, identified in the operating guidance and/or design specifications of the instruments/equipment.

Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

No
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B 6 – Inspection/Acceptance of Supplies and Services
T
he QAP
P shall describe or reference the procedures for how supplies and services are inspected and accepted. The QAPP shall identify the individual(s) responsible for inspection and acceptance. This description shall specify the elements of this Standard for which the vendor is responsible and how their adherence to the QAPP requirements will be verified. Acceptance shall be identified on the items themselves or in documented information traceable to the items.

S
upplies may include but are not limited to spare parts for instruments/equipment, standard materials and solutions, sample bottles, calibration gases, reagents, hoses, deionized water, potable water, and electronic data storage media.

Services provided by vendors to include, but not limited to contractors, sub- contractors, and sub-grantees may include document development, performing environmental information operations.

B7 – Environmental In formation Management
The QAP
P shall describe or cite the environmental information management process for the project, tracing the path of the environmental information from its generation to its final use or storage (e.g., the field, the laboratory. the office, the database).

The QAPP shall describe or reference the standard record-keeping procedures, the document control system, and the approach used for information storage and retrieval on electronic media. The QAPP shall describe or reference the control mechanism for detecting and correcting errors and for preventing loss of information during data entry, reduction, and reporting, and data entry to databases, forms, and reports, and databases. The QAPP shall provide or reference examples of any forms or checklists to be used in these processes.

The QAPP shall describe or reference all procedures to process, compile, and analyze the information. This includes procedures for addressing environmental information generated as part of the project as well as environmental information from other sources.

Also, the QAPP shall describe or reference any required computer hardware/software and address any specific performance requirements for the hardware/software configuration used. The QAPP shall describe or reference the procedures to demonstrate acceptability of the hardware/software configuration required and for assuring that applicable information resource management requirements are satisfied.

3. GROUP C ELEMENTS FOR ASSESSMENT, RESPONSE ACTIONS, AND OVER
SIGHT
The elem
ents in this group (Table 3) address assessment, response actions and oversight activities. Assessments ensure that the planned project activities in t he Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

No
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QAPP are implemented as approved. Assessments can be internal and/or external and should be conducted throughout the project to ensure that usable environmental information are obtained. Response actions address findings, corrective actions and non-conformances identified from the assessments.

Ov
ersight activities ensure that response actions and reporting mechanisms are in place to capture the project status and any QA issues that arise during implementation and through assessments.

The elements in this group, identified in Table 3, address the activities for assessing the effectiveness of project implementation and associated QA and QC activities.

Refer to the current version of EPA Guidance on Technical Audits and Related Assessments for Environmental Data Operations for additional information.

G
roup
C: Assessment, Response Actions and Oversight
Element Description
C1 Assessments and Response Actions
C2 Oversight and Reports to
Management
Table 3
C1 – Assessments and Response Actions
This element addres
ses the activities for assessing the effectiveness of the implementation of the project and associated QA and QC activities. The purpose of an assessment is to ensure that the QAPP is implemented as approved.

Assessments are conducted both during and after the environmental information operations identified in the Group B Elements.

Assessments
Assessment is the evaluation process used to measure the performance or effectiveness of a system and its elements. Assessments may also be used as an investigative tool where problems may be suspected.

The QAPP
shall include assessment activities. The QAPP shall identify the assessments for the project to include the number, frequency, and types of planned assessments that will be performed. The QAPP shall also identify who will be performing the assessments. Assessment activities may include audits, performance evaluations, management reviews, peer reviews, inspections, surveillances, or readiness reviews (including competency assessment, pre-award assessment of proposal, or technical assessment), peer consultations, product reviews (e.g., data inspection, software testing, pre-dissemination reviews, or Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

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review of contractor deliverables). The EPA organization sponsoring the work may also specify additional assessment requirements.

T
he QAPP shall address how assessment findings, non-conformances, and corrective actions will be documented. One objective of this documentation is to communicate assessment results to management and to the EPA organization sponsoring the work as specified in Section C2 Oversight and Reports to Management. Documentation may include reports, memos, and/or other formal communication as specified by the EPA organization sponsoring the work. The assessment documentation shall also indicate the timeframe for response actions.

Audits are a type of assessment. Audits are systematic and independent examinations to determine whether quality activities and related results comply with planned arrangements and whether these arrangements are implemented effectively and are suitable to achieve objectives.

Peer review is a type of assessment. Contact the EPA organization sponsoring the work to determine peer review activities for the project.

The QAPP should be the basis for planning and conducting assessments, although other planning documentation to include, but not limited to SOPs, workplans, statements of work may also be used.

Assessors should be free of any conflicts of interest, such as might occur by close association with the environmental information operations being assessed.

Independence from the environmental information operations helps to ensure that the assessor has no stake in the outcome of the assessment, other than an interest that the environmental information operations are conducted objectively and in accordance with the approved QAPP.

Response Actions
The QAPP shall describe how response actions associated with assessment findings, non-conformances, and corrective actions will be developed, documented and tracked to ensure completion. The QAPP shall also identify the individual(s) responsible for response actions and how the response actions will be reported.

Response actions may include formal memos and notifications addressing findings, corrective actions, or non-conformances; and timelines for follow-up assessments.

C2 – Oversight and Reports to Management
The QAPP shall identify the individual(s) responsible for oversight activities. The QAPP shall describe the oversight activities that ensure that response actions and reporting mechanisms are in place to capture the project status and any QA issues that arise during implementation and through assessments.

T
he QAPP shall identify all reports to management. The QAPP shall describe the content of the management reports; and who is responsible for transmitting the Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

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te: IT/IM directives are reviewed annually for content, relevance, and clarity Form Rev. 08/21/2023

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report, how the report will be transmitted, and to whom. Distribution shall include the Project Operations Manager, the Project QAM of the organization conducting the work, and the EPA organization sponsoring the work. An assessment report would be an example of management report.

QAPP prepar
ers shall also contact the EPA organization sponsoring the work for additional QA reporting requirement.

4. GROUP D ELEMENTS FOR ENVIRONMENTAL INFORMATION REVIEW AND

USABILITY DETERMINATION
The elements in this group (Table 4) address the activities associated with env
ironmental information review for the purpose of determining whether the environmental information meets the established environmental/data quality objectives, the performance/acceptance criteria, and are useable for its intended purpose. Information review activities ensure that products and services resulting f
rom the environmental information operations are of known and documented qua
lity for their intended use(s) and that any limitations concerning its intended us
e is documented and communicated.

A
lthough environmental information review takes place after the environmental information operations have been conducted, determination of the type of information/data verification, information/data validation, and information/data qua
lity assessment activities needed to determine whether the project’s environmental information/data quality objectives are met begins during the planning phase of the project and are documented in the QAPP.

Additional information can also be found in the current versions of the following:
• EPA Guidance on Environmental Data Verification and Data Validation • EPA Guidance for Data Quality Assessment Practical Methods for Data Analysis
• EPA Data Quality Assessment: A Reviewer’s Guide
• EPA Data Quality Assessment: Statistical Tools for Practitioners Group D: E
nvironmental Information Review and Usability Determination Element Description
D1 Environmental Information Review
D2 Useability Determination
Table 4
D1 – Environmental Information Review
The QAPP shall describe or cite the procedures for the information/data Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

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IT/IM DIRECTIVE

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verification and information/data validation activities.

The QAPP shall also describe or cite the data quality assessment activities that will occur after the environmental information operations phase of the project is completed, if applicable. Information/data verification and information/data validation activities are conducted prior to and may serve to inform information/data quality assessment activities.

The Q
APP shall also describe or reference how performance criteria and/or acceptance criteria, and information/data quality indicators identified in A6 will be incorporated in the environmental information/data review process.

The QAPP shall also describe who will conduct these activities, and how the activities will be documented and communicated.

For add
itional environmental information review requirements including requirements for performance and/or acceptance criteria, and information/data quality indicators, contact the EPA organization sponsoring the work.

In general, verification is confirmation, through provision of objective evidence, that specified requirements have been fulfilled; and validation is confirmation, through provision of objective evidence that the requirements for a specific intended use or application have been fulfilled.

The following activity descriptions are from the EPA Quality Guidance documents listed above:

Data Verification is the process of evaluating the completeness, correctness, and conformance/compliance of a specific data set against the method, procedural, or contractual requirements.

Data Validation is an analyte- and sample-specific process that extends the evaluation of data beyond method, procedural, or contractual compliance (i.e., data verification) to determine the analytical quality of a specific data set.

Data Quality Assessment is the scientific and statistical evaluation of data to determine if the data obtained from environmental information operations are of the right type, quality, and quantity to support their intended use.

D2 – U
seability Determination
Determining useability of the environmental information is the culmination of the entire QA process for the project and involves a retrospective evaluation of the planning process. Not all environmental information may be useable for its intended purpose. The useability of the environmental information is performed at the conclusion of the environmental information operations using the outputs of the environmental information/data verification, the environmental information/data validation, and the environmental information/data quality assessment activities.

This reconciliation phase involves a qualitative and quantitative evaluation of Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

No
te: IT/IM directives are reviewed annually for content, relevance, and clarity Form Rev. 08/21/2023

IT/IM DIRECTIVE

STANDARD
environmental information to determine if the project information is of the right type, quality, and quantity to support its intended use and are suitable for the decisions that will be made.

The QAPP shall describe or reference the process that will be used to determine whether the environmental information is useable. The QAPP shall describe how this determination will be documented and the individual(s) responsible. The QAPP shall describe how any known or anticipated limitations on the use of the environmental information will be communicated and to whom.

6. R OLES AND RESPONSIBILITIES
EPA Administrator: Promotes and ensures quality is an integral part of the Agency’s mission by assuring that environmental information operations supporting EPA’s programs and activities are of known and documented quality, scientifically valid, legally defensible, and appropriate for the intended use. The Administrator may re-delegate t he
r
esponsibilities for this Standard to Assistant Administrators (AA) and Regional Administrators (RA).

A
ssistant Administrators (AA) and Regional Administrators (RA): Each AA and RA is responsible for implementing this Standard in the context of the organization’s specific mission.
• Ensuring that adequate resources are devoted to QA activities to ensure c
ompliance with EPA’s QA directives, to support the organization’s mission and to fully implement the organization’s approved QMP.
• Ensuring that the organization’s QMP includes activities that will help assure the qua
lity of the information the organization collects, manages, or uses in carrying out
its mission.
• Providing reasonable assurance and certifying annually to the DAA for IT/IM/CIO that their organization has implemented the Quality Policy and Procedure and have internal controls in place to ensure that environmental information produce d
and
utilized is of known and documented quality for the intended use. Provide this certification along with the organization’s QA annual report to the EQMD. The AA/
RA may re-delegate the responsibilities for certification to the appropriate mana
ger or supervisor. Promoting continuous improvement in QA activities acros s t
he organization.

Office of Mission Support (OMS), Deputy Assistant Administrator (DAA) for Information Technology/Information Management (IT/IM)/Chief Information Officer (CIO) (DAA for IT/IM/CIO): Acts as the EPA Senior Management Official for quality management and leads Agency-wide implementation of the Quality Policy and Procedure and EPA’s Quality Program. Informs AAs, RAs, and the CIO Strategic Advisory Council (SAC) of any issues related to the quality of Agency environmental information and environmental information operations encompassed by this Standard.

Chief Information Officer’s (CIO’s) Strategic Advisory Council (SAC): Consisting of Senior Information Officials (SIOs) and other senior managers, the SAC advises and reports to the DAA for IT/IM/CIO on Agency-wide environmental information operations.

Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

No
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The SAC serves as a forum to discuss coordination of cross-cutting Agency quality-related issues.
.

Se
nior Information Officials (SIOs): Oversee effective implementation, coordination, and management of the organization’s Quality Program for environmental information operations. Located in each Program Office and Region, SIOs report to the Agency DAA for IT/IM/CIO on quality-related issues.

National Program Office Directors: Provide Program direction to the Regional Program Office Directors on National Program Office QA guidance.

Mission Support Division Directors (MSDDs): Manage issues related to information technology and information management (IT/IM). Support the Region’s Quality Program and coordinate with Laboratory Services and Applied Science Division Directors (LSASDDs).

Laboratory Services and Applied Science Division Directors (LSASDDs): Serve as Director of a Regional Division with oversight of the Regional Quality Program through direct management oversight of the Regional QA personnel including the Regional QAM (RQAM). Through this oversight the LSASDD ensures conformance with this Policy and Regional QMPs.

Science and Technology Policy Council (STPC): Serves as a mechanism for addressing EPA’s science policy issues that go beyond regional and program boundaries, with a goal of integrating policies that guide Agency decision-makers on their use of scientific and technical information.

The STPC is an executive level council that is chaired by the Agency Science Advisor, and provides a venue for identifying, coordinating, and, when appropriate, establishing consensus for high priority, cross-agency science, and technology policy issues to assist Programs and Regions. It focuses on issues that require high-level action and are relevant to the Regions and Program Offices (such as: Peer Review, Public Access, and Risk Assessment).

Office of Acquisition Solutions: Responsible for planning, awarding and administering contracts for the Agency, including issuing and interpreting acquisition regulations; administering training for contracting and program acquisition personnel; providing advice and oversight to regional procurement offices; and providing information technology improvements for acquisition.

Office of Grants and Debarment: Provides cradle-to-grave administrative management of all Headquarters-administered grants, loans, cooperative agreements, fellowships, interagency agreements (IAs) and for the management of the Agency's Suspension and Debarment program.

Offi
ce of General Counsel and Offices of Regional Counsel: Provide legal advice on issues related to environmental information operations.

Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

No
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OMS, Office of Records, Administrative Systems and eDiscovery (ORASE) and Enterprise Quality Management Division (EQMD) Directors: Serve as Office and Division Directors respectively and are responsible for oversight of the Agency’s Quality Program. Execute actions on behalf of the DAA for IT/IM)/CIO according to Delegation 1-

41. M
andatory Quality Program.

E
PA Quality Assurance Managers (QAMs) or designee: Have delegated authority for the mana
gement of the Quality Program as described in their organization’s QMP. The QAM roles and responsibilities below serve as a reference to assist the QAM in identifying activities and best practices. These activities and best practices are applicable to their organizations and may assist in continuous improvement. These activities are not provided as performance measures for the organization but may be used to guide the QAM in discussion with management on their roles and expectations for implementing the Quality Directives.

QAMs are individuals within the organization who are assigned specific quality management duties and are delegated authority for quality management as defined in the organization’s QMP. Organizations may re-delegate the QAM’s responsibilities as described in their QMP. The functions of the QAM or designee may be totally related to Quality Program activities or may be in conjunction with other functions and responsibilities within the organization. If these personnel have other functions to perform, there should be no conflict of interest. It is the QAM’s responsibility to determine whether a conflict of interest exists.

Specif
ic duties and responsibilities shall include:
• Facilitating QMP development and approval by the organization and preparing updates to the approved QMP.
• Representing the organization on matters pertaining to quality management and QA
and QC activities.
• Providing expert assistance to the staff in the organization on QA and QC policies, requi
rements, programs and procedures applicable to procurement and technical activities.
• Reviewing QAPPs and, if applicable, QMPs for all projects, work assignments, deli
very orders, task orders, grants, cooperative agreements, and interagency agreements involving environmental information operations that are performed by or on behalf of EPA.
• Approving all QAPPs for implementation in all applicable projects, work ass
ignments, delivery orders, task orders, grants, cooperative agreements, and interagency agreements performed on behalf of EPA.
• Coordinating the correction of deficient QAPPs with the author(s) and their manage
ment including, as applicable, EPA authors, the COR, or the PO. • Identifying QA and QC training needs for the organization. • Providing oversight of QA and QC implementation in the environmental programs conduc
ted by or for the organization.
• Performing assessments of environmental programs and confirming the eff
ectiveness of corrective actions.
• Managing the day-to-day i mplementation of the mandatory Quality Program.

Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

No
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• Acting as liaison between the organization and EQMD on matters of QA requi
rements.
• Coordinating with senior management regarding changes to the Quality Program as nee
ded to assure its continued effectiveness and assisting in reporting the results to EQMD.
• Managing organization resources designated for the Quality Program. • Maintaining records of pertinent Quality Program activities performed by the organ
ization.
• Reviewing environmental information products (i.e., project reports containing envi
ronmental information or reporting the results of environmental information activities), independently (i.e., by others than those who produced the information or the reports) to confirm that the information is presented correctly; and • Preparing reports approved by management prior to release, publication, or dis
tribution.

T
he QAM or designee roles and responsibilities reflect the activities that support sys
tematic planning and life cycle management of EPA’s environmental information operations products and services. Criteria for success are the organization executive management endorsement of quality, sufficiency of quality resources, and empowerment/authority of the QAM to oversee the organization’s Quality Program. The list above does not prescribe the roles of management, but instead presents them from the perspective of the QAM. Executive management actions and support are needed for success. The QAM is to be aware of the support needed by the organization and can communicate those needs to management. Note: The QAPP Standard also uses the term Project Quality Assurance Manager to refer to the individual designated as the QAM for project defined in the QAPP.

Agen
cy Personnel: Perform work associated with environmental information operations as identified in their organization’s QMP.

Recipients of Extramural Agreements: Perform all environmental information operations in accordance with this Policy’s requirements as defined by federal laws, regulations, and as defined in their extramural agreements. The agreement terms and conditions may also specify applicability of the EPA lead organization's QMP.

7. RELATED INFORMATION
These c
itations are valid at the time of issuance of this Standard. Since these documents are subject to periodic review, users of this Standard should refer to the most recent version.

OMS Links:
• Environmental Information Quality Policy
• Environmental Information Quality Procedure
• EPA QA Field Activities Procedure
• CIO Notification Procedure for Environmental Data Quality Issues • Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of Information Disseminated by the Environmental Protection Agency Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

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• Enterprise Architecture Policy
• Data Standards Policy
• Enterprise Data Management Policy
• EPA Guidance for Quality Assurance Project Plans
• EPA Guidance for Geospatial Data Quality Assurance Project Plans • EPA Guidance for Quality Assurance Project Plans for Modeling • EPA Guidance for Preparing Standard Operating Procedures • EPA Guidance on Technical Audits and Related Assessments for Environmental Data Operations
• EPA Guidance on Environmental Data Verification and Data Validation • EPA Data Quality Assessment: Statistical Tools for Practitioners • EPA Guidance on Quality Assurance for Environmental Technology Design, Construction and Operation
O
ther EPA/External Links:
• ASQ/ANSI E4: 2014 (R2019) Quality management systems for environmental information and technology programs— Requirements with guidance for use • U.S. EPA Scientific Integrity Policy
• U.S. EPA Peer Review Handbook
• A Summary of General Assessment Factors for Evaluating the Quality of Scientific and Technical Information EPA 100/B-03/001
• 40 CFR Part 49: Tribal Authority Rule
• Uniform Federal Policy (UFP) for Quality Assurance Project Plans • Uni form Federal Policy for Quality Assurance Project Plans: Evaluating, Assessing, and Documenting Environmental Data Collection and Use Programs - Part 1: UFP-QAPP Manual
• Workbook for Uniform Federal Policy for Quality Assurance Project Plans:

Evaluating, Assessing, and Documenting Environmental Data Collection and Us e Programs
• Uniform Federal Policy for Quality Assurance Project Plans - Part 2B: Quality Assurance/Quality Control Compendium (Minimum QA/QC Activities)

8. D EFINITIONS
Assessment—The evaluation process used to measure the performance or effectiveness of a system and its elements. As used here, assessment is an all-inclusive term used to deno
te any of the following: audit, performance evaluation, management review, peer review, inspection, surveillance, or readiness review (including competency assessment, pre-award assessment of proposal, or technical assessment), peer consultation, product review (e.g., data inspection, software testing, pre-dissemination review, or review of contractor deliverables).

Audit—A systematic and independent examination to determine whether quality activities and related results comply with planned arrangements and whether these arrangements are implemented effectively and are suitable to achieve objectives.

Directive No: CIO 2105-S-02.1
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Pursuant to Delegation 1-19

No
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IT/IM DIRECTIVE

STANDARD
Consensus Standards— Standards that are developed and adopted by achieving agreement with all affected parties. These standards are developed in accordance with procedures used by the International Organization for Standardization or organizations accredited by the ANSI.

D
ata— A
quantitative or qualitative representation of values, facts, observations, or ideas in a formalized manner capable of being transmitted, processed, stored, analyzed, interpreted, and/or communicated by some process, whether on paper or in electronic form.
• Qualitative data—is descriptive.
• Quantitative data— is numerical.
• Pr
imary data— are data observed, collected, stored, or generated directly for a s
pecific purpose.
• Existing data—are data that have been collected, derived, stored, or reported in t
he past or by other parties (for a different purpose and/or using different methods and quality criteria). Sometimes referred to as data from other sources. • Metadata— Metadata is structured information that describes, explains, locates, or otherwise makes it easier to retrieve, use, or manage an information resource.

Data Standard— Documented consensus-based agreement on the format and definition of common data.

Environmental Information—Includes data and information that describe environmental processes or conditions which support EPA’s mission of protecting human health and the environment. Examples include but are not limited to:
• direct measurements of environmental parameters or processes. • analytical testing results of environmental conditions (e.g., geophysical or hydrological conditions).
• information on physical parameters or processes collected using environmental technologies.
• calculations or analyses of environmental information. • information provided by models.
• information data compiled or obtained from databases, software applications, decision support tools, websites, existing literature, and other sources: and • design, construction, and operation or application of environmental technology.

Environmental Information Operations— A col lective term for work performed to collect, produce, evaluate, or use environmental information and the design, construction, operation, or application of environmental technology.

Environmental Measurement—A s
ubgroup of Environmental Information that includes or
produces values derived from tools, instruments, observational results, laboratory operations on environmental samples, or other sampling and testing equipment. It is any data collection activity or investigation involving the assessment of chemical, physical, or biological factors in the environment which affect human health and the environment.

Directive No: CIO 2105-S-02.1
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IT/IM DIRECTIVE

STANDARD
Environmental Processes—Manufactured or natural processes that produce discharges or that impact human health and the environment.

E
nvironmental Programs— Work or activities involving the environment, including but not limited to, characterization of environmental processes and conditions; environmental monitoring; environmental research and development; the design, construction, and operation of environmental technologies; and laboratory operations on environmental samples.

Environmental Technology—An all- inclusive term for systems, devices and their components applicable to both hardware and methods or techniques that measure and/or remove pollutants or contaminants and/or prevent them from entering the environment.

Examples include but are not limited to:
• Pollution prevention measurement, monitoring, reduction, control, and/or treatment processes, such as wet scrubbers (air), granulated activated carbon unit (water), filtration (air, water).
• Containment to prevent further movement of the contaminants, such as capping, and solidification or vitrification, and biological treatment. • Storage containers, methods, or facilities, such as drums, tanks, and ponds or lagoons.
• Remediation processes and their components, and/or technologies, such as soil washing (soil), pump and treatment, soil vapor extraction (soil), land farming an d
ot
her bioremediation processes.

Environmental Technology does not include or incorporate QA associated with the development and design of IT systems.

Extramural Agreement— A legal agreement between EPA and a non-EPA organization.

Such agreements include but are not limited to contracts, work assignments, delivery orders, task orders, cooperative agreements, research grants, state and local grants, and EPA-funded interagency agreements and as negotiated in other agreements not funded by EPA. Refer to Environmental Information Quality Procedure, for additional details related to QA documentation associated with extramural agreements.

Graded Approach—The process of determining the level of detail for management controls to be applied to an activity according to the intended use and the degree of confidence needed in the quality of the results. This approach establishes the QA and QC requirements commensurate with the importance of the work, the available resources, and the unique needs of the organization.

Intergovernmental
— Between the EPA and international, other federal, state, tribal, territorial, area-wide, regional or local governments and agencies.

Management System— A management system may describe the polices, objectives, principles, organizational authority, responsibilities, accountability, and implementation plan of an organization.

Directive No: CIO 2105-S-02.1
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No
te: IT/IM directives are reviewed annually for content, relevance, and clarity Form Rev. 08/21/2023

IT/IM DIRECTIVE

STANDARD
Operations Manager—The Operations Manager is independent of the QAM. In some organizations this individual may also be referred to as the program manager or person responsible for the activity.

Or
ganization— An EPA organization is an office, region, national center, or laboratory. An external organization is a state, tribe, agency or other government entity, academia, company, corporation, firm, enterprise, or institution, or part thereof, whether incorporated or not, public or private, that has its own functions and administration.

Primary Quality Assurance Organization (PQAO)
— A monitoring organization, a group
of monitoring organizations or other organization that is responsible for a set of stations that monitor the same pollutant and for which data quality assessments can be pooled.

Each criteria pollutant sampler/monitor at a monitoring station must be associated with only one PQAO.

Process
— A set of interrelated resources and activities which transforms inputs into outputs. Examples of processes include analysis, design, data collection, operatio n, fabrication, and calculation.

Product— The intended result or final output of an activity or process that is disseminated or distributed among EPA organizations or outside of EPA.

Project— A unique process consisting of a set of coordinated, defined, and controlled activities with start and finish dates, undertaken to achieve an objective conforming to specific requirements including constraints of time, cost, and resources.

Project Quality Assurance Manager (Project QAM)— The individual designated as the quality assurance manager for project defined in the QAPP. Note: The QAPP Standard also uses the term Quality Assurance Manager for the individual designated in the organization’s QMP as the principal manager within the organization having oversight authority and responsibilities for planning, documenting, coordinating, and assessing the effectiveness of the Quality Program for the organization.

Quality
— The totality of processes, procedures, features, and characteristics of a product or service that bear on its ability to meet the stated or implied needs and expectations of the user.

Quality Assurance (QA)
— Management of an integrated system of activities involving planning, implementation, documentation, assessment, reporting, and quality improvement to ensure that a process, item, or service is of the type and quality needed and expected by the organization.

Quality Assurance Manager (QAM)
— The individual designated in the organization’s
QMP as the principal manager within the organization having oversight authority and responsibilities for planning, documenting, coordinating, and assessing the effectiveness of the Quality Program for the organization. Note: The QAPP Standard also uses the term Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

No
te: IT/IM directives are reviewed annually for content, relevance, and clarity Form Rev. 08/21/2023

IT/IM DIRECTIVE

STANDARD
Project Quality Assurance Manager to refer to the individual designated as the QAM for project defined in the QAPP.

Qual
ity Assurance Project Plan (QAPP)— A planning document related to a project that describes in comprehensive detail the necessary QA/QC requirements and other technical activities that must be implemented to ensure that the results of the work performed will satisfy the stated performance and acceptance criteria.

Quality Control (QC)—Th e ov
erall system of technical activities that measures the
attributes and performance of a process, item, or service against defined standards to verify that they meet the stated requirements; operational techniques and activities that are used to fulfill requirements for quality.

Quality Management—The aspects of the organization’s overall management system that drive the implementation of an organization’s Quality Program. Quality Management includes strategic planning, allocation of resources, and other systematic activities (e.g., planning, implementation, documentation, and assessment) pertaining to an organization’s Quality Program.

Quality Management Plan (QMP)—A formal document that describes a Quality Program in terms of the organizational structure, functional responsibilities of management and staff, lines of authority, and required interfaces for those planning, implementing, and assessing all activities conducted.

Quality Program—The totality of management controls, processes, and documentation in EPA’s planning, implementation, and assessment for ensuring the quality of Agency environmental information operations products and services.

9. W AIVERS
S
tatutory requirements for quality may supersede the specifications in this Directive or be mor
e rigorous. In such cases, affected programs shall be exempt from the requirements of this Directive. EPA organizations conducting exempted activities shall comply with EPA CIO 2105.1 in all other respects. The following exemptions from these requirements apply:

The collection of environmental data under the authority of Good Laboratory Practices as defined by 40 CFR 792, for the Toxic Substances Control Act.

The collection of environmental data under the authority of Good Laboratory Practices as defined by 40 CFR 160, for the Federal Insecticide, Fungicide, and Rodenticide Act.

10. DIRECTIVE(S)

SUPERSEDED
• EPA Requirements for Quality Assurance Project Plans (EPA QA/R-5, March 2001) • EPA Systematic Planning: A Case Study for Hazardous Waste Site Investigations (QA/CS-1, February 2006)
Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

No
te: IT/IM directives are reviewed annually for content, relevance, and clarity Form Rev. 08/21/2023

IT/IM DIRECTIVE

STANDARD
• EPA Systematic Planning: A Case Study of Particulate Matter Ambient Air Monitoring (
QA/CS-2, EPA QA/CS-2)

11. C ONTACTS
For information about this Standard or the Quality Program, contact the OMS, ORASE, EQMD, or email [email protected].

Vaughn Noga, Chief Information Officer and Dep uty Assistant Administrator for Information Technology and Information Management
Directive No: CIO 2105-S-02.1
Issued by the EPA Chief Information Officer,
Pursuant to Delegation 1-19

No
te: IT/IM directives are reviewed annually for content, relevance, and clarity Form Rev. 08/21/2023

IT/IM DIRECTIVE

STANDARD
APPENDIX A: ACRONYMS & ABBREVIATIONS
AA As
sistant Administrator
ANSI American National Standards Institute
ASQ American Society for Quality
CFR Code of Federal Regulations
CIO Chief Information Officer
COR Contracting Officer Representative
DAA Deputy Assistant Administrator
EPA Environmental Protection Agency
EQMD Enterprise Quality Management Division
FMFIA Federal Managers Financial Integrity Act
FY Fiscal Year
IM Information Management
IQA Information Quality Act
IQG Information Quality Guidelines
IT Information Technology
LSASDD Laboratory Services and Applied Science Division Director MSDD Mission Support Division Director
NTTA National Technology Transfer and Advancement Act
OMB Office of Management and Budget
OMS Office of Mission Support
ORASE Office of Records, Administrative Systems and eDiscovery PL Public Law
PO Project Officer
PQAO Primary Quality Assurance Organization
QA Quality Assurance
QAFAP Quality Assurance Field Activities Procedure
QAM Quality Assurance Manager
QAPP Quality Assurance Project Plan
QC Quality Control
QMP Quality Management Plan
RA Regional Administrator
RQAM Regional Quality Assurance Manager
SAC Strategic Advisory Council
SIO Senior Information Official
SOP Standard Operating Procedure
STPC Science and Technology Policy Council
UFP Uniformed Federal Policy
USC United States Code
Attachment 6:

SCVRUPPP Old Industrial CMP
i
Control Measure Plan to Reduce
PCBs and Mercury in Urban Runoff
from Old Industrial Areas
Plan and schedule for control measure implementation during MRP 3.0 in the Santa Clara Valley
Submitted in compliance with Provision C.11/12.c of NPDES Permit No. CAS612008, Order No. R2-2022-0018

FINAL REVISED
September 2024

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley ii

This report is submitted by the agencies participating in the

City of Campbell City of Milpitas City of Santa Clara
City of Cupertino City of Monte Sereno City of Saratoga City of Los Altos City of Mountain View City of Sunnyvale Town of Los Altos Hills City of Palo Alto County of Santa Clara Town of Los Gatos City of San José Santa Clara Valley Water District (Valley Water)

Prepared for:

Santa Clara Valley Urban Runoff Pollution Prevention Program (SCVURPPP)

Prepared by:

EOA, Inc.
1410 Jackson St., Oakland, CA 94612

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley iii

TABLE OF CONTENTS
List of Figures ............................................................................................................................................................. iv List of Tables ............................................................................................................................................................... iv List of Appendices ....................................................................................................................................................... v Acronyms .................................................................................................................................................................... vi EXECUTIVE SUMMARY ............................................................................................................................................. vii

1. INTRODUCTION .............................................................................................................................................. 1

1.1 Problem Definition........................................................................................................ 1

1.2 Land Areas Contributing Moderately or Highly Elevated PCBs or Mercury to Stormwater ............................................................................................................................. 1

1.3 Regulatory Requirements ............................................................................................ 3

1.4 Control Measures Plan Purpose and Approach ........................................................... 4

1.5 Organization of the Plan .............................................................................................. 6

2. PRIORITIZED LOCATIONS FOR PCBs AND MERCURY CONTROL MEASURE IMPLEMENTATION ....... 7

2.1 OI Land Areas Available for Control Measure Implementation ..................................... 7

2.2 Planned Additional Verification Monitoring During MRP 3.0 ........................................12

3. TARGETED CONTROL MEASURE PROGRAMS......................................................................................... 15

3.1 Source Area Investigations .............................................................................................. 15 Planned/Ongoing Source Area Investigations During MRP 3.0 ...........................................18 Other Actions to Support Implementation of the Control Program .......................................20

3.2 Controls for Properties with Moderately Elevated PCBs or Mercury ............................20 Control Measure Description ..............................................................................................20 Planned/Ongoing Implementation During MRP 3.0 .............................................................22 Other Actions to Support Implementation of the Control Program .......................................23

3.3 Abatement of Highly Elevated PCBs or Mercury Source Properties ............................23 Control Measure Description ..............................................................................................23 Planned/Ongoing Implementation During MRP 3.0 .............................................................24

3.4 Control Program for Public ROW Areas in Catchments with High Priority OI Land Areas 25
Control Measure Description ..............................................................................................25 Planned/Ongoing Implementation During MRP 3.0 .............................................................26

4. OTHER CONTROL MEASURE PROGRAMS ................................................................................................ 27

4.1 Green Stormwater Infrastructure .................................................................................27 Control Measure Description ..............................................................................................27 Current and Anticipated Level of Implementation................................................................28

4.2 Other Types of Stormwater Treatment Systems .........................................................34 Control Measure Description ..............................................................................................34 Current and Anticipated Level of Implementation................................................................34

5. ESTIMATED POLLUTANT LOAD REDUCTIONS ......................................................................................... 41

5.1 Targeted Control Measure Programs ..........................................................................41

5.2 Other Control Measures ..............................................................................................42

5.3 Summary of Anticipated Load Reductions ..................................................................43

6. PLANNING AND IMPLEMENTATION SCHEDULE....................................................................................... 45

7. REFERENCES ............................................................................................................................................... 48

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley iv

LIST OF FIGURES
Figure 2.1. Flow chart demonstrating how verification monitoring is used to prioritize OI land areas for targeted controls during MRP 3.0 based on PCBs monitoring data. ............................................................................................ 9 Figure 2.2. Geographical extent of land areas in the Santa Clara Valley identified as old (pre-1980) industrial land use in 2002 (i.e., starting date for the PCBs and Mercury TMDLs) categorized as fully addressed for PCBs and mercury or prioritized for targeted controls based on monitoring data. ...................................................................................... 11 Figure 2.3 Stormwater catchments and associated old industrial (OI) parcels in the Santa Clara Valley where Verification Monitoring has been competed or is planned during MRP 3.0. ................................................................. 13

Figure 3.1. Flow chart demonstrating progression from Source Area Investigations through control measure implementation and final outcomes for high priority OI land areas. ............................................................................. 16

Figure 3.2. Stormwater catchments with high priority old industrial (OI) land areas that are targeted for Public ROW Investigations, On-site Inspections and Sampling and Targeted Control Programs in the Santa Clara Valley during MRP 3.0. ...................................................................................................................................................................... 19

Figure 4.1. Locations where parcel-based Low Impact Development (LID) projects have been recently completed or are anticipated during MRP 3.0, including those within high priority catchments with moderately or highly elevated PCBs. ........................................................................................................................................................................... 29

Figure 4.2. Planned location and drainage area of the anticipated River Oaks Stormwater Capture Project in the City of San Jose, CA. .......................................................................................................................................................... 33

Figure 4.3. Drainage areas for high-flow capacity stormwater treatment systems and inlet-based stormwater screening devices installed, planned or proposed for installation during MRP 3.0. ..................................................... 36 Figure 4.4. Areas of potential multi-benefit for PCBs, mercury and trash load reductions in the Santa Clara Valley. .. 40

LIST OF TABLES
Table 1.1. Average PCBs and mercury concentrations (mg/kg) in sedimenta measured across the SF Bay Area within five land use categories, including source properties where highly elevated PCBs and/or mercury concentrations have been observed....................................................................................................................................................... 3 Table 2.1. Old industrial (OI) land areas in the Santa Clara Valley fully addressed for PCBs and mercury prior to MRP

3.0 and those (remaining) areas that are not fully addressed for PCBs and mercury, and further prioritized for targeted controls. ......................................................................................................................................................... 10

Table 2.2. Verification Monitoring planned by SCVURPPP during MRP 3.0 to reclassify undetermined priority old industrial (OI) parcels in the Santa Clara Valley. .......................................................................................................... 14 Table 3.1. Stormwater catchments with high priority old industrial (OI) land areas that are targeted for Public ROW Investigations or On-site Inspections and Sampling in the Santa Clara Valley during MRP 3.0. ................................. 18 Table 4.1. Extent of land areas in high, undetermined and low priority catchments in the Santa Clara Valley where parcel-based Low Impact Development (LID) projects have been recently completed or are anticipated during MRP

3.0. ............................................................................................................................................................................... 30 Table 4.2 Drainage areas and associated land uses for high-flow capacity stormwater treatment systems and inlet- based stormwater screening devices installed or planned for installation during MRP 3.0 in high priority stormwater catchments with moderately or highly elevated PCBs or mercury. .............................................................................. 37

Table 4.3. Drainage areas and associated land uses for high-flow capacity stormwater treatment systems and inlet- based stormwater screening devices installed during MRP 3.0 in undetermined or low priority stormwater catchments. .................................................................................................................................................................. 38 Table 5.1. Estimated PCBs and mercury load reductions anticipated to occur via the implementation of control measures identified in Sections 5.1 and 5.2 of this Plan .............................................................................................. 44 Table 6.1. Anticipated schedule for control measure planning and implementation tasks in old industrial (OI) and moderate PCBs or mercury land areas during MRP 3.0. ............................................................................................. 46

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley v

LIST OF APPENDICES
Appendix A High Priority Stormwater Catchment Factsheets Appendix B Draft Outreach Materials and Source Property Pollutant Control Plan Template MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley vi

ACRONYMS
BASMAA Bay Area Stormwater Management Agencies Association BAMSC Bay Area Municipal Stormwater Collaborative
BMP Best Management Practice
CASQA California Stormwater Quality Association
CWA Clean Water Act
GSI Green Stormwater Infrastructure
HDS Hydrodynamic Separator
OI Old Industrial
LID Low Impact Development
MPC Monitoring and Pollutants of Concern Committee
MRP Municipal Regional Permit
MS4 Municipal Separate Storm Sewer System
NPDES National Pollution Discharge Elimination System
O&M Operations and Maintenance
PCBs Polychlorinated Biphenyls
POC Pollutant of Concern
POTW Publicly Owned Treatment Works
RMC Regional Monitoring Coalition
RMP Regional Monitoring Program for Water Quality in San Francisco Bay ROW Right-of-Way
RWSM Regional Watershed Spreadsheet Model
SCVURPPP Santa Clara Valley Urban Runoff Pollution Prevention Program SFBRWQCB San Francisco Bay Regional Water Quality Control Board SFEI San Francisco Estuary Institute
STM Stormwater Treatment Measure
SWRP Stormwater Resource Plan
TMDL Total Maximum Daily Load
TSS Total Suspended Solids
USEPA US Environmental Protection Agency
WMA Watershed Management Area
WY Water Year

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley vii

EXECUTIVE SUMMARY
Fish tissue monitoring in San Francisco Bay (Bay) has revealed the bioaccumulation of Polychlorinated Biphenyls (PCBs), mercury, and other pollutants in Bay sportfish. The levels found are thought to pose a health risk to people consuming these fish. As a result, an interim advisory has been issued on the consumption of certain types of sportfish from the Bay. The San Francisco Bay Regional Water Quality Control Board (Regional Water Board) developed Total Maximum Daily Load (TMDL) water quality restoration programs for PCBs and mercury that identified urban runoff as an important pathway for these legacy pollutants to the Bay.

For over two decades, San Francisco Bay Area cities and counties have implemented control measures to reduce contributions of PCBs and mercury from municipal separate storm sewer systems (MS4s) that convey urban runoff to the Bay. Building off this significant experience, this Control Measure Plan to Reduce PCBs and Mercury in Urban Runoff from Old Industrial Areas (Plan) was developed by the Santa Clara Valley Urban Runoff Pollution Prevention Program (SCVURPPP or Program) on behalf of all SCVURPPP member agencies (i.e., Co-permittees).

This Plan is revised from the version submitted on March 31, 2023 to address Regional Water Board comments provided in a letter dated August 2023. The Plan complies with the requirements of the National Pollutant Discharge Elimination System (NPDES) Permit (Order No. R2-2022-0018; Permit No. CAS612008), also known as the Municipal Regional Permit (MRP 3.0).

This Plan summarizes the control measure programs, implementation schedules, and pollutant load reductions that SCVURPPP member agencies anticipate achieving during the MRP 3.0 term in the Santa Clara Valley. This Plan addresses MRP 3.0 Provisions C.11/12.c requirements for Co-permittees to submit plans and schedules for implementing control measures and stormwater treatment in old industrial (OI) land areas and other areas that generate moderate levels of PCBs or mercury to address the load reduction requirements included in these provisions. This Plan includes maps of the areas where control measures are to be implemented, the acreage of these areas, and a description of design and sizing features for all control measures implemented for each treated catchment in the Santa Clara Valley. This Plan describes two types of control programs: 1) Targeted Control Programs and (2) Other Control Programs. Targeted control programs are directed by Co-permittees and include ongoing, enhanced, and new actions that target OI land areas located in stormwater catchments containing known or suspected PCBs or mercury source areas or evidence of moderately to highly elevated PCBs or mercury based on monitoring data. Other (non-targeted) control measures include actions that are implemented by Co-permittees, other agencies, or by private parties associated with OI land use areas, but do not specifically target areas with known moderately to highly elevated PCBs or mercury in the catchment. Although they are not intended to target areas with moderately or highly elevated PCBs or mercury, these other control measures can still provide significant PCBs and mercury load reduction benefits in areas where there is evidence of contamination prior to implementation of the control.

Anticipated Control Measure Implementation
Land areas where Targeted Control Programs should be implemented are identified through monitoring data collected at multiple spatial scales. Verification Monitoring is conducted by SCVURPPP at the catchment or sub-catchment scale. This type of monitoring can include collecting stormwater samples at the catchment scale to verify that there are moderately or highly elevated PCBs or mercury in the stormwater catchment. Verification Monitoring can also include collection of sediment samples in the public right-of-way (ROW) in locations draining OI land areas. Catchments verified as having moderately to highly elevated PCBs or mercury are targeted for additional investigation and controls, as described below. SCVURPPP conducts Source Area Investigation monitoring, in catchments verified as having moderately to highly MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley viii
elevated PCBs or mercury. The purpose of this type of monitoring is to identify the source(s) of PCBs or mercury in the catchment. Source Area Investigation monitoring has been ongoing since MRP 1.0, but during MRP 3.0 SCVURPPP further refined its process to incorporate new and enhanced efforts to gain access to and collect samples on private properties to determine if a property is a source of PCBs or mercury in stormwater.

Targeted Control Programs described in this Plan use available information to target land areas with moderately or highly elevated PCBs or mercury. Control measure programs that target these moderately or highly elevated OI land areas include:

1. Controls for Properties with Moderately Elevated PCBs or Mercury. This control program is a new effort developed during MRP 3.0 that targets Moderate Pollutant (PCBs or mercury) Contributing Properties (MPCPs) for on-site controls.

2. Abatement of Highly Elevated PCBs Source Properties. This control program is a continuation of ongoing efforts since MRP 1.0 to target properties that are sources of highly elevated PCBs for referral and abatement.

3. Controls for Public ROW Areas in Catchments with High Priority OI Land Areas.

This control program focuses on catchments with moderately to highly elevated PCBs or mercury where source investigations failed to identify specific PCBs or mercury source properties. If PCBs or mercury source properties cannot be identified in a catchment with moderately or highly elevated PCBs or mercury, Co-permittees will delineate the drainage area associated with the moderate or high result(s), and follow the process described in the Clean Watersheds for a Clean Bay (CW4CB) Guidance Manual to evaluate how other types of controls (e.g., enhanced O&M activities) may provide PCBs and/or mercury reductions. The selection of appropriate controls for each catchment is site-specific, and will be determined through an evaluation process that will take place after the results from a source area investigation indicate that no source property(s) has been identified in the catchment.

The Other Control Measure Programs described in this Plan implement control measures in OI land areas that have multiple benefits and provide reductions of PCBs, mercury and trash.

As such, these other types of control programs may be implemented in catchments that have yet to be verified as contributing moderately or highly elevated PCBs or mercury to stormwater; or where monitoring data indicate that an OI land area is not moderately or highly elevated.

Other control measure programs include:

1. Green Stormwater Infrastructure (GSI). Includes parcel-based Low Impact Development (LID) implemented on properties, public green streets and regional GSI projects.

2. High-Flow Capacity Stormwater Treatment Systems and Inlet-based Stormwater Screening Devices. Stormwater treatment systems that include proprietary devices that remove sediment, trash, and other pollutants from stormwater through screening, trapping, and settling mechanisms.

In addition to the monitoring and control measures programs described above, this Plan also describes a new monitoring program that is currently under development by SCVURPPP to better demonstrate the potential scale of load reductions that can be achieved via both targeted and other control programs in OI land areas. Additional details on this program are described in Section 4.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley ix
Estimated PCBs and Mercury Load Reductions
The permit requires that Co-permittees in the Santa Clara Valley collectively achieve a reduction of 121 g/yr of PCBs and 28 g/yr of mercury during the permit term in OI land areas and other areas with land uses that generate moderately to highly elevated PCBs or mercury (i.e., ≥ 0.2 mg/kg PCBs and ≥ 0.3 mg/kg mercury in sediment or stormwater particle ratio, and/or > 36 ng/L PCBs in stormwater). Based on conservative estimates, anticipated control measure implementation (excluding source property referrals) is expected to result in the reduction of 121 g/yr for PCBs (ranging from 61 g/yr to 182 g/yr), and 25 g/yr for mercury (ranging from 13 g/yr to 35 g/yr) by the end of the permit term in OI areas with moderate PCBs or mercury. All load reductions were calculated using the methods approved by the Regional Water Board Executive Officer and described in the Source Control Load Reduction Accounting for Reasonable Assurance Analysis report (BASMAA 2022). These estimates represent a “best” estimate for anticipated control measure implementation during MRP 3.0. The best estimates were calculated generally assuming that roughly 50% of the anticipated control measure implementation described in this Plan would be completed during MRP 3.0. Ranges assume 25% to 75% of anticipated control measure implementation described in this Plan would be completed during MRP 3.0. Best estimates and ranges for PCBs and mercury demonstrate that Co-permittees should collectively achieve the C.11.c and C.12.c load reduction requirements during MRP 3.0.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 1 1. INTRODUCTION
This Control Measure Plan to Reduce Polychlorinated Biphenyls (PCBs) and Mercury in Urban Runoff from Old Industrial Areas (Plan) presents the current status of control measure planning and implementation in the Santa Clara Valley (Santa Clara County, CA) to achieve PCBs and mercury load reductions required by the Municipal Regional Stormwater National Pollutant Discharge Elimination System (NPDES) Permit (Order No. R2-2022-0018; Permit No.

CAS612008), also known as the Municipal Regional Permit (MRP). This Plan was developed by the Santa Clara Valley Urban Runoff Pollution Prevention Program (SCVURPPP or Program) on behalf of all SCVURPPP member agencies (i.e., Co-permittees1) in compliance with MRP Provisions C.11.c.iii.(1) and C.12.c.iii.(1).

1.1 Problem Definition
Fish tissue monitoring in San Francisco Bay (Bay) has revealed the bioaccumulation of PCBs, mercury, and other pollutants in Bay sportfish (SFBRWQCB, 1995). The levels found are thought to pose a health risk to people consuming these fish and as a result, an interim advisory has been issued on the consumption of sportfish from the Bay. The advisory led to the designation of the Bay in 1998 by San Francisco Bay Regional Water Quality Control Board (SFBRWQCB or Regional Water Board) as an impaired water body on the Clean Water Act (CWA) "Section 303(d) list" due to elevated levels of PCBs and mercury. In response, the Regional Water Board developed Total Maximum Daily Load (TMDL) water quality restoration programs targeting PCBs and mercury. The general goals of the TMDLs are to identify sources of PCBs and mercury and implement actions to control the sources of these pollutants to achieve water quality standards and restore beneficial uses of the Bay (SFBRWQCB 2006, 2008). In the TMDLs, stormwater discharges, including those in the Santa Clara Valley, were identified as a key sources of these pollutants to the Bay.

Since the development and adoption of the PCBs and Mercury TMDLs, SCVURPPP Co- permittees have implemented numerous control measures to reduce the loads of PCBs and mercury in stormwater. These control measures have been previously reported by SCVURPPP and have had a direct benefit to Bay beneficial uses by reducing the contributions of PCBs and mercury from stormwater (SCVURPPP 2021).

1.2 Land Areas Contributing Moderately or Highly Elevated PCBs or Mercury to Stormwater
Over the past 20 years, SCVURPPP Co-permittees have spent significant public resources to identify locations within the urban landscape where PCBs or mercury are elevated and determine what control measures will likely provide the most load reduction benefits for these pollutants. Findings from numerous studies demonstrate that PCBs and mercury sources are generally associated with watershed land areas where equipment containing these pollutants were manufactured, transported or used and facilities that recycle PCBs or mercury-containing devices and equipment. These sources include current and historic metal, automotive, and

1 Cities of Campbell, Cupertino, Milpitas, Monte Sereno, Mountain View, Palo Alto, San José, Santat Clara Saratoga Sunnyvale, the Towns of Los Altos Hills and Los Gatos, the County of Santa Clara and Valley Water.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 2 hazardous waste recycling and transfer stations; electrical properties and power plants; and rail lines. These sources are typically located in areas that were industrialized between the late 1920’s and the late 1970’s, the timeframe when the production and use of PCBs and mercury were the greatest in the U.S. These areas are identified as old industrial (OI) land areas and are considered potential sources of PCBs and mercury in stormwater discharges to local creeks/rivers and the Bay.

Screening-level PCBs and mercury concentration thresholds have been selected to identify whether a land area likely has elevated (moderate or high) PCBs or mercury and to indicate proximity to a source (BASMAA 2022). Concentrations are considered elevated if sediment collected on properties or in the public right-of-way (ROW) are ≥0.2 mg/kg for PCBs or ≥0.3 mg/kg for mercury. Concentrations of PCBs in sediment that are ≥0.2 mg/kg, but <0.5 mg/kg are considered moderately elevated and concentrations ≥0.5 mg/kg are classified as highly elevated (SFBRWQCB 2022). Concentrations of mercury in sediment that are ≥0.3 mg/kg, but <1.0 mg/kg are considered moderately elevated and concentrations ≥1.0 mg/kg are classified as highly elevated (SFBRWQCB 2022). PCBs concentrations <0.2 mg/kg in sediment and mercury concentrations <0.3 mg/kg in sediment are considered low/background urban concentrations.

Additionally, stormwater samples are considered elevated if particle ratios (i.e., whole water PCBs or mercury concentration divided by the suspended sediment concentration) are ≥0.2 mg/kg for PCBs, ≥0.3 mg/kg for mercury, or for PCBs only, if whole water concentrations are >36 ng/L (i.e., the top 15% of concentrations measured in stormwater across the Bay Area). A similar stormwater concentration threshold has not been set for mercury.

The dataset of PCBs and mercury concentrations measured over the past 20 years in sediment samples throughout the San Francisco Bay Area (SF Bay Area) has been invaluable to Co- permittees. This dataset has helped identify land areas where PCBs or mercury are elevated, and where controls measures will have the greatest load reduction benefits (BASMAA 2022).

These sediment samples were collected from roadways, curb and gutters, driveways, sidewalks, storm drain inlets, manholes, culverts, and surface soils within public ROWs and on private properties across the Bay Area. To date, this data set includes over 1,600 PCBs datapoints and over 1,400 mercury datapoints. Table 1.1 presents the average concentrations of PCBs and mercury derived from this dataset, based on the predominant land use within the vicinity of where the sediment was collected. Additional information on these data is provided in BASMAA (2022). These data support the assumption that OI and other old (i.e., developed prior to 1980) land areas where PCBs or mercury were more heavily used in the past, contribute much higher masses of these pollutants per unit area than newer urban land areas developed post-1980, after the sale of PCBs was banned in the US. Other (non-industrial) old urban land areas where elevated PCBs concentrations have been observed include commercial/ transportation and residential areas. For mercury, elevated concentrations have been found in OI land areas, old residential, and even new urban land areas.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 3 Table 1.1. Average PCBs and mercury concentrations (mg/kg) in sedimenta measured across the SF Bay Area within five land use categories, including source properties where highly elevated PCBs and/or mercury concentrations have been observed.

Land Use Associated Category PCBs
(mg/kg)
Mercury
(mg/kg)
Source Property 32b NA
Old Industrial b 0.79b 0.43
Old Commercial / Old Transportation b 0.22b 0.20
Old Residential b 0.20 0.43
New Urban 0.07 0.46
Agriculture / Open Space 0.07 0.29
a mg/kg – milligrams per kilogram of sediment(< 2mm grain size) b Average concentration for old industrial, old commercial/transportation, and old residential land use categories are in the moderate (0.2 - < 0.5 mg/kg) to high (≥ 0.5 mg/kg) range for PCBs.

1.3 Regulatory Requirements
The MRP regulates the control/management of stormwater and non-stormwater discharges from Phase I Municipal Separate Storm Sewer Systems (MS4s) in the SF Bay Area. The MRP is issued to SF Bay Area municipalities and flood control agencies by the Regional Water Board. The current version of the MRP (MRP 3.0) became effective on July 1, 2022. Provisions C.11 and C.12 contain specific requirements for controlling PCBs and mercury in municipal stormwater. These requirements are consistent with the urban runoff implementation plans for the Guadalupe River watershed mercury TMDL and the SF Bay PCBs and mercury TMDLs.

Sub-provisions C.11/12.c require Co-permittees to implement (or cause to be implemented) treatment control measures, stormwater diversion to wastewater treatment facilities, redevelopment (provided green stormwater infrastructure (GSI) is implemented in compliance with C.3.b), enhanced operation and maintenance (O&M), or other control measures to comply with the performance metrics identified in Provisions C.11/12.c.i. Performance metrics must be achieved by the end of the permit term (i.e., June 2027). For the Santa Clara Valley Co- permittees, the C.11/12.c.i performance metrics are the following:

1. Reduce PCBs and mercury loads from 664 acres of Old Industrial or Moderate PCBs or mercury areas by implementing stormwater control measures with at least 70% load reduction efficiency; or

2. Reduce loads from these areas by 28 g/yr of mercury and 121 g/yr of PCBs.

If Co-permittees choose to comply with these requirements by demonstrating PCBs and mercury load reductions (i.e., option #2 above), then the Co-permittees must use accounting methods described in BASMAA (2022) that have been approved by the Regional Water Board’s Executive Officer.

By March 31, 2023, Co-permittees were required to submit plans and schedules for implementing controls in old industrial/moderate PCBs and mercury areas to achieve the C.11/12.c.i performance metrics. The Control Measure Plans (CMPs) must include the following:
• Maps of the areas where control measures are to be implemented; • Acreage of these catchments (areas); and
• Descriptions of design and sizing features for all control measures, treatment devices and stormwater diversion facilities implemented for each treated catchment.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 4 Given that MRP 3.0 allows (and encourages) Co-permittees to comply with all requirements in C.11 and C.12 through a collaborative effort, SCVURPPP developed and submitted a CMP on behalf of all SCVURPPP Co-permittees in March 2023.

In a letter dated August 25, 2023, Regional Water Board staff provided comments on SCVURPPP’s CMP as well as the CMPs submitted by the four other countywide programs that represent Co-permittees in counties other than Santa Clara. The letter requested that all stormwater programs (including SCVURPPP) revise and resubmit their CMPs by October 31, 2023 to address shortcomings identified by Regional Water Board staff in the letter. In a follow- up meeting held on September 15, 2023 between Regional Water Board, stormwater program, and Co-permittee staff, the CMPs and comments included in the letter were discussed and clarified. Stormwater programs agreed to revise their plans to address applicable comments provided in the letter, but requested additional time to resubmit their CMPs. Regional Water Board staff agreed to extend the resubmittal timeline to March 31, 2024, contingent upon receiving an adequate written response summarizing planned revisions to their CMPs. In October 2023, SCVURPPP developed and submitted a letter that outlined the planned revisions to the SCVURPP CMP and formally requested an extension to the original timeline. In a letter dated October 31, 2023, Regional Water Board staff agreed to the proposed revisions and extended the deadline for SCVURPP (and all stormwater programs) to submit their revised CMPs to March 31, 2024. This Plan has been revised from the version submitted in March 2023 to address all Regional Water Board comments included in the letter.

1.4 Control Measures Plan Purpose and Approach
The purpose of this Plan is to describe the control measures that SCVURPPP Co-permittees anticipate implementing to achieve the PCBs and mercury load reductions required by MRP Provisions C.11.c and C.12.c, respectively. This Plan includes descriptions of the ongoing, enhanced and new control measures Co-permittees have already begun to implement and will continue to implement during the remainer of MRP 3.0 in OI land areas.

This Plan describes two types of control programs: 1) Targeted Control Programs and (2) Other Control Measure Programs. Targeted control programs are directed by Co-permittees and include ongoing, enhanced, and new actions that target OI land areas located in stormwater catchments containing known or suspected PCBs or mercury source areas or evidence of moderately to highly elevated concentrations based on monitoring data. Other (non-targeted) control measures include actions that are implemented by Co-permittees, other agencies, or by private parties associated with OI land use areas, but do not specifically target areas with known moderately to highly elevated PCBs or mercury in the catchment. Although they are not intended to target areas with moderately or highly elevated PCBs or mercury, these other controls may still provide important load reduction benefits in OI land areas where there is evidence of PCBs or mercury contamination prior to implementation of the control.

Land areas where Targeted Control Programs should be implemented are identified through monitoring data collected at multiple spatial scales. Verification Monitoring is conducted by SCVURPPP at the catchment or sub-catchment scale. This type of monitoring can include collecting stormwater samples at the catchment scale to verify that there are moderately or highly elevated PCBs or mercury in the stormwater catchment. Verification Monitoring can also include collection of sediment samples in the public ROW in locations draining OI land areas.

Catchments or parcels verified as having moderately to highly elevated PCBs or mercury are targeted for additional investigation, as described below. SCVURPPP conducts Source Area Investigation Monitoring, in catchments verified as having moderately to highly elevated PCBs or mercury. The purpose of this type of monitoring is to identify the source(s) of PCBs or mercury in the catchment. Source area investigation monitoring has been ongoing since MRP MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 5 1.0, but during MRP 3.0 there are new and enhanced efforts to gain access to and collect samples on private properties to determine if a property is a source of PCBs or mercury in stormwater.

Targeted Control Programs described in this Plan use available information to target land areas with moderately or highly elevated PCBs or mercury. Control measure programs that target these moderately or highly elevated OI land areas include:

1. Controls for Properties with Moderately Elevated PCBs or Mercury. This control program is a new effort developed during MRP 3.0 that targets Moderate Pollutant (PCBs or mercury) Contributing Properties (MPCPs) for on-site controls.

2. Abatement of Highly Elevated PCBs Source Properties. This control program is a continuation of ongoing efforts since MRP 1.0 to target properties that are sources of highly elevated PCBs for referral and abatement.

3. Controls for Public ROW Areas in Catchments with High Priority OI Land Areas.

This control program focuses on catchments with moderately to highly elevated PCBs or mercury where source investigations failed to identify specific PCBs or mercury source properties. If PCBs or mercury source properties cannot be identified in a catchment with moderately or highly elevated PCBs or mercury, Co-permittees will delineate the drainage area associated with the moderate or high result(s) and follow the process described in the CW4CB Guidance Manual to evaluate how other types of controls (e.g., enhanced O&M activities) may provide PCBs and/or mercury reductions. The selection of appropriate controls for each catchment is site-specific, and will be determined through an evaluation process that will take place after the results from a source area investigation indicate that no source property(s) has been identified in the catchment.

The Other Control Measure Programs described in this Plan implement control measures in OI land areas more opportunistically than the targeted control measures summarized above. As such, these other types of control programs may be implemented in catchments that have yet to be verified as having moderately or highly elevated PCBs or mercury; or where monitoring data indicate that an OI land area is not moderately or highly elevated. Other control measure programs include:

1. Green Stormwater Infrastructure (GSI). Includes parcel-based Low Impact Development (LID) implemented on properties and public green streets and regional GSI projects.

2. High-Flow Capacity Stormwater Treatment Systems and Inlet-based Stormwater Screening Devices. Stormwater treatment systems that include proprietary devices that remove sediment, trash, and other pollutants from stormwater through screening, trapping, and settling mechanisms.

In addition to the monitoring and control measures programs described above, this Plan also describes a new monitoring program that is currently under development by SCVURPPP to better demonstrate the potential scale of load reductions that can be achieved via both targeted and other control programs in OI land areas. Additional details on this program are described in Section 4.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 6 1.5 Organization of the Plan
The subsequent sections of this Plan are organized as follows:

Section 2 – Prioritized Locations For PCBs and Mercury Control Measure Implementation. This section identifies and prioritizes all OI land areas in the Santa Clara Valley that are potentially available for new or enhanced controls during MRP 3.0. These OI land areas are further prioritized for controls based on the availability and magnitude of PCBs or mercury monitoring data collected to date to classify OI land areas as high or low priority.

Section 3. Targeted Control Measure Programs. This section presents full details about the new, enhanced and ongoing control measure programs targeted in catchments containing moderately to highly elevated PCBs or mercury.

Section 4. Other Control Measure Programs. This section presents information about ongoing planning and implementation of other types of control measures that may provide important PCBs or mercury load reduction benefits on OI land areas. The types of controls and the assessments that Co-permittees will conduct to confirm that the controls implemented in these areas provide PCBs or mercury load reduction benefits are also presented in this section.

The new monitoring program that is under development to provide data to better evaluate the collective benefits of these other control measures is also described.

Section 5 – Estimated Pollutant Load Reductions. This section provides estimates of the PCBs and mercury load reductions that will occur if control measures described in Sections 3 and 4 of this Plan are implemented. Maximum and “best” load reduction estimates are provided and compared to the performance metrics identified in MRP 3.0 Provisions C.11/12.c. This information demonstrates that the majority of the estimated load reduction benefits that will be achieved via this Plan will occur through controls targeted at OI land areas in catchments with moderately or highly elevated levels of PCBs or mercury.

Section 6. Implementation Schedule. This section outlines the implementation schedule for the control measures described in this Plan.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 7 2. PRIORITIZED LOCATIONS FOR PCBS AND MERCURY

CONTROL MEASURE IMPLEMENTATION
This section identifies and prioritizes all OI land areas in the Santa Clara Valley that are potentially available for new or enhanced controls during MRP 3.0. These OI land areas are prioritized for controls based on the availability and magnitude of PCBs or mercury concentrations observed in monitoring data associated with specific OI land areas in the Santa Clara Valley.

2.1 OI Land Areas Available for Control Measure Implementation In 2002 (starting date of the PCBs and Mercury TMDLs), there were 7,509 acres of OI land areas in the Santa Clara Valley.2 These OI land areas are widely distributed across the Valley and are mostly comprised of private properties and old railroads. Over the past two decades, a large portion (30%) of this OI area has been redeveloped and stormwater runoff from these areas is now addressed through Low Impact Development (LID) and Green Stormwater Infrastructure (GSI). An additional portion of the 2002 OI area (1.2%) has been identified by SCVURPPP as a highly elevated PCBs source property and was referred to the Regional Water Board for abatement by a Co-permittee. Given the high level of pollutant load reduction efficiencies of LID/GSI control measures and source property abatement3, PCBs and mercury generated on these OI land areas are assumed to be effectively addressed by these controls.

For this Plan, LID/GSI controls implemented and source properties referred prior to July 1, 2021 are considered baseline controls and thus do not count towards the performance metrics described in MRP 3.0 Provisions C.11/12.c.4 As such, these areas are not considered “available” for new/enhanced controls during MRP 3.0. The remaining OI land areas where LID/GSI was not implemented, or source property referrals were not made as of July 1, 2021 (i.e., areas not fully addressed for PCBs and mercury) are considered potentially available for new or enhanced controls during MRP 3.0. Controls implemented in these areas after the baseline date and through the end of the permit term (i.e., between July 1 2021 and June 30, 2027) may count towards the performance metrics in MRP 3.0 Provisions C.11/12.c.

All OI land areas in the Santa Clara Valley do not contribute the same level of PCBs or mercury to stormwater. To allow for the most cost-effective implementation of stormwater control measures, OI land areas that are potentially available for controls must be prioritized based on available monitoring data. Information gained through sediment and stormwater monitoring data is used to help Co-permittees prioritize OI land areas for PCBs or mercury control measure implementation. Over the past 20 years, SCVURPPP has conducted stormwater and sediment monitoring on behalf of Co-permittees in the Santa Clara Valley to help prioritize and direct PCBs and mercury control measure implementation.

Monitoring conducted to verify that an OI land area is in fact contributing moderately or highly elevated levels of PCBs or mercury to a Co-permittee’s MS4 is called Verification Monitoring.

This type of monitoring is typically conducted in stormwater catchments containing OI land

2 The CMP submitted in March 2023 identified 8,350 acres of old industrial (OI) land areas in the Santa Clara Valley.

This number included 6,577 acres of OI parcels, 932 acres of old railroad parcels and rights-of-way (ROWs), and 841 acres of public ROW areas (i.e., streets/roads). The public ROW areas were removed from the OI land use classification in the current Plan (March 2024) for consistency with the other Bay Area counties, reducing the total OI land use area in the Santa Clara Valley to 7,509 acres. 3 BASMAA 2022.
4 Per Regional Water Board letter dated August 25, 2023.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 8 areas or in other areas where PCBs or mercury were historically used, disposed of, or released.

Verification Monitoring involves collecting screening-level stormwater or sediment samples in locations that drain entire catchments or sub-catchments containing OI areas. Samples are collected in the MS4, typically at outfalls (if possible) or further upstream in areas that drain a defined sub-catchment or specific OI parcels. If any screening-level samples have elevated concentrations (i.e., ≥ 0.2 mg/kg PCBs or ≥ 0.3 mg/kg mercury in sediments, or in stormwater, ≥

0.2 mg/kg PCBs or ≥ 0.3 mg/kg mercury particle ratio and/or > 36 ng/L of PCBs, which is the top 15% of stormwater concentrations measured in MS4s across the Bay Area), then the OI land areas within the catchment area are verified as potential contributors of moderately or highly elevated PCBs or mercury to stormwater, and the catchment is then targeted for additional controls to reduce/eliminate the sources of PCBs or mercury in the catchment. SCVURPPP Verification Monitoring is focused on collecting data in all OI land areas.

SCVURPPP has conducted Verification Monitoring of OI land areas for nearly two decades. The information gained through monitoring conducted through Water Year 2023 (i.e., September 31, 2023) was used to prioritize the 5,156 acres of OI land area that has not been fully addressed for PCBs or mercury and thus is potentially available for new or enhanced controls during MRP

3.0. All OI land areas not fully addressed for PCBs or mercury were classified into the following categories based on this information:
• High Priority for Targeted Controls: OI land areas within catchments where moderately to highly elevated PCBs or mercury have been observed via monitoring data. These areas are prioritized for targeted controls during MRP 3.0. Includes OI land areas that have been confirmed as source properties (but not yet referred or abated) or are potential sources of PCBs or mercury to the MS4. Targeted investigations of all potential sources are needed to identify specific source properties that contribute moderately or highly elevated PCBs or mercury to stormwater and determine the appropriate controls to address each source. • Low Priority for Targeted Controls: OI land areas where only low levels of PCBs or mercury have been observed via monitoring. These areas have been verified to have low levels of PCBs or mercury via stormwater monitoring at or near catchment outfalls; via sediment samples collected in the public ROW near or adjacent to OI land uses areas; or via sediment samples collected on OI parcels. OI land areas that are categorized as Low Priority will not be targeted for further control measure implementation during MRP 3.0. • Undetermined Priority: OI land areas that have not yet been monitored for PCBs and mercury. These areas require Verification Monitoring at the catchment, sub-catchment, or individual parcel-level to verify if PCBs or mercury are moderately or highly elevated. OI land areas that are verified as having moderately or highly elevated PCBs or mercury via monitoring data will be re-categorized as High Priority, while OI land areas identified as having low PCBs and mercury monitoring data will be re-categorized as Low Priority.

The Verification Monitoring process to categorize OI land areas as high or low priority for controls during MRP 3.0 is demonstrated in Figure 2.1.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 9 Figure 2.1. Flow chart demonstrating how verification monitoring is used to prioritize OI land areas for targeted controls during MRP 3.0 based on PCBs monitoring data.

Table 2.1 and Figure 2.2 present the MRP 3.0 baseline (July 1, 2021) treatment status of all 2002 OI land areas in the Santa Clara Valley. These areas include 2,264 acres of OI land areas that are addressed by LID/GSI projects constructed prior to July 1, 2021, and 88 acres of source properties referred to the Regional Water Board during MRP 2.0 for abatement. The remaining 5,156 acres of OI land areas that have not yet been fully addressed for PCBs and mercury are further prioritized for control measure implementation based on verification monitoring conducting through Water Year (WY) 2023, which ended on September 30, 2023.

Through WY 2023, SCVURPPP has conducted monitoring associated with 3,596 acres of the 5,156 acres of OI land areas that are not yet fully addressed by controls for PCBs and mercury at the start of MRP 3.0, including nearly 300 acres that were monitored during MRP 3.0 (i.e., in WY2022 or WY2023). Low PCBs and mercury were observed on the vast majority of these areas (86%). Other than the fact that these land areas are classified as OI, there is no evidence indicating that these land areas are contributing moderately or highly elevated PCBs or mercury to stormwater in the Santa Clara Valley. Therefore, these OI land areas are considered low priority for targeted controls, at least for the term of MRP 3.0. A total of 474 acres of the remaining OI land areas monitored by SCVURPPP are associated with moderately or highly elevated PCBs or mercury, and therefore are considered high priority areas for targeted control measure implementation during MRP 3.0.

For the 1,559 acres of OI land areas that are currently categorized as undetermined priority, where limited or no monitoring data are available to assist in the prioritization process, monitoring is planned to occur during MRP 3.0 or the subsequent permit term. Results from this monitoring will reclassify OI land areas into either the high or low categories, which may increase the acres of high priority areas where additional targeted control measures should be considered.

Next Steps
Outcomes of Verification
Monitoring (sediment or
stormwater monitoring)
determine priority for
targeted controls during
MRP 3.0
Verification Monitoring
starts with all OI land areas
that have not been fully
addressed for PCBs and have
not yet been monitored
Undetermined
Priority OI Land
Areas
High Priority OI
Land Areas
(PCBs ≥ 0.2 mg/kg
or >36 ng/L)
Requires Source
Area Investigation
Low Priority OI
Land Areas
(PCBs < 0.2 mg/kg
and < 36 ng/L)
No Further Action
Required During
MRP 3.0
MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 10 Table 2.1. Old industrial (OI) land areas in the Santa Clara Valley fully addressed for PCBs and mercury prior to MRP 3.0 and those (remaining) areas that are not fully addressed for PCBs and mercury, and further prioritized for targeted controls .a

SCVURPPP
Co-permittee
Total OI Land
Area in 2002
(acres)
OI Land Areas Addressed for PCBs and Mercury
Prior to MRP 3.0b (Acres)
OI Land Areas Not Fully Addressed for PCBs and
Mercury Prior to MRP 3.0c,d (acres)
Source Properties
Referred to Regional
Water Board
Addressed by
Low Impact Development
or Green Stormwater
Infrastructure
High Priorityd Low Prioritye Undetermined
Priorityf
Campbell 119 -- 11 0.53 48 59
Cupertino 183 -- 49 -- 92 42
Los Altos 2.0 -- -- -- 2.0 --
Los Gatos 31 -- 10 -- 19 1.7
Milpitas 387 -- 91 -- 248 48
Mountain View 405 -- 118 54 (50) 163 (71) 49
Palo Alto 451 -- 110 50 (17) 181 (2) 109
San Jose 3,448 5.1 920 168 1,472 (32) 883 (77)
Santa Clara 1,019 12.3 209 147 468 (45) 183
Unincorporated
Santa Clara County 293 -- 0.50 -- 168 (12) 124
Saratoga 44 -- 0.56 -- 5.4 38
Sunnyvale 1,127 70.2 745 56 234 (42) 22
TOTALS 7,509
88 2,264 474 (67) 3,122 (204) 1,559 (77)
2,352 5,156
a July 1, 2021 is the date used to denote whether a control was implemented before or during MRP 3.0. bThese old industrial (OI) land areas include those areas that have been addressed by source property referral and abatement or LID/GSI as of July 1, 2021. cThese OI land areas include those areas that have not been addressed by source property referral and abatement or LID/GSI as of July 1, 2021. dThe acres shown in parentheses (349 acres total) were monitored during MRP 3.0 to date (i.e., through WY2024); results for WY22 and WY23 were used to categorize 272 acres of OI acres as high or low priority, while results for WY24 data (77 acres) are still pending. dOI land areas associated with moderately or highly elevated PCBs or mercury based on monitoring data. eOI land areas associated with low levels of PCBs and mercury based on monitoring data. fOI land areas that have not been fully monitored.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 11 Figure 2.2. Geographical extent of land areas in the Santa Clara Valley identified as old (pre-1980) industrial land use in 2002 (i.e., starting date for the PCBs and Mercury TMDLs) categorized as fully addressed for PCBs and mercury or prioritized for targeted controls based on monitoring data.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 12 As illustrated in Figure 2.2, the OI land areas that have not yet been addressed for PCBs or mercury and are prioritized for controls are geographically distributed throughout the Santa Clara Valley and are not located in a single or small number of stormwater catchments. As a result, the treatment of entire stormwater catchments (e.g., diversions to POTWs) is likely not a cost-effective or a technically feasible option for addressing PCBs and mercury (or other pollutants) associated with these areas.

2.2 Planned Additional Verification Monitoring During MRP 3.0 The OI land areas in 31 catchments containing 789 acres of undetermined priority OI parcels were selected for Verification Monitoring during MRP 3.0. These catchments and the undetermined priority OI land areas within these catchments are shown on Figure 2.3.

Through WY2023, verification monitoring has been completed in 16 of the 31 catchments (i.e., ~300 acres of OI land areas). The outcomes from this monitoring have already informed the prioritization of these OI land areas into either the high or low priority categories, as shown on Figure 2.2 and in Table 2.1.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 13 Figure 2.3 Stormwater catchments and associated old industrial (OI) parcels in the Santa Clara Valley where V erification Monitoring has been competed or is planned during MRP 3.0.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 14 The remaining 15 catchments planned for Verification Monitoring during the permit term are presented in Table 2.2, along with the planned monitoring schedule. These 15 catchments represent more than 500 additional acres of OI land areas in the Santa Clara Valley. All OI land areas within catchments that are verified to have moderately or highly elevated PCBs or mercury through verification monitoring planned during MRP 3.0 will require Source Area Investigations as the next step, as described in the next section (Section 3.1).

Table 2.2. Verification Monitoring planned by SCVURPPP during MRP 3.0 to reclassify undetermined priority old industrial (OI) parcels in the Santa Clara Valley.

Catchment ID Co-permittee
Undetermined
Priority OI Land
Areas (acres)a
Planned Sample
Type
Implementation
Schedule
036PCL800 San Jose 59 Stormwater Planned WY2024
036PCL810 San Jose 9 Stormwater Planned WY2024
067CTC150 San Jose 28 Sediment Planned WY2024
PMC-D1 Santa Clara County 110 Stormwater Planned WY2025 066GAC152 San Jose 46 Stormwater Planned WY2025
049STA050 Santa Clara 37 Stormwater Planned WY2025
130CNC022 San Jose 34 Stormwater Planned WY2026
067CTC150 San Jose 28 Stormwater Planned WY2026
083CTC350 San Jose 28 Stormwater Planned WY2026
LGC-C3 San Jose 27 Stormwater Planned WY2027
067GAC190 San Jose 27 Stormwater Planned WY2027
050CTC100 San Jose 25 Stormwater Planned WY2027
016MTC910 Palo Alto 23 Sediment Planned WY2026
113LGC010 Campbell 23 Sediment Planned WY2027
113LGC565 Campbell 23 Sediment Planned WY2027
Total Acres 527
a Undetermined priority Ol parcels have not been fully addressed for PCBs and mercury and require monitoring to verify if they are associated with moderately or highly elevated PCBs or mercury concentrations.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 15 3. TARGETED CONTROL MEASURE PROGRAMS
This section describes control measure programs that are targeted at addressing PCBs or mercury on high priority OI land areas, known to generate moderately or highly elevated PCBs or mercury.5 The controls described are likely the most effective options for reducing pollutants associated with high priority OI land areas in the Santa Clara Valley. The targeted control measure programs currently being implemented or planned for implementation by SCVURPPP Co-permittees during the MRP 3.0 include the following:

1. Controls for Properties with Moderately Elevated PCBs or Mercury;

2. Abatement of Highly Elevated PCBs or Mercury Source Properties; and

3. Controls for Public ROW Areas in Catchments with High Priority OI Land Areas.

The overall goal of these targeted control programs is to identify and control contributions of moderately or highly elevated PCBs or mercury to stormwater. Additionally, these control measure programs will assist Co-permittees in achieving PCBs and mercury load reduction requirements described in MRP 3.0 Provisions C.11/12.c.

3.1 Source Area Investigations
As described in Section 2.2, Verification Monitoring assists Co-permittees in classifying and prioritizing OI land areas for control measure implementation. Once an OI land area is classified as high priority, based on monitoring data, SCVURPPP begins to conduct a Source Area Investigation in the associated stormwater catchment. The purpose of a Source Area Investigation is to identify specific source properties or source areas in the catchment that disproportionately contribute moderately or highly elevated PCBs or mercury to stormwater. As demonstrated in Figure 3.1, the outcomes of a Source Area Investigation help determine the appropriate control measure program that should be implemented to address PCBs or mercury contributions from one or more properties/areas in the catchment. Once identified, source properties or areas will be subject to the additional controls described in Sections 3.2, 3.3, and

3.4 until all technically and economically feasible controls to reduce PCBs or mercury loads from the catchment have been implemented.

5 As noted in Section 1.2, PCBs are considered elevated if concentrations in sediment are ≥ 0.2 mg/kg, or for stormwater samples if a PCBs particle ratio ≥ 0.2 mg/kg and/or a stormwater concentration >36 ng/L (i.e., the top 15% of concentrations measured in stormwater across the Bay Area) are observed. Mercury is considered elevated if concentrations in sediment are ≥ 0.3 mg/kg, or for stormwater samples if a mercury particle ratio ≥ 0.3 mg/kg are observed.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 16 Figure 3.1. Flow chart demonstrating progression from Source Area Investigations through control measure implementation and final outcomes for high priority OI land areas.

SCVURPPP has conducted Source Area Investigations in high priority catchments since MRP

1.0, but with new and enhanced efforts to gain access to and collect samples on private properties, this program is expanding during MRP 3.0. These new and enhanced efforts will support further reduction of PCBs and mercury to stormwater by accomplishing the following objectives:
1) Expand the search for source properties to include moderate PCBs or mercury6 sources in addition to high PCBs or mercury sources that have previously been the sole target, and
2) Identify additional source properties (both moderate and high) and (ultimately) control/abate.

Source Area Investigations are conducted in high priority catchments using a phased approach.

The first phase is a Targeted Public ROW Investigation and the second phase is an On-site Inspection and Sampling. Each of these investigation phases are described below. • Targeted Public ROW Investigation. This phase of investigation includes records review, public ROW surveys, and public ROW sampling. The information gathered during records review and public ROW surveys is used to inform development of a public ROW sampling plan. Samples are collected in public ROW locations that represents drainage or sediment release from suspect properties (typically OI parcels, but also other properties if records review/public ROW surveys indicate potential for PCBs or mercury sources on a given property). If any public ROW samples have elevated concentrations (≥ 0.2 mg/kg for PCBs or ≥ 0.3 mg/kg for mercury), the parcels draining or contributing

6 As described in Section 1.2, moderate PCBs and mercury are defined in MRP 3.0 as concentrations in sediment between 0.2 mg/kg and 0.5 mg/kg for PCBs, and between 0.3 and 1.0 mg/kg for mercury. High PCBs and mercury concentrations in sediment ≥ 0.5 mg/kg for PCBs and ≥ 1.0 mg/kg for mercury.

Final Outcomes
Investigation results
determine appropriate
controls
Conduct Source Area
Investigations in all High
Priority OI land areas

SOURCE AREA

INVESTIGATION
(Pulbic ROW Investigation
and/or Onsite Inspection and
Sampling

ABATEMENT

OF HIGHLY

ELEVATED
PCBS

PROPERTIES
Sources of PCBs or
mercury in the
catchment are
identified and
addressed

CONTROLS FOR

MODERATELY

ELEVATED
PCBS

PROPERTIES

CONTROLS

FOR PUBLIC

ROW AREAS
WTIH

ELEVATED
PCBS
Sources of PCBs or
mercury in the catchment
are not identified; controls
in public ROW are
implemented to address
PCBs and mercury.

LOW

PRIORITY -
NO

FURTHER

CONTROLS
DURING
MRP3
MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 17 sediment to that location are prioritized for on-site investigation. There may also be catchments that had elevated screening-level samples, but subsequent public ROW sampling does not point to any specific property(ies) as the potential source. When this occurs, all suspect properties in the catchment will be prioritized for on-site investigation and sampling. This can occur for a variety of reasons, for example there may not be appropriate or accessible sampling locations within the public ROW that represent drainage from a given property. Also, it is important to note that while the presence of an elevated sediment concentration in the public ROW is usually a clear indicator of proximity to a source, a low sediment concentration may be found even if sources are nearby. This is because sediment concentrations can be highly variable over time and across small spatial scales, and this variability is likely to increase with distance from the source. In some cases, additional on-site data may not be needed to determine if a given property is a source of moderately or highly elevated PCBs or mercury. If the public ROW data provides clear evidence that a given parcel is a source of PCBs or mercury to the MS4, then that parcel will be prioritized for the appropriate program (i.e., Controls for Properties with Moderately Elevated PCBs or Mercury or Abatement of Highly Elevated PCBs Source Properties).
• On-site Inspection and Sampling: In this phase of investigation on-site inspections and sampling of suspect properties are conducted to determine if the property is a moderately or highly elevated source of PCBs or mercury. On-site inspections and sampling for PCBs and mercury are coordinated with existing municipal stormwater inspection programs. During the property inspection, SCVURPPP and Co-permittee staff gather information about the property, including:
o Locations and descriptions of all on-site inlets and any other storm drain infrastructure that is directly connected to the MS4;
o Locations of potential sediment migration off-site;
o Locations and descriptions of potential sources of PCBs or mercury on the property;
o Locations and types of best management practices (BMPs) in place to address sediment migration and provide stormwater treatment.

This information helps Co-permittees identify where sediment samples should be collected on the property, and will also facilitate development of control plans if sampling data confirm the property is a source of moderately elevated PCBs or mercury and subject to the Controls for Properties with Moderately Elevated PCBs or Mercury control program described in Section 3.2.

SCVURPPP’s monitoring contractor collects the sample(s) on the property with permission of the property/business owner.

If on-site samples do not have elevated PCBs or mercury, the property is re-categorized as low priority and no further action is required during the permit term. If on-site samples have elevated PCBs or mercury, the property is confirmed as a source of moderately or highly elevated PCBs or mercury. If samples are not collected on a given property, either because appropriate sample collection locations are not found on-site or because property/business owners refuse permission, additional inspections or other follow-up actions may be needed. If samples are not collected because property/business owners refuse permission, Co-permittees will evaluate and consider using all available legal remedies to collect samples on the property. Alternatively, Co- permittees may require property owners to submit and implement an approved plan to prevent release of sediment-bound pollutants to the MS4 in-lieu of collecting samples. This last option is currently under consideration by Co-permittees.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 18 Planned/Ongoing Source Area Investigations During MRP 3.0 As shown in Table 3.1, during MRP 3.0 to date, Source Area Investigations have been completed, are ongoing, or are planned in 15 catchments that contain more than 400 acres of high priority OI land areas targeted for control program implementation during MRP 3.0. These catchments are classified as high priority because previous Verification Monitoring found moderately or highly elevated PCBs or mercury. Public ROW investigation, and/or On-Site Inspection and Sampling, and implementation of appropriate controls based on the investigation outcomes will be conducted in these 15 high priority catchments during MRP 3.0 to identify and control the PCBs or mercury source(s) to stormwater. High Priority Catchment Factsheets that detail the ongoing or planned investigations and control measure implementation during MRP 3.0 in these 15 catchments, including catchment maps are provided in Appendix A.

SCVURPPP anticipates starting Source Area Investigations in these catchments during MRP

3.0. In order to achieve the C.11/12.b requirement to investigate 913 acres of OI land areas during the permit term, the Program estimates that investigations will need to be completed for about 200 acres of high priority OI land areas shown in Table 3.1, combined with completing investigations in at least 700 acres of undetermined priority OI land areas described in Section

2.2. Table 3.1. Stormwater catchments with high priority old industrial (OI) land areas that are targeted for Public ROW Investigations or On-site Inspections and Sampling in the Santa Clara Valley during MRP 3.0.

Catchment
IDa Co-permittee Investigation Type
High Priority
OI Parcelsb
(acres)
Implementation
Schedule
032SVC400 Mountain View On-site Inspection/Sampling 20 Completed WY2022 017XXX010 Mountain View Palo Alto Public ROW Investigation 48 Ongoing WY2023/24 017PMC600 Mountain View On-site Inspection/Sampling 70c Ongoing WY2024 067CTC250 San Jose On-site Inspection/Sampling 23 Planned WY2024 050GAC580 Santa Clara Public ROW Investigation 113 Planned WY2024 033SVW955 Sunnyvale Public ROW Investigation 1.4 Planned WY2024 034BFL230B Sunnyvale
On-site Inspection/Sampling 12 Planned WY2024
Public ROW Investigation 1.9 Planned WY2024
048SVE395 Sunnyvale Public ROW Investigation 3.0 Planned WY2024 049CZC800 Sunnyvale Public ROW Investigation 13 Planned WY2024 049SVE410 Sunnyvale On-site Inspection/Sampling 10 Planned WY2024 017ADC600 Palo Alto
On-site Inspection/Sampling 9b
Planned WY2025
Public ROW Investigation 12
050GAC020 San Jose On-site Inspection/Sampling 38 Planned WY2025 050GAC400 Santa Clara
On-site Inspection/Sampling 0.4 Planned WY2025
Public ROW Investigation 23 Planned WY2025
067CTC030 San Jose Public ROW Investigation 12 Planned WY2025 113LGC030 Campbell On-site Inspection/Sampling 0.5 Planned WY2026 Total 410
aStormwater Catchments have been described as Watershed Management Areas (WMAs) in previous reports. b High priority Ol parcels are available for controls and are located in catchments with moderately or highly elevated PCBs based on monitoring data.
c These acres are not OI parcels, but samples collected in the adjacent public ROW have moderately/highly elevated PCBs.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 19 Figure 3.2. Stormwater catchments with high priority old industrial (OI) land areas that are targeted for Public ROW Investigations, On-site Inspections and Sampling and Targeted Control Programs in the Santa Clara Valley during MRP

3.0. MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 20 During MRP 3.0, Source Area Investigations are initially focused on the catchments identified in Table 3.1and shown on Figure 3.2. However, as Verification Monitoring of undetermined priority OI land areas proceeds during the permit term, the Program anticipates that additional catchments will be verified as having moderate/high PCBs or mercury. These catchments with high priority OI land areas will then be added to the Source Area Investigation program. Given that this process is sequential, all high priority OI land areas identified during MRP 3.0 may not be fully investigated by the end of the permit term.

Other Actions to Support Implementation of the Control Program Since the effective date of MRP 3.0 (July 2022), SCVURPPP and its Co-permittees have also conducted a number of other actions to ensure the successful implementation of the new and enhanced On-site Inspection and Sampling tasks to support the identification of PCBs or mercury sources. SCVURPPP has worked with Co-permittees over the past year to develop the on-site inspection and sampling process and procedures, and to provide tools to support implementation. For example, SCVURPPP developed a number of supporting documents that are intended to inform property/business owners of the inspection and sampling process, and to provide general information about stormwater issues, PCBs and mercury, regulations, and controls. Appendix B provides drafts of these documents, which include the following:
• Property Owner Letter to Inspect and Collect Samples on-site Template; and • Stormwater Pollutants Factsheet on PCBs and Mercury.

Although the overall On-site Inspection and Sampling process described in Section 3.1 above will be similar across all Co-permittees, implementation details will be tailored to each individual Co-permittee. Over the past year SCVURPPP staff has met multiple times with staff from the Cities of San Jose and Sunnyvale, the two cities where on-site inspection and sampling is planned to begin in FY 2023-24. The details of how each City will implement these actions were discussed and tailored. For example, the City of San Jose has decided to coordinate these inspections with their MRP 3.0 Provision C.3 Operation and Maintenance inspection team, and will develop a San Jose-specific letter to property owners to inform them in advance of the upcoming inspections. Full details of how each municipality implements these actions in coming years will be documented in future reports to the Regional Water Board.

In addition, all Co-permittees that have high priority OI land areas within their jurisdictions began reviewing their existing municipal codes over the past year and seeking input from their City Attorneys. The purpose of the review is to ensure that the Co-permittees have adequate authority to implement the new on-site inspection and sampling investigations described above, as well as other new MRP 3.0 requirements. To date, the outcomes of these reviews have varied across Co-permittees. While some Co-permittees are satisfied with the language in their current municipal codes, other Co-permittees are currently working on updates to more fully support implementation of the new or enhanced programs described in this Plan. These efforts are currently on-going and SCVURPPP will provide updates on the outcomes of these actions in future reports to the Regional Water Board.

3.2 Controls for Properties with Moderately Elevated PCBs or Mercury Control Measure Description
This control program is a new effort developed by SCVURPPP during MRP 3.0 that targets properties that generate moderately elevated PCBs or mercury. This program to address moderate pollutant contributing properties (MPCPs) is focused on implementing control measures on-site, before PCBs or mercury can reach public ROWs and Co-permittee MS4s.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 21 This control measure entails identifying properties with moderately elevated PCBs or mercury concentrations in sediments (0.2 to < 0.5 mg/kg for PCBs and 0.3 to < 1.0 mg/kg for mercury) through the source area investigations described in Section 3.1. Once identified, the control program includes tasks for Co-permittees to work directly with the property owners to cause the implementation of appropriate on-site controls. MPCPs can be addressed through voluntary actions by the responsible party (i.e., property owner, manager, and/or leasee/business owner) or through controls implemented by the responsible party as required by enforcement actions taken by a Co-permittee.

Following identification of an MPCP, Co-permittees (with support from SCVURPPP) work directly with the responsible party to cause implementation of appropriate controls on the property to prevent the release of PCBs or mercury to stormwater. The Co-permittee may require the responsible party to develop and implement a site-specific Source Property Pollutant Control Plan. The Source Property Pollutant Control Plan will identify all applicable PCBs or mercury sources and transport pathways on the property (e.g., stormwater runoff, wind, vehicle tracking, etc.) and the appropriate controls or BMPs that will be used to intercept each identified PCBs or mercury source/transport pathway.

The control program for MPCPs is still under development, but a preliminary outline of the implementation process and the party responsible for each step in the process is presented here.

Step 1. SCVURPPP staff will compile and describe data used to identify each MPCP. After an MPCP has been identified, SCVURPPP staff will prepare a brief technical memorandum that summarizes the relevant information gathered about the property during the source investigation. The memorandum may include information gathered during records review, inspections, and sampling, and will also include site maps that identify known or potential PCBs or mercury sources and transport pathways from the property to the MS4, as documented by SCVURPPP during site inspections.

Step 2 Co-permittee staff will develop an internal Co-permittee work plan that describes the process and timeline to address each MPCP. Co-permittee staff will review the technical memorandum and develop a site-specific work plan for each MPCP. The work plan will outline the steps that the Co-permittee will need to take to engage the responsible party and cause implementation of controls on the property to reduce the release of PCBs or mercury to the public ROW and the associated timeline. The work plan will address the following components:

1. Outline the process the Co-permittee will follow to inform responsible parties of the MPCP determination and next steps. This process may entail submitting a letter to the responsible party and following up with a scheduled meeting to provide information/guidance on required actions. In the letter and/or during the site visit, Co- permittees will inform responsible parties of the PCBs or mercury issue on their property, outline the requirements of the new control program for MPCPs, and provide guidance to responsible parties on next steps.

2. Identify the property abatement requirements. For example, the Co-permittee may require the responsible party to develop and implement a site-specific Source Property Pollutant Control Plan acceptable to the Co-permittee. The Source Property Pollutant Control Plan will document potential sources of PCBs or mercury on the property and associated transport pathways, and identify the control measure(s) that will be implemented to reduce/eliminate release of PCBs or mercury to MS4s via each source/pathway combination. Alternatively, the Co-permittee may provide the responsible party with a list of recommended site-specific controls, BMPs or other MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 22 actions that the responsible party can implement to reduce transport of PCBs or mercury from the property to the MS4. Responsible parties can choose to implement the recommended controls in lieu of developing their own PCBs or mercury control plan. The responsible party will be solely responsible for implementing the on-site control measures described in the Source Property Pollutant Control Plan or on the recommended list.

3. Identify potential enforcement actions or penalties for non-compliance (and associated timelines) that may be required to ensure the responsible party completes all requirements in a timely manner.

4. Determine follow-up actions to confirm the MPCP is appropriately controlled. For example, the Co-permittee may conduct follow-up inspections to ensure controls/BMPs are implemented and maintained as needed; or the Co-permittee may require the responsible parties to submit documentation to verify controls are in place and appropriately maintained.

5. Develop a schedule/timeline for all the work plan components to be implemented, including:
• Informing the responsible party of the MPCP designation; • Submission of Source Property Pollutant Control Plan by the responsible party for Co-permittee review (if applicable);
• Co-permittee review and approval of the Source Property Pollutant Control Plan (if applicable);
• Control measure/BMP implementation schedule;
• Follow-up actions; and
• Any enforcement actions or penalties if appropriate.

Step 3. Co-permittees will begin working with the Responsible Party to implement the internal work plan to address the MPCP. SCVURPPP staff will provide guidance and support as needed.

Controls on MPCPs are expected to provide a relatively high load reduction benefit for PCBs (and potentially mercury). The benefit is estimated to reduce PCBs from the OI land-use based yield of 259 mg/acre/yr to the Old Commercial/Old Transportation land-use based yield of 49 mg/acre/yr (BASMAA 2022). There is not currently an approved method to account for mercury loads reduced as a result of implementing controls on properties with elevated mercury concentrations. This will need to be developed and approved by Regional Water Board in order to take mercury load reduction credit for these actions. As the program is implemented, there will be future opportunities to evaluate and document the load reduction benefits of these actions.

Planned/Ongoing Implementation During MRP 3.0
Although this control program is new to MRP 3.0, SCVURPPP has already identified one MPCP in the Santa Clara Valley via On-site Inspection and Sampling, and anticipates identifying many more as on-site investigations continue during the permit term. The MPCP that has been identified to date is a 20-acre property located in stormwater catchment 032SVC400 in the City of Mountain View. SCVURPPP prepared a High Priority Catchment Factsheet for this catchment that identifies the MPCP on a map, and describes all existing and planned controls in the catchment during MRP 3.0 (Appendix A).

The MPCP property identified in catchment 032SVC400 was targeted for On-site Inspection and Sampling because in summer 2022, the City received information that PCBs were found on the MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 23 property as part of an ongoing hazardous materials investigation. Because this property is already on their current C.4 business inspection list, the City of Mountain View staff, with support from SCVURPPP, conducted an unannounced inspection and sample collection event at the property in August 2022. During the inspection, two sediment samples were collected from inlets on the property. One of these samples had moderate PCBs concentrations (0.21 mg/kg), confirming this property is an MPCP. The Program prepared a technical memorandum for the City of Mountain View that outlines the results of the investigation and identifies the next steps for this MPCP. The City is currently reviewing the memo and preparing to implement the MPCP process at this site.

At this time, no other MPCP properties have been identified in the Santa Clara Valley. However, given the upcoming (spring 2024) planned implementation of the enhanced efforts to collect samples on private properties as part of ongoing Source Area Investigations (as described in Section 3.1), SCVURPPP anticipates that new MPCPs will be identified during 2024. As these properties are identified, all MPCPs will be subject to this new control measure program.

Other Actions to Support Implementation of the Control Program SCVURPPP and Co-permittees conducted a number of other actions to ensure the successful implementation of the new program Controls for Properties with Moderately Elevated PCBs or Mercury to address MPCPs. SCVURPPP has worked with Co-permittees over the past year to develop the details of the control program, and to provide tools to support implementation. For example, SCVURPPP has developed both a template letter to inform property owners of the MPCPs control program, and a template for a Source Property Pollutant Control Plan that Co- permittees can provide to Property Owners so they can develop their site-specific control plans.

SCVURPPP has also developed a fact sheet that identifies the types of controls/BMPs that will likely be needed on MPCPs to prevent release of sediment-bound PCBs or mercury from the property. Drafts of the Source Property Pollutant Control Plan template and the factsheet are provided in Appendix B.

In addition, as described earlier in this section, all Co-permittees that have high priority OI land areas within their jurisdictions began reviewing their existing municipal codes over the past year.

The purpose of the review is to ensure adequate authority to implement the new control program for MPCPs as described above, as well as other new MRP 3.0 requirements. To date, the outcomes of these reviews have varied across Co-permittees, as described earlier in this section. These efforts are currently on-going and SCVURPPP will provide updates on the outcomes of these actions in future reports to the Regional Water Board.

3.3 Abatement of Highly Elevated PCBs or Mercury Source Properties Control Measure Description
This control program is a continuation of the efforts implemented by SCVURPPP and Co- permittees since MRP 1.0. This program targets properties that contribute highly elevated PCBs (≥ 0.5 mg/kg in sediment) or mercury (≥ 1.0 mg/kg in sediment) to stormwater and is conducted in parallel to the control program for MPCPs. Highly elevated PCBs or mercury source properties are identified through research and monitoring (i.e., Source Area Investigations).

Subsequent abatement of these source properties combined with focused control measure implementation in the public ROWs associated with these source properties can provide significant PCBs or mercury load reduction benefits. Property abatement may occur via actions taken by a property owner/manager voluntarily or as an outcome of enforcement actions brought against property owners by Co-permittees or through referrals to regulatory agencies (e.g., Regional Water Board, USEPA, etc.). Upon referral, Co-permittees conduct (or cause to MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 24 be conducted) interim enhanced O&M activities in the public ROW adjacent to referred properties or implement downstream treatment measures. These interim measures are intended to intercept historically deposited PCBs or mercury-laden sediment and prevent further discharge of PCBs or mercury from the source area until the property abatement is complete.

Abatement of Highly Elevated PCBs Source Properties provides the greatest PCBs load reduction benefit of all control measure programs (i.e., more than 20 times greater than the next most beneficial control measure). As such, identifying and abating highly elevated PCBs source properties has been and remains the most effective control measure for reducing PCBs loads from OI land areas in the Santa Clara Valley. The BASMAA Source Control Load Reduction Accounting for RAA document (BASMAA 2022) that Co-permittees are required to use for calculating pollutant load reductions during MRP 3.0 does not currently provide a method to account for mercury load reductions for source property abatement. However, if monitoring data demonstrate PCBs source properties are also mercury source properties (i.e., mercury ≥ 1.0 mg/kg in sediment), Co-permittees will evaluate the available data and develop a method to account for mercury load reductions that will occur as a result of property abatement actions, pending Regional Water Board approval of the new methodology.

Planned/Ongoing Implementation During MRP 3.0
The Abatement of Highly Elevated PCBs or Mercury Source Properties program has continued since the adoption of MRP 3.0 and will continue during the entire permit term. Through on-going source area investigations, SCVURPPP has recently identified ten (10) highly elevated PCBs source properties (70 acres) that will require abatement actions during MRP 3.0. These 10 properties are located in 7 different catchments in the Cities of Palo Alto, San Jose, and Santa Clara. The current status and planned actions to address each of these highly elevated PCBs source properties is summarized below. Additional information, including maps that identify each confirmed source property, the potential enhanced O&M activities, and other on-going or planned controls in the seven (7) catchments targeted for source property referrals during MRP

3.0 is detailed in the High Priority Catchment Factsheets provided in Appendix A.

Palo Alto Highly Elevated PCBs Source Property – Catchment 031SCH250 In January 2024, the City of Palo Alto submitted a source property referral to the Regional Water Board for a 19.3 acre multi-parcel property located at 3130-3100 Hansen Way and the parking lot of the property at 1001 Page Mill Road. The referral included an enhanced O&M plan which was approved by Regional Water Board staff prior to referral submission. The enhanced O&M plan entails an annual video and cleanout of the main public storm drain line that runs under the source property and continues downstream through the catchment. The City of Palo Alto is planning to conduct the first video and storm drain line cleanout during the upcoming dry season (summer 2024).

San Jose Highly Elevated PCBs Source Properties – Catchments 051CTC275, 051CTC400, 051CTC450, 067SCL080 and 083GAC900
Eight of the recently confirmed source properties are located in 5 stormwater catchments in the City of San Jose, including:
• 1815 - 1775 Monterey Road and 60-64 Barnard Ave (13 acres); • 1800-1900 Monterey Road (14 acres);
• 1788 Rogers Ave (1.9 acres);
• 1726 Rogers Ave (1.4 acres);
• 1645 Old Bayshore Highway (0.24 acres);
• 701 Kings Row (4.0 acres);
MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 25 • Railroad easement (5.7 acres);
• 520 North Marburg Road (8.9 acres).

The City of San Jose is planning to submit referrals to the Regional Water Board for all of these properties during MRP 3.0. City staff are currently evaluating the enhanced O&M actions that could be implemented in the vicinity of these properties and preparing the referral paperwork.

During the next few months, City staff will reach out to Regional Water Board staff to discuss these properties and receive approval for the enhanced O&M plans. The City is considering other enhanced O&M options for properties without stormwater treatment systems and high-flow capacity stormwater treatment systems (i.e., HDS units) in downstream locations that drain the confirmed source properties, including storm drain line flush and capture, street sweeping, enhanced storm drain inlet and pump station cleanouts. The City anticipates submitting referrals to the Regional Water Board for six of the properties this year, and the remaining two properties in the following year.

Santa Clara Highly Elevated PCBs Source Property – Catchment 066GAC150 The final confirmed source property is a 1.9-acre property located at 280 Martin Avenue.

Program and City staff are currently evaluating the available options to address this property, which may include submission of a new source property referral to the Regional Water Board during MRP 3.0. The City may also decide to work directly with the property owner to abate or cause the property to be abated. SCVURPPP and City staff are also currently evaluating appropriate enhanced O&M actions that could be implemented in the vicinity of this confirmed source property.

3.4 Control Program for Public ROW Areas in Catchments with High Priority OI Land Areas
Control Measure Description
This control program focuses on high priority catchments with moderately or highly elevated PCBs or mercury where a source property cannot be identified via source area investigations. If PCBs or mercury source properties cannot be identified in high priority catchments through the investigation process, Co-permittees will evaluate how alternative controls (e.g., enhanced O&M activities) may address PCBs or mercury in the applicable public ROW areas within the catchment.

The set of alternative controls evaluated will be site-specific and will focus on intercepting PCBs or mercury from the public ROW within catchments with observed (and verified) moderate or high levels of PCBs or mercury. An evaluation process will take place after a source area investigation has been completed in the catchment. The evaluation process will help Co- permittees identify the best control measure options for a given location. This process will follow the control measure evaluation and selection process that is outlined in the Clean Watersheds for a Clean Bay (CW4CB) Guidance Manual that was developed by BASMAA (2017). The CW4CB control measure selection process was developed to assist municipal agencies in selecting control measures at the site or catchment scale to address PCBs or mercury in municipal stormwater runoff. Controls in the CW4CB Guidance Manual include enhanced O&M activities (e.g., street sweeping, catch basin cleaning, pipe cleaning) and retrofitting public streets with GSI or other stormwater treatment controls (i.e., media filters, HDS units, etc.). The CW4CB evaluation and selection process identifies the factors that should be considered for each of these types of controls, including cost; load reduction potential; opportunity/feasibility; safety, and implementation challenges. Additional control-measure specific and site-specific factors are also identified for consideration in the CW4CB Guidance Manual. These factors will MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 26 be incorporated into a control measure scoring spreadsheet that will be used to score and rank the different controls for specific situations. This evaluation process will serve as the basis for control measure selection to address public ROW areas in high priority catchments where PCBs or mercury source(s) cannot be identified.

Planned/Ongoing Implementation During MRP 3.0
Implementation of the Control Program for Public ROW Areas in Catchments with High Priority OI Land Areas in a given location during MRP 3.0 is contingent on first completing the source area investigation process within that catchment. Because Source Area Investigations are currently ongoing or planned in all catchments that contain OI land areas that are available for controls, no catchments are currently targeted for this control program. However, as the permit term progresses, if Source Area Investigations are completed in a catchment and moderately or highly elevated PCBs or mercury source properties are not identified, then Co-permittees will delineate the drainage area and follow the process described in the CW4CB Guidance Manual to select and implement additional controls to reduce stormwater loads of PCBs or mercury from the catchment.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 27 4. OTHER CONTROL MEASURE PROGRAMS
This section presents information about ongoing planning and implementation of Other Control Measures that may provide important PCBs and mercury load reduction benefits when implemented on OI land areas. Other Control Measures include:
• Green Stormwater Infrastructure (GSI):
o Parcel-based Low Impact Development (LID);
o Public Green Streets and Regional GSI Projects;
• High-Flow Capacity Stormwater Treatment Systems (e.g., HDS Units); and • Inlet-based Stormwater Screening Devices.

These types of controls are primarily implemented for purposes other than the reduction of PCBs or mercury, and often by private parties to address stormwater impacts associated with their properties. This section describes these types of controls and the assessment that Co- permittees will conduct to confirm if these controls will provide PCBs and mercury load reduction benefits when implemented in catchments that may not have verification monitoring demonstrating moderately or highly elevated PCBs or mercury concentrations in stormwater.

This section also describes a new monitoring program that is under development to provide data to evaluate the collective benefits of these control measures at the catchment scale.

4.1 Green Stormwater Infrastructure
Control Measure Description
GSI uses vegetation, engineered soils, and natural processes to manage water and create healthier urban environments. GSI can treat stormwater to remove pollutants and protect water quality, store stormwater (direct water to stable storage areas away from roads and other development), and infiltrate treated water back into the groundwater table (replenishing the groundwater table). At the scale of a neighborhood or project site, GSI refers to stormwater management systems and features that mimic nature by absorbing and storing water. The two major categories of GSI measures that will be implemented during MRP 3.0 are described below.
• Parcel-based Low Impact Development (LID) - All Co-permittees’ currently require developers to submit applications for proposed new development and redevelopment projects to their Planning Departments for approval prior to construction. All projects that exceed the MRP 3.0 Provision C.3.b thresholds for Regulated Projects are required to implement LID techniques. In addition, all stormwater treatment on Regulated Projects must meet the C.3.d numeric sizing criteria for stormwater treatment systems.

Implementation of LID through redevelopment activities on private and public properties has been and will continue to be one of the most effective control measures available for reducing pollutant loads from OI land areas.
• Public Green Streets and Regional GSI Projects – These types of projects include retrofit of GSI into existing developed areas within the public ROW or on public parcels.

Along or within a street or public ROW, these measures are referred to as Green Street measures. When parcel-based GSI measures capture runoff from on-site and off-site areas, they are referred to as Regional Projects. Generally located on publicly-owned lands, Regional Projects may involve collaboration among multiple municipalities and/or public agencies to construct large GSI projects that capture and treat stormwater from large drainage areas.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 28 Current and Anticipated Level of Implementation
Parcel-based Low Impact Development (LID)
All SCVURPPP Co-permittees are continuing to use their planning authorities to ensure that applicable new development and redevelopment projects address stormwater runoff pollutants through the implementation of LID techniques, as required by MRP 3.0 Provision C.3. The majority of the processes and programs needed for Co-permittees to implement these requirements are already in place and Co-permittees plan to continue these efforts, as well as enhance and update systems and processes as needed to ensure new requirements in MRP

3.0 will be fully implemented.

Table 4.1 and Figure 4.1 present the OI land areas that have been or are anticipated to be redeveloped during MRP 3.0.7,8,9 Countywide, 40 acres of OI land areas have been redeveloped as C.3 Regulated Projects since July 1, 2021, the cutoff date for accounting for actions implemented in compliance with MRP 3.0 Provisions C.11/12.c. Of these 40 acres, 15 acres are located in high priority catchments with moderately or highly elevated PCBs. Another 18 acres are located in undetermined priority catchments that have not yet been monitored, and the remaining 7.4 acres are in low priority catchments where monitoring to date has only found low levels of PCBs. There are also an estimated 422 acres of OI parcels that are currently anticipated to undergo redevelopment during MRP 3.0. Of these 422 acres, 185 acres are located in high priority catchments, 123 acres are located in undetermined priority catchments, and 113 acres are in low priority catchments.

While it is possible that not all of the “anticipated” GSI/LID projects summarized in Table 4.1 will be completed by the end of the MRP 3.0 term due to project delays, Co-permittees anticipate that the majority of these projects will be constructed by June 30, 2027. Further, there will likely be additional LID facilities constructed via redevelopment projects not included in these estimates that will be constructed during the permit term due to the reduced thresholds in MRP

3.0 for Regulated Projects, which became effective in July 2023.

All existing and planned/anticipated parcel-based LID projects that are located in undetermined and low priority catchments will be required to demonstrate PCBs or mercury load reductions achieved in order to claim credit for these projects under C.11/12.c. This information may include new monitoring data, information on historical parcel use, hazardous materials information from environmental impact reports (EIRs), etc. Co-permittees will conduct an assessment of each completed parcel-based LID project prior to claiming PCBs or mercury load reduction credit under C.11/12.c. Available information will be compiled and evaluated during the assessment to determine if there is adequate justification to claim a PCBs or mercury load reduction credit for a GSI/LID project.

7 Based on information available as of the writing of this report. 8 Projects completed between July 1, 2021 and June 30, 2027 are eligible for load reduction credit under MRP 3.0. 9 Co-permittees identified “anticipated” LID projects by reviewing project permit applications received as of approximately December 2022. Projects that qualify as C.3 Regulated Projects deemed likely to be completed during the permit term that will address OI land areas were identified.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 29 Figure 4.1. Locations where parcel-based Low Impact Development (LID) projects have been recently completed or are anticipated during MRP 3.0, including those within high priority catchments with moderately or highly elevated PCBs .

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 30 Table 4.1. Extent of land areas in high, undetermined and low priority catchmentsa in the Santa Clara Valley where parcel-based Low Impact Development (LID) projects have been recently completed or are anticipated during MRP 3.0.

Catchment
Priority

SCVURPPP
Co-permittee
Parcel-based LID Redevelopment Projects in MRP 3.0
(Acres of OI Parcels)
Constructed Anticipated/ Planned Total
High Campbell 0.3 1.7 2.0
Mountain View 1.3 1.3
San Jose 1.5 154 156
Santa Clara 5.8 21 27
Sunnyvale 7.1 6.8 14
Subtotal 15 185 200
Undetermined Campbell 0.4 0.4
Mountain View 4.3 4.3
Palo Alto 2.3 7.9 10
San Jose 16 55 71
Santa Clara 36 36
Sunnyvale 20 20
Subtotal 18 123 141
Low Mountain View 26 26
Palo Alto 47 47
San Jose 0.7 37 38
Santa Clara 3.7 3.7
Sunnyvale 3.0 3.4 6.4
Subtotal 7.4 113 120
Totals 40 422 462
a High priority catchments have moderate/high PCBs in the catchment based on monitoring data; Undetermined priority catchments have not yet been monitored, and Low priority catchments have low PCBs in the catchment based on monitoring to date.

To further support these efforts, and in general, provide more data to better understand the PCBs or mercury load reduction benefits of LID projects at the catchment scale, SCVURPPP Co-permittees are also developing a new monitoring program that will begin during MRP 3.0.

The full details of this new monitoring effort are still under development, but the overall plan is to identify catchments with completed C.3 LID projects, for which pre-redevelopment PCBs or mercury data are available (at the catchment, sub-catchment, or parcel scale). Post- redevelopment monitoring will be conducted and the results compared to pre-redevelopment monitoring data. The Program has already identified one catchment (017PMC600) in the Santa Clara Valley where this type of monitoring is currently being planned. Catchment 017PMC600, located in the City of Mountain View, will be targeted for post-redevelopment monitoring during the permit term. Additional information about this catchment, including a map of existing monitoring data, the extent of existing C.3 redevelopment, and other controls in the catchment is provided in the High Priority Catchment Factsheet (Appendix A).

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 31 The Program is also reviewing existing monitoring data and locations of recent redevelopment to identify other locations where this type of post-redevelopment monitoring could be conducted and compared to pre-redevelopment monitoring data.

Green Streets and Regional GSI Projects
Co-permittees are also continuing to implement their Municipal GSI Plans10 that were developed during MRP 2.0 to identify, prioritize, design and implement public GSI projects during MRP 3.0.

These efforts include the following actions:
• Annual reviews of Capital Improvement Plan (CIP) projects to identify any opportunities to incorporate GSI into CIP projects and evaluate feasibility. As part of this review, Co-permittees are conducting site reconnaissance, drainage area delineation, and cost analysis to determine which projects can include a GSI component;
• Evaluation of non-CIP project opportunities;
• Coordination with private development – Co-permittees continue to explore options for working with private property developers to install GSI facilities in public ROWs near redeveloped properties, such as along street frontages; • Evaluation of opportunities identified in SCVURPPP’s Stormwater Resource Plan (SWRP);
• Redevelopment in OI/moderate PCBs or mercury areas – Co-permittees are exploring opportunities to install GSI facilities in these areas as they are redeveloped;
• Continue to update and maintain the list of GSI projects that are planned for implementation, and infrastructure projects that have potential for GSI measures (Co-permittees submit these lists to the Regional Water Board each year with Annual Reports); and
• Continue to explore future funding options and identify resources for implementing GSI projects.

Co-permittees will continue to evaluate the extent of implementation, feasibility, locations, and funding options for additional GSI project opportunities during MRP 3.0. These new analyses may focus on the increased emphasis on addressing OI land areas, as well as the new C.3.j numeric GSI retrofit requirements in MRP 3.0. For the Santa Clara Valley, the countywide numeric retrofit target identified in MRP 3.0 Provision C.3.j is 46.09 acres of area treated by GSI projects during the permit term. Each municipal agency is required to address between 0.2 and

5.0 acres (prorated based on population) of land area via GSI retrofit projects.

In addition to the planning underway by each Co-permittee to address Provision C.3.j targets, there is also one large regional project in the City of San Jose that is currently under construction. This project is shown on Figure 4.2 and summarized below. • River Oaks Stormwater Capture Project - The City of San Jose received grant funding to support this project and the City provided matching funds. Construction began in 2023

10 City of Campbell 2019, City of Cupertino 2019, City of Los Altos 2019, City of Milpitas 2019, City of Monte Sereno 2019, City of Mountain View 2019, City of Palo Alto 2019, City of San Jose 2019, City of Santa Clara 2019, City of Saratoga 2019, City of Sunnyvale 2019, County of Santa Clara 2019, Town of Los Gatos 2019, Town of Los Altos Hills 2019
MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 32 and will be completed in 2024. The project will collect and treat stormwater runoff from approximately 344 acres of impervious and pervious surfaces prior to its discharge into the Guadalupe River. The catchment is primarily high-density residential and commercial land uses, with some open space. The project will modify the existing pump station and retrofit the existing stormwater detention basin to divert and treat stormwater runoff, and also convert the site into a publicly accessible bioretention area with recreational, aesthetic and educational features. The project will divert both dry and wet weather flows from the existing pump station into a large bioretention basin that will provide stormwater treatment prior to discharge to the Guadalupe River. The site where the bioretention basin will be constructed currently contains a stormwater detention basin used for flood control. The treated flows from the bioretention basin will be captured by underdrains and discharged to the Guadalupe River by a new pump station.

Additionally, SCVURPPP and Co-permittees are working through the Bay Area Municipal Stormwater Collaborative (BAMSC) to identify new funding sources for GSI implementation in the Santa Clara Valley and throughout the region. One such funding source is the new Region 9 USEPA San Francisco Bay Program Office established through recent federal legislation. The new SF Bay Program Office anticipates receiving federal funding annually to support the implementation of projects that protect and restore the SF Bay. The current priority list for projects includes those that implement GSI and address the PCBs TMDL for the SF Bay.

SCVURPPP is currently working with the BAMSC to establish a process at the regional scale to identify, rank, and select high priority projects for funding consideration through the new SF Program Office. SCVURPPP will provide updates on the status of establishing and implementing this new project prioritization and selection process in future reports to the Regional Water Board.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 33 Figure 4.2. Planned location and drainage area of the anticipated River Oaks Stormwater Capture Project in the City of San Jose, CA.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 34 4.2 Other Types of Stormwater Treatment Systems
Control Measure Description
The stormwater treatment systems described in this section are devices or series of devices that trap all particles retained by a 5 mm mesh screen and have a design treatment capacity of not less than the peak flow rate resulting from a one-year, one-hour storm in the tributary drainage catchment area. These devices are grouped into two general categories: 1) high-flow capacity systems that treat stormwater runoff from hundreds of acres (i.e., large devices), and 2) inlet-based stormwater screening devices that typically treat stormwater runoff from two or less acres of land (i.e., small devices). Because the State Water Board has certified a variety of these proprietary devices as achieving full trash capture, these systems are primarily installed for the purposes of MRP Provision C.10 (trash load reduction) compliance. However, when installed in drainages that contain moderately or highly elevated PCBs or mercury, these systems also reduce PCBs and mercury in direct proportion to the total suspended solids (TSS) removal efficiency (BASMAA 2018).

High-flow capacity stormwater treatment systems include hydrodynamic separators (HDS), debris separating baffle boxes (DSBBs), and gross solids removal devices (GSRDs). HDS devices are flow-through structures that use the tangential forces created by the incoming flow of water to separate trash, debris and sediment, oil and other pollutants from stormwater. These devices rely on a circular chamber to swirl the flow and a settling or separation unit to remove pollutants. Baffle boxes are subsurface rectangular vaults that are placed in line with the storm drain system to reduce pollutant loadings by capturing sediments, gross solids, and associated pollutants. Treatment mechanisms typically include filtration, hydrodynamic separations, and adsorption. These units are installed as sub-surface vaults commonly subdivided into a series of chambers by vertical baffles that interrupt the stormwater flow and promote capture of suspended particles by sedimentation. GSRDs use various screening technologies to remove trash, debris, and solids 5 mm and larger from stormwater runoff. These screens provide treatment by preventing solids larger than the screen opening from passing through. The PCBs and mercury removal efficiencies for these high-flow capacity stormwater treatment systems range from 14% (GSRDs) to 20% (HDS and Baffle boxes) (BASMAA 2022).

Inlet-based stormwater screening devices are generally screens or baskets that are installed in storm drain inlets and typically treat stormwater runoff from an acre or less of land. These devices can also provide PCBs or mercury load reductions due to the trapping and removal of contaminated sediment. When maintained appropriately, the PCBs and mercury removal efficiencies for these devices is approximately 18% (BASMAA 2022).

Current and Anticipated Level of Implementation
During MRP 3.0, Co-permittees are continuing to evaluate and plan for the installation of additional high-flow capacity stormwater treatment systems and inlet-based stormwater screening devices in the Santa Clara Valley to achieve trash, PCBs and mercury load reduction benefits. The systems that have been installed during MRP 3.0 to date, or are planned (i.e., currently funded) or proposed (currently undergoing feasibility analysis) for installation during MRP 3.0 and their estimated drainage areas are shown on Figure 4.2. The locations of OI land areas that are/will be treated by these systems are also shown on Figure 4.2. Tables 4.2 and

4.3 present additional information about installed and planned treatment systems shown on Figure 4.2. Since July 1, 2021, Co-permittees have installed 227 new inlet-based stormwater screening devices in high priority stormwater catchments with moderately or highly elevated PCBs, and are currently planning to install one new high-flow capacity stormwater treatment system that will treat 145 acres of OI parcels in a high priority catchment during the permit term MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 35 (Table 4.2). Additional systems and devices have been installed during the permit term that are located in catchments containing undetermined or low priority OI areas (Table 4.3). These systems address about 11 acres of OI land areas.

Additional information on the drainage areas and locations of newly installed or planned devices that are located in high priority catchments is detailed in the High Priority Catchment Factsheets provided in Appendix A. Installations of high-flow capacity stormwater treatment systems and inlet-based stormwater screening devices that are not located in high priority catchments will require additional information to demonstrate PCBs or mercury load reductions.

For the purpose of C.11/12.c performance metrics, the PCBs or mercury load reduction credit for these projects will only apply to those projects that can provide sufficient evidence of PCBs or mercury in the treated catchment. The assessment that will be conducted to demonstrate this is the same as that described for LID/GSI projects in Section 4.1.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 36 Figure 4.3. Drainage areas for high-flow capacity stormwater treatment systems and inlet-based stormwater screening devices installed, planned or proposed for installation during MRP 3.0.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 37 Table 4.2 Drainage areas and associated land uses for high-flow capacity stormwater treatment systems and inlet-based stormwater screening devices installed or planned for installation during MRP 3.0 in high priority stormwater catchments with moderately or highly elevated PCBs or mercury.

Co-
permittee
High Priority
Stormwater
Catchment
Status
(Installed after July
1, 2021 or Planned)
Device Type Device
Count
Acres Treated
Old
Industrial
Old Commercial/
Old Transportation
Old
Residential
New
Urban Ag/Open Totals
San Jose
050GAC020
Planned
High-flow
capacity
Stormwater
Treatment
1 -- 1.4 -- -- 1.1 2.6
051CTC275 141 166 1.7 102 28 438
051CTC400 4.3 3.1 -- 8.0 0.01 15
066GAC550 0.14 0.12 -- 0.07 -- 0.33
Other - San Jose 0.00 0.45 -- -- 0.32 0.77
Subtotal 145 171 2 110 29 457
Santa
Clara
049CZC800
Installed
Inlet-based
Stormwater
Screening
Device
10 4.8 9.3 -- 4 0.1 18
050GAC400 120 34 77 103 1.3 0.6 216
050GAC580 63 55 13 0.2 4.2 0.00 73
066GAC150 34 2.6 12 1.2 0.8 0.00 16.4
Subtotal 96 111 104 10 0.70 323
Totals 235 242 282 106 121 30 781

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 38 Table 4.3. Drainage areas and associated land uses for high-flow capacity stormwater treatment systems and inlet-based stormwater screening devices installed during MRP 3.0 in undetermined or low priority stormwater catchments.

Co-permittee Stormwater
Catchment ID
Status
(Installed after July
1, 2021 or Planned)
Device Type
Acres Treated
Old
Industrial
Old Commercial/
Old Transportation
Old
Residential
New
Urban Ag/Open Totals
Campbell
113LGC010
Installed
Inlet-based
Stormwater
Screening Device

2.3 3.8 0.0 1.8 -- 8.0
113LGC140 -- 0.3 1.6 -- -- 1.9
Other - Campbell -- 19 28 -- -- 47
Other - San Jose -- -- 0.0 -- -- 0.0
Cupertino Other - Cupertino Installed
Inlet-based
Stormwater
Screening Device
-- 0.1 -- -- 0.6 0.7
Los Gatos Other - Los Gatos Installed
Inlet-based
Stormwater
Screening Device
-- 15 2.6 -- 0.0 17
Palo Alto
Other - Palo Alto Installed
High-flow capacity
Stormwater
Treatment

4.5 105 84 34 89 317
016MTC910
Installed
Inlet-based
Stormwater
Screening Device
-- 4.2 0.7 -- -- 4.9
Other - Palo Alto -- 0.2 -- -- -- 0.2
Santa Clara
049STA050
Installed
Inlet-based
Stormwater
Screening Device

0.8 1.9 1.1 0.7 -- 4.5
049STA300 2.1 7.4 -- 1.4 -- 11
Other - Santa Clara 1.1 126 183 23 4.1 337
Other - Santa Clara
County -- -- 0.0 -- -- 0.0
Sunnyvale Other - Sunnyvale Installed
Inlet-based
Stormwater
Screening Device
-- 2.0 1.5 -- 0.7 4.2
Totals 11 285 301 61 95 753

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 39 In addition to installed and planned stormwater treatment systems described above, SCVURPPP conducted a GIS analysis to identify new opportunities for both high-flow capacity stormwater treatment systems and inlet-based stormwater screening devices within the Santa Clara Valley. This analysis is focused on identifying locations that would provide load reduction benefits for PCBs, mercury and trash. This analysis identified all overlapping areas in the Santa Clara Valley that met each of the following criteria:

1. OI land areas that are potentially available for controls during MRP 3.0; and

2. Areas that have moderate, high, or very high baseline levels of trash generation that are not currently addressed by existing (or planned) GSI or stormwater treatment systems; and

3. Areas that are located in high priority moderate/high PCBs or mercury catchments.

These areas represent potential locations where multiple benefits may be possible for reductions of PCBs, mercury and trash. The results identify locations where additional systems/devices will be considered during MRP 3.0 to address multiple pollutants. These multi- benefit areas based on the analysis conducted to date are illustrated in Figure 4.2.

The final step of this GIS/desktop analysis involved a careful review of the storm drain infrastructure configuration and other features within the areas of potential multi-benefit, to further evaluate the feasibility of installing and operating stormwater treatment systems in these areas. The results of this analysis to date have identified 23 high priority catchments that contain moderately or highly elevated PCBs that are potentially good candidates for high-flow capacity stormwater treatment systems or inlet-based stormwater screening devices to achieve multi-benefit PCBs, mercury and trash load reductions. The OI land areas within these catchments that overlap with significant trash generating areas total 309 acres. Another 266 acres of undetermined-priority OI land areas were also identified that overlap with significant trash generating areas. As verification monitoring of these undetermined priority OI land areas continues during the permit term, additional information will be available to determine if these locations are also good candidates based on the potential to provide multi-benefits.

In a related analysis, the City of San Jose has identified inlets in the City that are prioritized for potential installation of inlet-based stormwater screening devices based on trash load reduction needs. SCVURPPP staff reviewed these inlet locations and stormwater treatment devices, if feasible. As verification monitoring of undetermined priority catchments continues during the permit term, additional information will be available to determine if other inlets are also good candidates based on the potential to provide multi-benefits.

The next step is for Co-permittee staff to ground truth the information provided above by visiting the prioritized sites and making observations and measurements of the critical features necessary to identify whether a stormwater treatment device can be installed at the location of interest. One source of potential funding that Co-permittees are actively pursuing is through Caltrans’ Cooperative Implementation Agreements (CIAs). As part of this step, locations that are not good candidates for high-flow capacity devices will be considered for multiple inlet-based devices. As a last step in the analysis, Co-permittees will evaluate resources and determine the feasibility of installing and maintaining stormwater treatment devices at the given locations. The feasibility analysis will include consideration of the initial funds needed to purchase and install each device, as well as the ongoing staffing resources that will be required to operate and maintain each device in the future.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 40 Figure 4.4. Areas of potential multi-benefit for PCBs, mercury and trash load reductions in the Santa Clara Valley.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 41 5. ESTIMATED POLLUTANT LOAD REDUCTIONS
This section presents the estimated load reductions of PCBs and mercury that are anticipated to occur as a result of the continued, enhanced, and new control measures described in Sections 3 and 4. All load reductions were calculated using the accounting methodologies in BASMAA (2022).

5.1 Targeted Control Measure Programs
The estimated maximum annual PCBs and mercury load reductions that may be achieved by Co-permittees via implementation of Targeted Control Programs described in Section 3 were calculated based on the following assumptions:
• 70 acres of highly elevated PCBs source properties recently identified by Co-permittees but not yet been referred to the Regional Water Board will be referred during MRP 3.0; the associated enhanced O&M in public ROWs adjacent to the source properties will be implemented by Co-permittees; and Co-permittees will be credited for 50% of the PCBs load reduction associated with these properties.
• 50 new acres of highly elevated PCBs source properties will be identified (i.e., 2.6% of the ~2,000 acres of OI land areas that require either Verification Monitoring or Source Area Investigation to identify sources) and referred to the Regional Water Board during MRP 3.0; the associated enhanced O&M in public ROWs adjacent to the source properties will be implemented by Co-permittees; and Co-permittees will be credited for 50% of the PCBs load reduction associated with these properties. • 20 acres of MPCPs identified to date in Mountain View will be addressed as Mountain View staff work with the property owner to implement control measures on the property during MRP 3.0; Co-permittees will be credited for the associated PCBs load reduction. • 400 new acres of MPCPs will be identified (i.e., 20% of the 2,000 acres of OI land areas that require either Verification Monitoring or Source Area Investigations to identify sources); Co-permittees will be able to successfully work with the appropriate parties (e.g., property owners or managers) to implement control measures on the properties during MRP 3.0; and Co-permittees will be credited for the associated PCBs load reduction.
• PCBs loads reduced for abatement of highly elevated source properties is 5 g/acre/yr and loads reduced for controls implemented on MPCPs is 0.2 g/acre/yr. • No mercury load reductions for targeted controls are currently accounted for in this Plan.

During the permit term, Co-permittees may propose accounting methodologies for moderately and highly elevated mercury source properties and submit to the Regional Water Board for approval.

Control measures described in Section 3 and implemented based on the assumptions above would address 540 acres of OI parcels in high priority catchments with moderate/high PCBs and provide up to 390 g/yr of PCBs load reduction in the Santa Clara Valley. Abatements of all newly identified source properties (both highly and moderately elevated) however are unlikely to be completed by the end of the permit term. As listed in Table 5.1, a more conservative “best” estimate of PCBs load reduction that will be realized during MRP 3.0 via Targeted Control Programs is 50% of the 390 g/yr load reduction (i.e., 195 g/yr). Of this amount, the best estimate for the load reductions that will be achieved via controls on moderate PCBs properties (i.e., in MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 42 compliance with C.12.c) is 44 g/yr of PCBs load reduction. Note, there are assumed to be no mercury load reduction benefits via abatement of PCBs source properties. However, if mercury concentrations are elevated at any of these moderate or high PCBs source properties prior to abatement, then mercury load reduction benefits will be evaluated.

5.2 Other Control Measures
The estimated maximum annual PCBs and mercury load reductions that may be achieved by Co-permittees via implementation of the Other Control Programs described in Section 4 were calculated based on the following assumptions:
• 15 acres of parcel-based LID facilities constructed after July 1, 2021 address OI parcels located in high priority catchments that have moderate/high PCBs based on monitoring data.
• 25 acres of parcel-based LID facilities constructed after July 1, 2021 address OI parcels located in undetermined/low priority catchments; evidence of pre-redevelopment PCBs or mercury contamination will be provided.
• Anticipated construction of 185 acres of parcel-based LID facilities on C.3 Regulated Projects address OI parcels in high priority catchments that have moderate/high PCBs based on monitoring data by the end of MRP 3.0.
• Anticipated construction of 236 acres of parcel-based LID facilities on C.3 Regulated Projects address OI parcels in undetermined/low priority catchments by the end of MRP

3.0; evidence of pre-redevelopment PCBs or mercury contamination will be provided. • The construction of a regional GSI stormwater capture project that will address 0.4 acres of OI, 0.42 acres of old commercial/old transportation, and 12 acres of old residential land use areas.
• 50% (23 acres) of the Provision C.3.j retrofit requirement will be implemented in high priority catchments that have moderate/high PCBs based on monitoring data. • PCBs and mercury load reductions for parcel-based LID are calculated as the difference between the OI land use yield and the new urban land use yields, as described in BASMAA 2022.
• PCBs and mercury load reduction efficiencies are 70% for green streets and regional retrofit projects constructed in areas with evidence of moderate to high PCBs and mercury.
• Planned new high-flow capacity stormwater treatment systems will be installed in high priority catchments by the end of MRP 3.0 that will address 145 acres of OI, 171 acres of old commercial/old transportation, and 2 acres of old residential land use areas. • 227 inlet-based stormwater screening devices installed after July 1, 2021 in high priority catchments that address 97 acres of OI, 112 acres of old commercial/old transportation, and 105 acres of old residential land use areas.
• 178 inlet-based stormwater screening devices installed after July 1, 2021 in undetermined priority catchments that address 6.4 acres of OI, 285 acres of old commercial/old transportation, and 301 acres of old residential land use areas. Evidence of PCBs or mercury contamination in the drainage area will be provided. • One high-flow capacity stormwater treatment system installed after July 1, 2021 in an undetermined priority catchment that addresses 4.5 acres of OI, 105 acres of old MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 43 commercial/old transportation, and 84 acres of old residential land use areas. Evidence of PCBs or mercury contamination in the drainage area will be provided. • PCBs and mercury load reduction efficiencies for high-flow capacity stormwater treatment systems and inlet-based stormwater screening devices range from 14% to 20%, depending on the type of system installed (BASMAA 2022).

Control measures described in Section 4 and implemented based on the assumptions above would address more than 700 acres of OI parcels in high priority catchments with moderately or highly elevated PCBs. This level of control measure implementation would provide 142 g/yr of PCBs load reduction and 44 g/yr of mercury load reduction. Construction/installation of all planned GSI facilities and other stormwater treatment systems, however, are unlikely to be completed by the end of the permit term. As listed in Table 5.1, a more conservative “best” estimate of PCBs and mercury load reductions that will be realized during MRP 3.0 via Other Control Programs is roughly 50% of the maximum load reduction for anticipated/planned projects and 100% of the load reduction for projects that have already been completed (i.e., 77 g/yr) for PCBs and 25 g/yr for mercury.

5.3 Summary of Anticipated Load Reductions
Table 5.1 presents the estimated PCBs and mercury load reductions that are anticipated via the control measures outlined in Sections 5.1 – 5.2 as described in this Plan. All load reductions were calculated using the methods approved by the Regional Water Board Executive Officer and described in BASMAA (2022). These estimates include the maximum load reduction potential if all controls described in this Plan are implemented, as well as the best estimate and ranges for the more realistic levels of control measure implementation during MRP 3.0. The best estimates for load reductions anticipated to occur during MRP 3.0 in OI land and other land areas with moderate to high PCBs in the Santa Clara Valley are 272 g/yr for PCBs (ranging from 131 g/yr to 401 g/yr) and 25 g/yr for mercury (ranging from 13 g/yr to 35 g/yr). The majority of the PCBs load reductions during MRP 3.0 (~70%) will occur as a result of targeted control programs implemented in high priority catchments with moderately to highly elevated PCBs based on monitoring data. Excluding high PCBs source property referrals, the best estimates for load reductions that will be achieved via this Plan in moderate OI areas are 121 g/yr for PCBs and 25 g/yr for mercury. These best estimates for PCBs demonstrate that Co-permittees will be able to achieve the C.12.c load reduction requirement of 121 g/yr from OI/moderate PCBs areas during MRP 3.0. The range of likely mercury load reductions demonstrates that Co-permittees may be able to achieve the C.11.c load reduction requirement of 28 g/yr from OI/moderate mercury areas during MRP 3.0. Note, these estimates do not include any mercury load reductions for addressing moderately elevated mercury source properties. Co-permittees will need to evaluate the mercury load reduction benefits of moderate PCBs source property abatements that occur during the permit term and document the mercury load reduction benefits achieved at properties where monitoring data indicated mercury concentrations on the property were elevated. These evaluations are expected to provide additional mercury load reductions that will ensure achievement of the C.11.c load reduction requirement for mercury.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 44 Table 5.1. Estimated PCBs and mercury load reductions anticipated to occur via the implementation of control measures identified in Sections 5.1 and 5.2 of this Plan.a, b, c Control
Measure
Assumptions for Estimated Loads Reduced
PCBs Loads Reduced (g/yr) Mercury Loads Reduced (g/yr)
Maximum
Potential
Best
Estimate Min Max Maximum
Potential
Best
Estimate Min Max
Targeted
Control
Programs
70 acres of confirmed highly elevated PCBs source properties will be referred and 50% load reduction will be credited 176 88 44 132 No mercury load reduction is currently estimated for
moderately or highly elevated
PCBs source property
abatement, but will be
evaluated during the permit
term for any PCBs source
properties that also have
elevated mercury.
50 acres of new highly elevated PCBs source properties will be identified/referred and 50% load reduction will be credited 126 63 32 95
20 acres of currently identified MPCPs will be controlled for PCBs 4 2 1 3 400 acres of new MPCPs will be identified and controlled for PCBs 84 42 21 63 Subtotal 390 195 98 293
Other
Control
Measures
LID facilities in high priority catchments via C.3 requirements for Regulated projects (Constructed after July 1, 2021) 4 1
LID facilities in medium/low priority catchments via C.3 requirements for Regulated projects (Constructed after July 1, 2021); evidence of PCBs or mercury contamination provided 7 3 2 5 1 1 0.3 0.9 Anticipated completion of planned/potential LID facilities in high priority catchments via C.3 requirements for Regulated projects 48 24 12 36 9 5 2 7 Anticipated completion of planned/potential LID facilities in medium/low priority catchments via C.3 requirements for Regulated projects; evidence of PCBs or mercury contamination provided 61 31 15 46 12 6 3 9 Anticipated completion of planned regional GSI project which will address old commercial/old transportation and old residential land areas 0.3 0.2 0.1 0.2 5 2 1.2 4 50% of the green street or regional GSI projects constructed by Co-permittees to comply with Provision C.3.j will address old industrial/moderate PCBs or mercury land use areas 4 2 1 3 1 0.5 0.3 0.8 Anticipated high-flow capacity stormwater treatment systems installed in high priority catchments 9 5 2 7 4 2 1 3
Inlet-based stormwater screening devices installed in high priority catchments after July 1, 2021 6 3
Anticipated high-flow capacity stormwater treatment systems installed in undetermined or low priority catchments; evidence of PCBs or mercury contamination provided. 1 1 0.3 1 4 2 1.0 3.0 Inlet-based stormwater screening devices installed in undetermined priority catchments; evidence of PCBs or mercury contamination provided. 2 1 0.5 1 4 2 1.1 3.2 Subtotal 142 77 33 109 44 25 13 35
Subtotal – Includes all controls in moderate/OI areas for credit towards MRP C.11/12.c 230 121 55 175 44 25 13 35 Totals 532 272 131 401 44 25 13 35
a Maximum Potential: the total load reduction that can be achieved for the maximum level of planned implementation for all controls described in Sections 3 and 4. b Best Estimate: the total load reduction that can be achieved assuming only 50% of the maximum level of anticipated/planned implementation occurs and 100% implementation for control measures completed since July 1, 2021.
c Range: the range of load reductions that can be achieved assuming 25% to 75% of the maximum level of planned implementation occurs for all control measures.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 45 6. PLANNING AND IMPLEMENTATION SCHEDULE
Table 6.1 provides the anticipated schedule for implementing the major control measure planning and implementation actions described in this Plan during the term of MRP 3.0. Given the uncertainties in the Plan surrounding the development and implementation of new programs, funding options, and other limitations, SCVURPPP will provide updates to this Plan via the Program’s annual report to document the completion of tasks, projects, progress of ongoing evaluations and planning studies, and the addition of any new projects or controls not included in this version of the document. The annual updates will also serve to document many of the requirements of MRP Provision C.11/12 for annual reporting, including:
• Report progress on the acreage of land areas investigated, and actions taken for parcels investigated (e.g., abatement referral, enforcement, etc.); • Source Property Referral Reports;
• Descriptions of enhanced O&M associated with Source Property Referrals; and • Report on control measures implemented consistent with the Plan, and any modifications thereto.

Further, the information documented in the Plan and annual updates will be used to demonstrate achievement of the PCBs and mercury load reduction requirements identified in C.11/12.c, as well as document the overall loads of PCBs and mercury reduced Program-wide through implementation of all control measures during the permit term.

The Plan may also be updated and revised to reflect changing or new conditions in local watersheds, additional knowledge gained and lessons learned from ongoing control measure implementation, monitoring data, model outputs, etc. SCVURPPP will collect information from Co-permittees on an annual basis to document completed projects and level of control measure implementation achieved each year, and all associated loads reduced due to these actions.

Tracking and mapping of completed GSI/LID projects will continue through the SCVURPPP Stormwater Treatment Measures (STM) Data Portal. Currently, the STM Data Portal operates as a centralized, web-based data management system with a connection to GIS platforms to track and map all completed GSI/LID projects in the Santa Clara Valley. The data portal may be updated in the future to track other types of control measures, including installation of other types of stormwater treatment systems and devices, the locations and types of enhanced O&M activities, and to document abatement on PCBs or mercury source properties (both moderately and highly elevated), as they are completed.

Additionally, this Plan does not limit SCVURPPP or any of its Co-permittees from pursuing any and all remedies that they may have in response to the MRP, including seeking funding for these mandates.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 46 Table 6.1. Anticipated schedule for control measure planning and implementation tasks in old industrial (OI) and moderate PCBs or mercury land areas during MRP 3.0.

Control Measure - Planning and Implementation Tasks
MRP 3.0 Year
FY 22-23
FY 23-24
FY 24-25
FY 25-26
FY 26-27
Targeted Control Programs
Verification
Monitoring and
Source Area
Investigations
Conduct Verification Monitoring in undetermined priority catchments to confirm moderate/high PCBs or mercury

Conduct Targeted Public ROW investigations in high priority catchments Develop new on-site inspection and sampling procedures
Conduct On-site Inspection and Sampling investigations
Review investigation results and identify new moderate/high PCBs or mercury source properties
Program to Control
Moderate Pollutant-
Contributing
Properties (MPCPs)
Develop the new Program to Control MPCPs
Implement the new Program to Control MPCPs
Program to Abate
High PCBs or
Mercury Source
Properties
For recently confirmed source properties (70 acres), evaluate options and develop plans for abatement and enhanced O&M

Submit referrals for high PCBs or mercury source properties to Regional Water Board and begin enhanced O&M in public ROWs

For new high PCBs or mercury source properties identified during MRP 3.0, evaluate options for property abatement and enhanced O&M and develop plans

Submit referrals for new source properties to Regional Water Board and begin enhanced O&M in public ROWs
Controls for Public
ROW Areas in
Catchments with
High Priority OI Land
Areas
As source investigations are completed, develop plans to implement controls in public ROWs in catchments where sources were not identified.

Document PCBs and mercury loads reduced during permit term for implementation of targeted control programs.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 47 Control Measure - Planning and Implementation Tasks
MRP 3.0 Year
FY 22-23
FY 23-24
FY 24-25
FY 25-26
FY 26-27
Other Control Programs
Green Stormwater
Infrastructure

Continued municipal oversight and review to ensure all C.3 Regulated Project requirements are met. Continued inspections and tracking of all C.3 Regulated Projects.

Continued planning and implementation of Co-permittee GSI Plans River Oaks Regional Stormwater Capture Project
Design
Construction
Ongoing planning to identify public C.3.j project sites, develop funding sources, design and construct projects.

Document PCBs or mercury loads reduced during permit term for all constructed GSI/LID projects.

Plan and implement new monitoring program to provide post-redevelopment data for LID/GSI projects
Other Stormwater
Treatment Systems
Construct planned high-flow capacity stormwater treatment systems and inlet-based stormwater screening devices.

Conduct additional GIS analyses to identify candidate catchments for high-flow capacity stormwater treatment systems or inlet-based stormwater screening devices to achieve multiple benefits.

Ground-truth candidate catchment locations and potential funding sources.

Plan and implement additional stormwater treatment systems.

Document mercury and PCBs or mercury loads reduced during permit term for all constructed/installed high-flow capacity stormwater treatment systems and inlet-based stormwater screening devices.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 48 7. REFERENCES
Bay Area Stormwater Management Agencies Association (BASMAA) 2017. Clean Watersheds for a Clean Bay. Final Project Report. Prepared by EOA, Inc. and Geosyntec Consultants. April 2017.

BASMAA 2017. Guidance to San Francisco Bay Area Local Agencies for Reducing Polychlorinated Biphenyls (PCBs) and Mercury in Municipal Stormwater Runoff. May 2017.

BASMAA 2018. Evaluation of PCBs in Caulk and Sealants in Public Roadway and Storm Drain Infrastructure Final Project Report. Prepared by EOA, Inc. August 16, 2018.

BASMAA 2022. Source Control Load Reduction Accounting for Reasonable Assurance Analysis. Prepared for BASMAA by Geosyntec Consultants, Inc., and EOA, Inc. January 21, 2022.

City of Campbell 2019. Green Stormwater Infrastructure Plan. July 2019.

City of Cupertino 2019. Green Stormwater Infrastructure Plan. September 2019.

City of Los Altos 2019. Green Stormwater Infrastructure Plan. July 2019.

City of Milpitas 2019. Green Stormwater Infrastructure Plan. September 2019.

City of Monte Sereno 2019. Green Stormwater Infrastructure Plan. August 2019.

City of Mountain View 2019. Green Stormwater Infrastructure Plan. September 2019.

City of Palo Alto 2019. Green Stormwater Infrastructure Plan. 2019.

City of San Jose 2019. Green Stormwater Infrastructure Plan. September 2019.

City of Santa Clara 2019. Green Stormwater Infrastructure Plan. August 2019.

City of Saratoga 2019. Green Stormwater Infrastructure Plan. August 2019.

City of Sunnyvale 2019. Green Stormwater Infrastructure Plan. August 2019.

County of Santa Clara 2019. Green Stormwater Infrastructure Plan. September 2019.

San Francisco Bay Regional Water Quality Control Board (SFBRWQCB), California State Water Resources Control Board, and California Department of Fish and Game. 1995. Contaminant Levels in Fish Tissue from San Francisco Bay: Final Report. San Francisco Regional Water Quality Control Board, Oakland, CA.

SFBRWQCB 2006. Mercury in San Francisco Bay, Proposed Basin Plan Amendment and Staff Report for Revised Total Maximum Daily Load (TMDL) and Proposed Mercury Water Quality Objectives.

SFBRWQCB 2008. Total Maximum Daily Load for PCBs in San Francisco Bay, Staff Report for Proposed Basin Plan Amendment. February 2008.

SFBRWQCB 2022. San Francisco Region Water Quality Municipal Regional Stormwater NPDES Permit. Order R2-2022-0018, NPDES Permit No. CAS612008.

Santa Clara Valley Urban Runoff Pollution Prevention Program (SCVURPPP) 2021. Stormwater Control Measures Plan for PCBs and Mercury in the Santa Clara Valley - Version 5.0 (2016- 2021). September 30 2021.

MRP 3.0 Control Measure Plan for Old Industrial Areas in the Santa Clara Valley 49 SCVURPPP and Santa Clara Valley Water District (Valley Water) 2019. Santa Clara Basin Stormwater Resource Plan. Final Report. Prepared by EOA, Inc., Paradigm Environmental, and Lotus Water. August 2019.

Town of Los Gatos 2019. Green Stormwater Infrastructure Plan. August 2019.

Town of Los Altos Hills 2019. Green Stormwater Infrastructure Plan. August 2019

1 City of San Pablo
2025 Request for Proposals for PCB-125

DATE: April 16, 2025

SUBJECT: ADDENDUM NO. 1
Request for Proposals
PCB TMDL Special Studies and
Implementation Project (PCB-125)

To Prospective Consultants:

The following are responses to the questions submitted prior to the April 15 due date:

1 Question Since the Scope-of-Work involves a PCB TMDL study, will the awardee need to engage an environmental laboratory to perform PCB analyses, i.e. is this a component of the Scope?
Answer Yes.
2 Question Considering the page count on this, do resumes count towards the page limit?
Answer The proposals can exclude resumes from the page count. Please include resumes as an appendix or attachment.
3 Question Will the City be providing an attendee list of those who participated on the call?
Answer No.
4 Question On the RFP cover page, the title includes “(PCB-125)”. What is the driver or reason for PCB-125 in the title?
Answer PCB-125 is the City’s internal project tracking number/system.

5 Question Does the City require a prevailing wage for travel time? Answer Yes.
6 Question RFP Section 9, Method of Payment, specifies that the contract will be a Lump Sum agreement. The work and work tasks are anticipated to be adaptively managed as the work proceeds over the five-year period, e.g., under Task 2, “Because of the anticipated timing of permit adoption, the scope of work for this task divides first-year activities not specifically dependent on adopted regulatory language, and later years’ activities where precise regulatory language should be available to fully scope out sub-tasks in accordance with adopted permit language.” Can the contract be conducted as a time and materials agreement with a firm fixed not to exceed value?
Answer Yes, the City has changed Section 9. Method of Payment to time and material with a not-to-exceed amount. The RFP Language changes as follows:

Remove the paragraph in Section 9. Method of Payment:

The method of payment for this contract will be a Lump Sum agreement with

2 City of San Pablo
2025 Request for Proposals for PCB-125

the ability of monthly progress payments based on work performed. The consultant performs the services stated in the contract for an agreed amount as compensation. For invoice procedures; the City will receive the invoice from the Contractor, submit for reimbursement from EPA, once payment is received the City will then issue payment for the invoice.

And replace with the following:

The method of payment for this contract will be time and material with a not- to-exceed amount. The contract has the ability for progress payments not to exceed a frequency of more than monthly. For invoice procedures; the City will receive the invoice from the Contractor, and submit it for reimbursement from EPA, once payment is received the City will then issue payment for the invoice

7 Question Item C.4 of the RFP requests Resumes or Statement of Qualifications. Do the resumes count toward the 25-page limit?

Answer No, please see the answer to question 2.
8 Question Can the proposer provide an appendix of resumes to provide a streamlined response that will not count against the 25-page limit?

Answer Yes, please see the answer to question 2.
9 Question Items C.9. Method of Payment and C.12. Special Requirements are part of the Proposal Requirements. Please clarify the required information for each to respond to the RFP.

Answer No specific proposal requirement is needed for C.9 if the cost proposal provides the key information as stated in item C.8. For C.12 the proposer is expected to take the required steps to ensure that the DBE requirements are met. Proposals can either state in their proposal that they have completed the required steps regarding a “good faith effort” or can state how the DBE requirements are being met.
10 Question Item C.10 References requires a summary of three projects in progress or completed. Is a description of the services expected in addition to items a- e?

Answer As part of C.10.b the reference should provide a 1-2 sentence description of the project type and the services the proposed provided. 11 Question Item C.11 Consultant Contract Statement requires a statement affirming the acceptance or listing of any proposed modifications of the terms of the City’s Consultant Agreement. How would the City like Proposers to prepare these?

3 City of San Pablo
2025 Request for Proposals for PCB-125

Answer If a proposer is accepting contract language as is, please make a statement that the proposer agrees to the contract language as is and does not require any modifications. Any proposer who may have proposed modifications can make redline adjustments to the provided standard contract language or a list of requested changes with specific sections identified and the requested alternative language provided.
12 Question Can figures and tables be provided on 11 x 17” paper?

Answer Yes.
13 Question EPA released a notice on 4/11/2025 suspending DBE requirements under 40 CFR Part 33. Does this notice affect the information required to be submitted in response to RFP Section K, Special Requirements?

Answer On April 11, 2025, EPA released RAIN-2025-G02. The City will be following this new guidance. Please note that not all sections of 40 CFR Part 33 have been suspended, in addition, the guidance states “nothing in this class exception and waiver affects EPA’s statutory obligations or agency recipient obligations under 2 CFR Part 200.” Therefore, according to the City’s understanding of the guidance there will be no changes to “Section 12 Special Requirements” of the RFP, and the City is still requesting assistance with the completion of form 5700-52A as stated in Section D.5 on page 15.

14 Question In Attachment 4, the City of San Pablo attached a Quarterly Report Template. Does the City of San Pablo also have a template for the Final Report to be submitted as a requirement for the EPA Grant Award?

Answer No.
15 Question Can the City of San Pablo provide the template for the Final Report to be submitted as a requirement for the EPA Grand Award?

Answer No.
16 Question Please confirm that the Region 2 Phase II Programs participating in the Grant Project are those listed as project partners:
a. Marin Countywide Stormwater Pollution Prevention Program, b. Napa Countywide Stormwater Pollution Prevention Program, c. County of Sonoma,
d. City of Petaluma,
e. City of Benicia, and
f. Port of Oakland

Answer The above-listed Phase II programs are participating in the program in addition to Solano County. Therefore, the full list of Phase II programs is as follows:
b. Marin Countywide Stormwater Pollution Prevention Program, c. Napa Countywide Stormwater Pollution Prevention Program, d. County of Sonoma,
4 City of San Pablo
2025 Request for Proposals for PCB-125

e. City of Petaluma,
f. City of Benicia,
g. Port of Oakland, and
h. Solano County.

Updated: 3/25 Page 17
Exhibit B
Consultant’s Proposal dated May 1, 2025

May 1, 2025
Amanda Booth
City of San Pablo
1000 Gateway Ave
San Pablo, CA 94806
Subject: Larry Walker Associates, Inc. Proposal for Request for Proposals - PCB TMDL Special Studies and Implementation Project
Dear Ms. Booth:

Larry Walker Associates, Inc. (LWA), and our
partners, EOA, Geosyntec Consultants, Stone Creek
Environmental, Applied Marine Sciences, Integral
Consulting, and Northgate Environmental
Management (collectively the LWA Team), are
pleased to express interest in the Request for
Proposals for the PCB TMDL Special Studies and
Implementation Project (PCB-125). With over 40
years of experience in water quality and stormwater
management, the LWA Team brings specialized
expertise in technical stormwater permit
implementation and grant administration to support
the City of San Pablo (City) and the Bay Area Municipal Stormwater Collaborative (BAMSC) Regional Partners.

In responding to the RFP, LWA has assembled a team of experts who currently assist the BAMSC Regional Partners with administrative, technical, and stormwater program implementation. In addition to a proven record in implementing regionwide grant-funded projects in the San Francisco Bay, the LWA Team has the direct experience in providing comprehensive support to the BAMSC Regional Partners in implementing the San Francisco Bay PCBs TMDL. We are confident our team's expertise aligns perfectly with the project requirements and objectives. Our combined resources bring together industry-leading specialists in water quality monitoring, PCB source identification, control measure planning, regional project coordination, and grant administration – all essential components for successful execution of this project.

Having worked on similar TMDL implementation projects throughout the Bay Area, we recognize the importance of close coordination with Phase I Countywide Programs and Phase II permittees, as well as the need for innovative approaches to PCB source identification and control. Our team has the technical expertise, local knowledge, and proven track record necessary to deliver all required tasks while ensuring stakeholder engagement.

The LWA Team understands that the City submitted the USEPA Water Quality Improvement Fund (WQIF) Grant Application on behalf of the BAMSC Regional Partners and will serve as the fiscal agent for the duration of the Project. The LWA Team is poised to support the City with project management and LWA Team Experience
 BAMSC Regional Stakeholder engagement
 EPA Grant Administration and Project
Implementation
 NPDES compliance for municipal governments.
 San Francisco Bay PCBs TMDL Implementation,
including TMDL calculations and compliance
 Countywide Stormwater Program
Implementation and Collaboration
 Phase II Permittees Program Implementation
Support
PCB TMDL Special Studies and
Implementation
PCB-125

compliance with all EPA grant requirements. The LWA Team has the proven ability to successfully manage and implement grant projects for both individual and diverse stakeholder groups. Hallmarks of our approach include bringing flexibility to the project while managing the overall effort to meet the desired end goals; integrating project staff into a cohesive working team; providing an adaptive atmosphere that encourages interaction and communication; and being responsive to unforeseen needs, such as additional meetings or changes in direction or scope.

Our experience specifically includes the implementation and administration of multiple WQIF grant awards, including countywide and regionwide projects. With our Team’s extensive background in PCBs TMDL implementation, strong working relationships with the City and the BAMSC Regional Partners, and proven expertise in producing deliverables on-time, the City can be assured of our commitment and ability to complete the proposed workplan within the grant timeframe.

As an officer of LWA, I welcome the opportunity to discuss how we can support the City in implementing the WQIF Grant Agreement and Workplan. Please contact me with any questions about our qualifications or approach to serving the City.

Sincerely,

Sandy Mathews, Vice President
Larry Walker Associates, Inc.

Contract Point of Contact
Sandy Mathews, Vice President
2246 Sixth Street
Berkeley, CA 94710
(510) 883-9873 x 412
[email protected]

PROPOSAL FOR
May 1, 2025
PCB TMDL Special
Studies and
Implementation
Project
Presented to:

The City of San Pablo
Prepared by:

Larry Walker Associates, Inc.
in association with
EOA, Geosyntec Environmental Consultants,
Stone Creek Environmental Consulting,
Applied Marine Sciences, Integral Consulting &
Northgate Environmental Management
LARRY WALKER ASSOCIATES PROPOSAL PREPARED FOR:

City of San Pablo

PCB TMDL Special Studies & Implementation (PCB 125) 1 Larry Walker Associates, Inc. (LWA) is pleased to provide the following proposal in response to the Request for Proposals (RFP) for PCB TMDL Special Studies and Implementation Project (Project) (PCB-125) for the City of San Pablo (City). The LWA Team comprises Applied Marine Sciences, Inc. (AMS), EOA, Inc. (EOA), Geosyntec Consultants, Inc. (Geosyntec), Integral Consulting, Inc. (Integral), Northgate Environmental Management, Inc. (Northgate), and Stone Creek Environmental Consulting, Inc. (Stone Creek).

The LWA Team understands that the City is seeking qualified consultants to implement the Workplan associated with EPA Grant Award No. W9-97T23001-0, the PCBs TMDL Special
Studies and Implementation Project, which will fund the continued implementation of the San Francisco Bay PCBs
TMDL. The LWA Team understands that the City submitted the USEPA Water Quality Improvement Fund (WQIF) Grant
Application on behalf of the Bay Area Municipal Stormwater Collaborative (BAMSC) Regional Partners and will serve as the fiscal agent for the duration of the Project.

2.0 ORGANIZATION CHART & PERSONNEL
As demonstrated by the qualifications and supporting information listed below, the LWA Team is uniquely and effectively positioned to assist the City in implementing the PCB Total Maximum Daily Load (TMDL) Special Studies and Implementation Project. The LWA Team is comprised of the trusted technical leadership for all five Bay Area Phase I Stormwater Programs and the Phase II permittees with more than 30 years of experience in stormwater management in the San Francisco Bay Area.

Figure 1. Structure of the LWA Team
Project Manager
Elizabeth Yin, Senior Scientist
2246 Sixth Street
Berkeley, CA 94710
(510) 883-9873 x 414
[email protected]

LARRY WALKER ASSOCIATES PROPOSAL PREPARED FOR:

City of San Pablo

PCB TMDL Special Studies & Implementation (PCB 125) 2 Key staff identified for the LWA Team are comprised of highly qualified professionals who possess the qualifications and experience to successfully lead their tasks to support the City and the Project Partners with the requested services. LWA will have overall responsibility for the successful completion of all tasks and the delivery of high-quality deliverables. The organizational chart presented in Figure 1 provides an overview of the LWA Team structure. Assigned key staff are available for the duration of the contract and are committed to meeting the City and Regional Partners' schedule.

As Project Manager, Ms. Yin will coordinate staff and subcontractors to ensure seamless delivery of all project components. The identified task leads will support Ms. Yin in developing the approach for each Task identified by the City and Project Partners. The LWA Team has additional technical specialists available to support the Project with expertise in:
• Implementing regional monitoring programs;
• Developing and implementing PCBs Programs;
• Working with Phase II communities, including monitoring constituents of concern; • Developing monitoring plans and preparing reports detailing control measures; • Administration of large-scale grant-funded projects; and • Regulatory negotiation and stakeholder facilitation.

LWA will notify the City in writing to receive approval for any change to the Project Team key staff.

2.1 HISTORY OF COLLABORATION
The LWA Team has a proven track record of successfully managing collaborative, team- based projects and working cooperatively with other firms to achieve project objectives and goals. Hallmarks of our approach include bringing flexibility to the project plan while managing the Project to meet the stated end goals; integrating multidisciplinary experts into a cohesive working team; and providing an adaptive atmosphere that encourages interaction and communication amongst the Team and stakeholders.

In particular, the LWA Team has a long history of successful completion of projects using local, state, and federal grants, both for individual agencies as well as through regional collaborations. The LWA Team leads, participates, and is integral to the success of BAMSC, which was formed to continue to provide an institutionalized mechanism for its member agencies to develop innovative products and programs that are more cost-effective done regionally than can be accomplished locally. Through BAMSC, the LWA Team has overseen the completion of numerous collaborative regional projects and has proven its capacity to collaborate on significant projects of regional importance by producing deliverables and outcomes that provide much of the foundation for current regional stormwater quality management efforts.

In addition, the LWA Team is comprised of firms that have direct experience working with the City of San Pablo, as well as all of Phase I and Phase II Regional Partners involved in the scope of work:
• Phase I Programs:
 Alameda Countywide Clean Water Program (ACCWP);
 Contra Costa Clean Water Program (CCCWP);
 Santa Clara Valley Urban Runoff Pollution Prevention Program (SCVURPPP);  San Mateo Countywide Water Pollution Prevention Program (SMCWPPP); and  Solano Stormwater Alliance.
• Phase II Programs:
 Marin Countywide Stormwater Pollution Prevention Program (MCSTOPPP);  Napa Countywide Stormwater Pollution Prevention Program (NCSPPP);  County of Sonoma;
 City of Petaluma;
 City of Benicia;
 Port of Oakland; and
 Solano County.

LARRY WALKER ASSOCIATES PROPOSAL PREPARED FOR:

City of San Pablo

PCB TMDL Special Studies & Implementation (PCB 125) 3

3.0 FIRMS STATEMENT OF QUALIFICATIONS
Table 1 features our Team's broad expertise in developing and implementing regional PCBs monitoring programs, working with Phase II permittees, monitoring constituents of c oncern, identifying source properties and control measure planning, regional collaboration, and grant administration.

Table 1. LWA Team Relevant Project Experience
Technical Expertise Permittee Experience
Firms
Tributary Monitoring
Alternative Source Property Investigation
Green Infrastructure Planning
PCB-Containing Building Materials and
Waste Control Program
PCB Source Property and Area Identification
Overpass and Bridge PCB Control
Mercury Collection and Recycling
PCB Risk Reduction Program
TMDL Water Quality Monitoring
Regional Load Reduction Accounting
Framework
Public ROW and Private Property Sediment
Sampling
Catchment Verification Sampling
Load Verification Monitoring
GIS Maps & Databases
PCBs Control Programs for Private Properties
PCBs Control Programs for MS4
Program Administration & Management
Contra Costa Clean Water Program
Alameda Countywide Clean Water Program
San Mateo Countywide Pollution Prevention
Program
Santa Clara Valley Urban Runoff Pollution
Prevention Program
Solano Stormwater Alliance
Phase II Permittees
LWA • • • • • • • • • • • • • • • • • •
AMS • • • • • • • • • • • •
EOA • • • • • • • • • • • • • • • • • • • • • • •
Geosyntec • • • • • • • • • • • • • • • • • • • • •
Integral • • • • • • • • • • •
Stone Creek • • • • • •
Northgate • • • • • • • •
LARRY WALKER ASSOCIATES PROPOSAL PREPARED FOR:

City of San Pablo

PCB TMDL Special Studies & Implementation (PCB 125) 4

3.1 LWA FIRM PROFILE
LWA is a Women-Owned Business Enterprise founded in 1979, with over four decades of experience providing specialized water resources management consulting services throughout California. Headquartered in Davis, with strategic regional offices in Berkeley, Santa Monica, Ventura, San Diego, Yreka, and Seattle, our team of more than 75 professionals delivers comprehensive solutions to over 350 public agencies across California.

For more than 45 years, LWA has been a partner, innovator, and industry leader, assisting public agencies in navigating and solving complex environmental and public policy challenges. Our expertise spans the full spectrum of water management services, including water resources planning, regulatory compliance, recycled water program development, stakeholder engagement, specialized technical studies, and water quality monitoring. LWA has been a statewide leader in all aspects of stormwater management and has a successful history of supporting municipal stormwater programs throughout the state, excelling at developing and delivering innovative, strategic, and technically sound solutions.

Stormwater Program Implementation. LWA has a successful history of supporting Phase I and Phase II municipalities throughout California with general regulatory oversight and administration as well as the development and implementation of key stormwater program elements, including public education and outreach, commercial and industrial support, planning and land development support, illicit discharge tracking and elimination, training, annual reporting, assessments of program effectiveness, and the development and implementation of pollutant specific issues such as pyrethroids, methylmercury, and trash. LWA's guidance and implementation tools reflect our staff's real-world practical experience.

Grant Administration: Our firm has successfully secured numerous competitive grants for municipal clients, including multiple Water Quality Improvement Fund applications. Our experience highlights a comprehensive understanding of grant requirements and evaluation criteria through previous successful applications across California. In addition, LWA has extensive knowledge of green infrastructure implementation in urban environments and a current understanding of the City of San Pablo's needs, working relationship with the Project Partners, and the scope of the PCBs TMDL Special Studies and Implementation Project.

Stormwater Permits & Regulatory Assistance. LWA has the demonstrated ability to evaluate a wide range of complex regulatory requirements for municipalities and develop pragmatic solutions. Our track record includes collaboration with personnel from the United States Environmental Protection Agency (USEPA), the State Water Resources Control Board (State Water Board), and/or various Regional Water Quality Control Boards to effect positive change in regulatory outcomes. Notably, we have significant experience tracking regulatory developments and preparing comments for agencies and organizations on important federal, state, and local rules, regulations, and policies affecting permit conditions.

3.2 INTEGRAL FIRM PROFILE
Integral is a national science and engineering firm delivering technical solutions to complex environmental, health, and natural resource challenges faced by our clients. We employ an unrelenting commitment to technical excellence, innovation, and collaboration to help our clients address yesterday's environmental impacts, meet today's demands, and create a more sustainable tomorrow.

Since our founding in 2002, we have operated on a platform of mutual respect with a demonstrated commitment to the well-being, diversity, and professional development of our staff and an equal commitment to strong partnerships with our clients and teaming partners. We are a company where people come to solve today's toughest environmental challenges through technical innovation and teamwork.

LARRY WALKER ASSOCIATES PROPOSAL PREPARED FOR:

City of San Pablo

PCB TMDL Special Studies & Implementation (PCB 125) 5

3.3 AMS FIRM PROFILE
AMS is a certified California small business enterprise that specializes in the design, conduct, and management of
environmental science and regulatory compliance
investigations and assessments. Since its inception in 1989, AMS has provided high-quality scientific support and project management to federal, state, and local government agencies and private industry. AMS specializes in designing, conducting, and managing projects that deal with complex biological and chemical phenomena, fate and effects studies, and ecological baseline and impact monitoring studies in aquatic environments.

AMS has an extensive history of supporting commercial entities, nonprofits, and resource management agencies in investigations related to risks posed by PCBs and other organic contaminants. Notable examples include the conduct of statistical analysis to support the Regional Monitoring Program Small Tributaries Loading Strategy in tailoring a stormwater monitoring program to detect trends in PCBs and other contaminants, trends monitoring in water, sediment, and biota conducted for the Central Coast Long-term Environmental Assessment Network, and over a decade of compliance monitoring conducted for ACCWP consistent with Pollutants of Concern provisions of the Municipal Regional Permit (MRP).

AMS has also supported multiple grant projects focused on PCBs, including a California Proposition 13 investigation of elevated concentrations of PCBs in the Ettie Street Pump Station watershed of Oakland, a Proposition 13 study of the potential linkage between sea otter mortality and presence of persistent organic pollutants in environmental media along the California central coast, and management of monitoring, quality assurance, and data management components of the USEPA Water Quality Improvement Fund grant project, Clean Watersheds for a Clean Bay.

3.4 EOA FIRM PROFILE
EOA is a privately owned environmental science and engineering consulting firm founded in 1985, with offices in Oakland and Sunnyvale. Specializing in municipal stormwater management and National Pollutant Discharge Elimination System (NPDES) permit compliance, EOA has built an unmatched solid reputation as a leader in the field. By combining regulatory expertise, public policy insight, and practical application of sound science, engineering, and program management, EOA is dedicated to helping clients protect, restore, and enhance water quality. With over 30 years of experience in municipal stormwater management, EOA has provided technical and regulatory services since the early 1990s, particularly for Bay Area municipalities. EOA's long-standing relationships with programs such as the SCVURPPP and SMCWPPP highlight its integral role in regional stormwater management efforts .

EOA specializes in reducing PCBs from urban runoff, a challenge faced by municipalities throughout the Bay Area. With extensive experience designing and implementing monitoring studies, EOA deeply understands PCB distribution across local watersheds. As the technical lead for SCVURPPP and SMCWPPP, EOA spearheads efforts to identify sources of PCBs, develop controls, and assess their effectiveness, helping municipalities comply with regulatory requirements. For over two decades, EOA has played a key role in regional efforts to address PCBs, contributing to projects led first by the Bay Area Stormwater Management Agencies Association and then by BAMSC. Through its leadership, EOA has assisted municipalities throughout the Bay Area in making significant progres s toward achieving the urban runoff wasteload allocations required by the PCBs TMDL for San Francisco Bay. With its unmatched technical knowledge and dedication to addressing the unique challenges of the Bay Area, EOA continues to be a trusted partner in municipal stormwater management and water quality protection.

LARRY WALKER ASSOCIATES PROPOSAL PREPARED FOR:

City of San Pablo

PCB TMDL Special Studies & Implementation (PCB 125) 6

3.5 STONE CREEK FIRM PROFILE
Stone Creek is a female-owned, small business consulting firm specializing in environmental permitting and compliance. Stone Creek was formed in 2020. Colleen Hunt, owner, brings over 25 years of experience in environmental regulatory compliance. Ms. Hunt formed Stone Creek to provide exceptional, client-driven services with the dedication to developing streamlined and cost-effective regulatory compliance strategies.

Stone Creek specializes in municipal stormwater management, including compliance with the State' s Phase II Permit. Specifically, Stone Creek supports multiple clients with Phase II Permit compliance. This includes development of stormwater management plans, development of TMDL implementation strategies, program effectiveness assessment, monitoring reports and annual reports. Stone Creek supports the BAMSC Phase II subcommittee with Colleen Hunt serving as a co-chair for the subcommittee and attends as a Phase II representative in the BAMSC Steering Committee.

3.6 GEOSYNTEC FIRM PROFILE
Geosyntec is a multidisciplinary engineering and consulting firm with 2,200 employees in more than 100 offices worldwide. We work with public and private sector clients to address complex problems involving the environment, natural resources, and civil infrastructure. Since 1983, Geosyntec has served municipalities and government agencies providing services in water resources, civil engineering and design, environmental consulting, geotechnical engineering, and construction management.

Geosyntec's engineers and scientists stand among the world's foremost experts in urban water management and are leading innovators in the design of best management practices that mitigate impacts to surface water quality, enhance water conservation
strategies, and contribute to municipal water supplies.

Our Oakland-based professionals assist CCCWP and
ACCWP in stormwater management planning and
program implementation tasks related to countywide
PCBs and mercury TMDL implementation and
reporting. Geosyntec projects have contributed to
setting industry standards and guidelines.

We recognize the importance of technical leadership and local expertise in the variety of discipline areas that this program will encompass. Our team members are actively engaged or have a history of performing countywide and regional projects directly related to the relevant scope of services and are appropriately trained and licensed.

3.7 NORTHGATE FIRM PROFILE
Founded in 1999, Northgate is a woman-owned, full-service environmental engineering firm headquartered in Oakland, CA.

Specializing in stormwater quality management and
environmental compliance support for government agencies, Northgate has a thorough understanding of stormwater issues affecting the related Bay Area' s policy frameworks and regulatory requirements. Through various as-needed environmental and stormwater services contracts, Northgate helps public agencies to understand applicable permit requi rements, identify adequate compliance pathways, and support stormwater projects with assessments , including special studies and surveys, site inspections, and water quality monitoring. The company 's experience includes performing hazardous material business inspections, drainage areas delineation, green stormwater infrastructure (GSI) planning, on-land visual trash assessments (OVTAs), PCBs load reduction assessments, TMDL monitoring, and MRP reporting.

LARRY WALKER ASSOCIATES PROPOSAL PREPARED FOR:

City of San Pablo

PCB TMDL Special Studies & Implementation (PCB 125) 7

3.8 PROJECT DESCRIPTIONS
The following project descriptions feature select efforts demonstrating our expertise in managing large- scale program implementation, regional monitoring plan development and implementation, reporting and data management, and grant administration. These examples highlight our collaborative approach, technical excellence, and consistently delivering exceptional results.

Project 1. MRP Compliance Support, Performed by LWA
Client Name Alameda Countywide Clean Water Program
Years of Service 2010-Present
Since 2010, LWA has led a team of consultants
providing support to the ACCWP in fulfilling the
requirements of the MRP, including
implementation of the PCBs and mercury
TMDLs. LWA's work efforts have also included
serving as the Program Manager, facilitating
permittee subcommittees and workgroups,
providing training for municipal staff, providing
regulatory support, developing a Stormwater
Resources Plan, and evaluating pollutants of
concern.
• Serve as the Program Manager since 2022,
facilitating the Management Committee,
serving as program liaison, and budgeting
and tracking contractor work efforts.
• Assisting the permittees with identifying,
characterizing, and managing PCBs and
mercury source areas and reporting load
reductions associated with these activities
annually.
• Supporting the POC monitoring program design and annual reporting required by MRP Provision C.8.f.
• Developed the ACCWP Stormwater Resource Plan, including the identification of potential GI projects throughout the county, which supported the ACCWP Permittees in developing their GI Plans.
• Revised the City of Dublin's typical green infrastructure details to serve as countywide details that were included in GI Plans.
• Facilitated the MRP 3 C.11/C.12 Workgroup that negotiated a programmatic approach for the MRP 3 permit term.
• Prepared MRP-required TMDL PCBs and Mercury Control Measure Plan and countywide RAA. • Coordinated training for the Industrial and Illicit Discharge, the New Development, and Municipal Maintenance Subcommittees, coordinating more than 25 workshops that trained more than 1,000 municipal agency staff within Alameda County. • Lead the New Development Subcommittee developing annual work plans, leading special projects, and facilitating subcommittee meetings.
• Developed training to support the Turner Court Green Infrastructure Grant Project . • Lead the Data Management-GIS subcommittee providing technical support on managing data and the development and use of Geographic Information System (GIS) tools to support MRP implementation.

RELEVANCE TO RFQ
 Provide Phase I Permit implementation
support
 Prepare and manage program budget
 Serve as the Program’s liaison with the
Regional Water Board and public
 Identify and characterize PCBs sources
areas and properties
 Identify and plan control programs and
practices
 Lead permittee subcommittees
 Coordinate with permittees and
subcommittees to develop work products
 Engage with permittee level and regional
stakeholder groups
LARRY WALKER ASSOCIATES PROPOSAL PREPARED FOR:

City of San Pablo

PCB TMDL Special Studies & Implementation (PCB 125) 8
Project 2. MRP Technical Services and Staff Augmentation, Performed by LWA Client Name Contra Costa Clean Water Program
Years of Service 2014-Present
LWA leads a team of consultants to provide
technical support services to the Contra Costa
Clean Water Program (CCCWP). LWA provides
guidance and recommendations to Program staff
on various technical studies and regulatory
projects required by the MRP and has supported
CCCWP during MRP 2.0 and 3.0 negotiations.

LWA has also provided on-call staffing support
during several recent staffing transitions. LWA staff
lead CCCWP committees and workgroups,
develop guidance, support permittees and
participate in BAMSC committees and technical
workgroups.

Work to date has included:
• Assisted with the MRP 2 and MRP 3
reissuance process, including developing
strategies for proposed programs, leading
MRP workgroups, developing comment letters,
testimonials, and presentations for negotiations
with the Regional Water Board.
• Provided CCCWP Permittees with guidance on the MRP 3.0 requirements, including planning, implementation, and reporting.
• Led the Municipal Operations Committee, Development Committee, AGOL Workgroup, Administrative, and Management Committee.
• Supported the interim Program Manager in ad-hoc workgroups. • Participated in regional collaborative efforts, such as the BAMSC Trash Subcommittee and BAMSC Cost Reporting Workgroup, to support MRP compliance. • Led the preparation and review of the Program's Annual Reports. • Provided briefings and updates to CCCWP committees, and relevant permittee and community stakeholder meetings, such as the Contra Costa Watersheds SWRP, Delta and Bay TMDLs, Asset Management, and emerging water quality issues.
• Assisted permittees with identifying, characterizing, and managing PCBs and mercury source areas and annually reporting load reductions associated with these activities. • Developed the Source Control Accounting for Reasonable Assurance Analysis (RAA) report. • Assisted with preparation and review of the CCCWP's Annual Reports, Urban Creeks Monitoring Reports (UCMR), Delta Methylmercury Control Study Reports, Stressor/Source Identification reporting, and other water quality monitoring plans and reports as requested. • Supported permittee implementation of source identification and control measures for mercury, methylmercury, and PCBs.
• Developed and provided training to municipal inspectors on C.4, C.5, and C.6 requirements. • Supported development of grant applications, including successful Prop 1 planning grant and implementation grants for CCCWP members.
• Provides grant administration and project support, including grant administration and development of the Contra Costa Watersheds Stormwater Resource Plan. • Provides support for implementing WQIF grants, including the Clean Watersheds for All and Watching Our Watersheds regional implementation projects.

RELEVANCE TO RFP
 Phase I Permit implementation
 Grant Administration and Project
Implementation
 Prepare and mange team budgets
 Prepare staff reports and briefings
 Lead report development and review
consultant reports
 Develop regional compliance and
negotiation strategies
 Prepare stakeholder briefings
 Identify and characterize PCBs sources
areas and properties
 Identify and plan control programs and
practices
 Engage with permittee level and regional
stakeholder groups
LARRY WALKER ASSOCIATES PROPOSAL PREPARED FOR:

City of San Pablo

PCB TMDL Special Studies & Implementation (PCB 125) 9
Project 3. Phase II Permit Compliance, Performed by LWA Client Name Marin Countywide Stormwater Pollution Prevention Program Years of Service 2013-Present
MCSTOPPP is a collaborative program that unites
the 11 cities and the County of Marin through a
Joint Exercise of Powers Agreement. LWA was
selected by MCSTOPPP in 2013 to provide
support for the Phase II Permit.

Work has involved developing tools and
approaches for all aspects of the permit, including
legal authority, public outreach and participation,
staff training, illicit discharge control, construction stormwater control, municipal operations, program
effectiveness assessments, annual reporting,
TMDL monitoring and status reporting, and trash
reduction planning. Recent work efforts have
focused on supporting MCSTOPPP prepare for the
reissuance of the Phase II Permit, building on
LWA's 12 years of experience with the program
and our statewide engagement with the California
Stormwater Quality Association's (CASQA) on the
reissuance process.

Work efforts have included:
• Provided regulatory assistance in negotiations with the Regional Water Board on the proposed merger into the regional Phase I Permit.
• Assisted with the evaluation of proposed control programs for the San Francisco Bay PCBs and mercury TMDLs and the negotiation of the proposed programs. • Conducted a geospatial analysis of pollutant loads reduced under the Phase II Permit 's Post Construction requirements and potential PCBs source areas within the watershed based on the SFEI Regional Watershed Spreadsheet Model.
• Conducted a geospatial analysis of potential PCBs and mercury source areas based upon the SFEI and ABAG land use data and drafted summary guidelines for conducting source area evaluations.
• Assisted with negotiations with the State Water Board on the proposed Phase II Permit reissuance, including drafting comment letters and summaries for MCSTOPPP members. • Developed an estimate of resource needs to implement the proposed new requirements including cost reporting, TMDL monitoring and implementation, asset management, post construction, and business inspections.
• Developed the Marin Countywide Storm WaterResource Plan, which identified and prioritiz ed projects to capture, treat and increase infiltration capacity, and/or use stormwater in ways that provide multiple benefits.
• Developed experiential learning activities on various stormwater requirements to municipal staff and proivided "train-the-trainer" sessions to allow program staff to deliver training. • Drafted an approach for TMDL Water Quality Monitoring requirements and obtained Regional Water Board acceptance for the appropand developing a QAPP and sampling plan for the pesticide toxicity TMDL.

RELEVANCE TO RFP
 Provide Phase II Permit Implementation
Support
 Prepare technical reports and briefings
 Conduct geospatial analyses to identify
pollutant source areas and calculate load
reductions
 Develop compliance strategies
 Evaluate and plan for pollutant load
reduction strategies
 Negotiate permit and TMDL
requirements
 Prepare stakeholder briefings
 Engage with permittee level and regional
stakeholder groups
LARRY WALKER ASSOCIATES PROPOSAL PREPARED FOR:

City of San Pablo

PCB TMDL Special Studies & Implementation (PCB 125) 10

4.0 STAFF STATEMENT OF QUALIFICATIONS OR RESUMES
The LWA Team brings together highly qualified professionals with extensive experience supporting the City and Regional Partners in implementing stormwater monitoring requirements , managing large-scale regional projects, and meeting grant requirements. Each team member has been strategically selected based on their specialized expertise, regional knowledge, and proven track records in implementing this work with the Regional Partners. The following biographies highlight our key staff's qualifications, demonstrating the depth and breadth of experience they bring to the City. Detailed resumes are provided in Appendix 1. Resumes.

LWA Team Biographies
Ms. Yin is a Senior Scientist with LWA and brings
over ten years of experience in water quality
management and regulatory compliance, with
particular expertise in stormwater program
implementation and trash reduction initiatives. At LWA, she provides both strategic planning and technical support services to LWA's stormwater clients, supported by a strong background in project management and data analysis. Ms. Yin is intimately familiar with the regional landscape of stormwater program management and NPDES permit implementation in the San Francisco Bay Area, having successfully supported CCCWP since 2020. She has demonstrated success in grant writing and program implementation across California, having secured funding and managed projects for various municipalities, including the Stormwater Grant Program Proposition 1 Implementation Grant Application for San Pablo. Ms. Yin currently supports the CCCWP as a Grant Project Manager and Project Management Team member for multiple grant projects.

Ms. Mathews is a Vice President and leads LWA's
stormwater market sector. She has 30 years of
experience developing and implementing water
quality compliance programs and has been engaged
in Bay Area stormwater programs since the early 1990s. She provides both strategic planning and technical support services to LWA's stormwater clients, leveraging her regulatory and program implementation expertise to assist stormwater programs in finding cost-effective compliance solutions.

Ms. Mathews works with Bay Area Phase I and Phase II, including the Alameda, Contra Costa, Napa, and Marin countywide programs as well as numerous individual public agencies, including the Ports of Oakland and San Francisco. Ms. Mathews has managed grant projects for various clients .

Dr. Smith brings a unique combination of scientific
expertise and grant-writing success to water
resource management projects. Since joining LWA
in 2023, she has secured multiple grant awards for
groundwater recharge initiatives, including successful applications for the Sierra Valley Groundwater Management District. Her background as a biogeochemist and climate change scientist, coupled with extensive experience in data analysis and project management, enables her to develop compelling technical narratives for funding proposals. As Assistant Project Manager for the San Joaquin County Region Storm Water Resource Plan, she has demonstrated skill in stakeholder engagement and government collaboration, key elements in successful grant applications. Dr. Smith's technical proficiency in statistical analysis, geospatial visualization, and environmental monitoring strengthens her ability to craft data-driven grant proposals that effectively communicate project impacts and outcomes.

Elizabeth Yin, LWA
Role: Project Manager & Task 4 Key Staff
Sandy Mathews, CPESC/QSD/P, LWA
Role: Task 2 Key Staff
Rebecca Smith, Ph.D., LWA
Role: Task 4 Key Staff
LARRY WALKER ASSOCIATES PROPOSAL PREPARED FOR:

City of San Pablo

PCB TMDL Special Studies & Implementation (PCB 125) 11
Mr. Sommers is the President of EOA and has over
25 years of consulting and project management
experience and specializes in all aspects of
stormwater management and assessment, including
pollutant control programs, monitoring strategies, and effectiveness assessments. Chris has managed many groundbreaking stormwater management projects at the county, regional, and statewide scales, including Regional Guidance on Conducting RAAs for the San Francisco Bay PCBs and Mercury TMDLs and statewide guidance on Trash Control Measure Implementation. These and other projects managed by Mr. Sommers have assisted cities, counties, and other California public agencies with identifying pollutant sources, identifying and implementing appropriate and cost-effective control measures approaches, and tracking progress towards numeric targets. Mr. Sommers has proven experience of effectively assisting public agencies in developing practical and cost-effective stormwater management strategies, optimizing control measure implementation, and maintaining compliance with NPDES permit requirements.

Dr. Sabin is a Managing Scientist at EOA and brings
20 years of experience in water quality protection
and restoration across California, specializing in
stormwater NPDES compliance, TMDL programs,
and monitoring. She assists San Francisco Bay Area municipal agencies with stormwater management and pollutant control initiatives, particularly for PCBs and mercury. Her expertise includes characterizing watershed pollutant concentrations, identifying source areas, and evaluating control measure effectiveness. Dr. Sabin authored key regional documents including the TMDL Implementation Plan for PCBs and Mercury for SCVURPPP and co-authored BASMAA's Source Control Load Reduction Accounting guidance. She led the PCBs in Storm Drain Infrastructure Caulk Project and supported implementation of building demolition pollution prevention programs. For six years, she helped manage the $7M EPA-funded Clean Watersheds for a Clean Bay project evaluating stormwater best management practices (BMPs). Previously, at Southern California Coastal Water Research Project, she researched atmospheric deposition impacts on water quality.

Ms. de Berry, a Managing Scientist at EOA, brings
over 25 years of consulting expertise in municipal
stormwater management, specializing in NPDES
permit compliance for San Francisco Bay Area
agencies. She conducts watershed investigations and environmental analyses focused on nonpoint pollution sources and water quality enhancement. Her core competencies include TMDL compliance and stormwater BMP selection, combining technical solutions with r egulatory knowledge. She designs monitoring plans to identify pollutants and stressors such as trash, PCBs, bacteria, and nutrients, while leading field studies using advanced techniques to calibrate pollutant fate models. Skilled at stakeholder coordination and presenting technical content to diverse audiences, she consistently meets schedule and budget commitments. Ms. de Berry currently serves as co-chair of the CASQA's Monitoring and Science Subcommittee.

Ms. Welsh is a Senior Scientist with Geosyntec and
has over a decade of experience in environmental
consulting. Her expertise lies in water resources,
water quality monitoring, and stormwater
management. She has coordinated countywide water quality monitoring programs, managed projects for PCBs and mercury TMDL implementation, and supported municipal stormwater compliance across diverse topics. She is also a Qualified Industrial Stormwater Practitioner (QISP) under the California Industrial General Permit. In addition, Ms. Welsh's seven years of climate change and remote sensing research have resulted in over 10 peer-reviewed publications, and she has recently worked on projects that integrate future climate projections into GSI design.

Chris Sommers, EOA
Role: Tasks 1.1 and 3 Key Staff
Lisa Sabin, Ph.D., EOA
Role: Tasks 1.1 and 3 Key Staff
Bonnie de Berry, CPSWQ, EOA
Role: Task 3 Key Staff
Lisa Welsh, Ph.D., QISP, Geosyntec
Role: Tasks 1.1 and 3 Key Staff
LARRY WALKER ASSOCIATES PROPOSAL PREPARED FOR:

City of San Pablo

PCB TMDL Special Studies & Implementation (PCB 125) 12
Ms. Austin has 35 years of experience in water
quality and stormwater management. She has in-
depth knowledge of NPDES permitting; municipal
stormwater program planning and operations; and
stormwater BMP selection, design, and maintenance. Ms. Austin has worked closely with both public and private clients on stormwater and industrial NPDES permit compliance-related tasks for much of her career. She is active in stormwater planning, providing technical assistance to various clients on regulatory issues, developing and evaluating conceptual BMP plans, and assessing the significance of potential water quality and hydromodification impacts (CEQA analysis) in California. Ms. Austin has assisted ACCWP and CCCWP with PCBs and mercury TMDL compliance for over a decade.

Ms. Hunt, Principal Compliance Specialist at Stone
Creek, has a 26-year career in water quality
regulations, including 18 years at the Regional
Water Board and eight years as a consultant. Ms.

Hunt specializes in municipal stormwater compliance, including compliance with the State 's Phase II Permit. Ms. Hunt supports Phase II permittees with compliance strategies, including the development of stormwater management plans, TMDL implementation, program effectiveness, and monitoring data analysis and reporting. Additionally, Ms. Hunt serves as the BAMSC Phase II Subcommittee Co-Chair and the CASQA Phase II Subcommittee Co-Chair.

Mr. Salop, a Principal Scientist at AMS, brings
extensive experience managing complex water
quality monitoring programs, currently serving as
Field Program Manager for the Regional Monitoring
Program's (RMP) Status and Trends component in the San Francisco Estuary, overseeing field sampling design and implementation for numerous Bay Area NPDES dischargers. His expertise includes managing NPDES monitoring programs for the Alameda Countywide Clean Water Program and Solano Stormwater Alliance, previously serving as Project Manager for the $2M+ EPA Clean Watersheds for a Clean Bay grant project, and Assistant Project Manager for the Clean Estuary Partnership supporting TMDL development for San Francisco Bay-Delta. Mr. Salop has developed numerous Quality Assurance Project Plans and served as QA officer for various local, regional, state and federal grant projects, including investigations of Areas of Special Biological Significance, fecal pathogen pollution monitoring, PCBs loading assessments, and EPA Ocean Disposal Site evaluations.

Mr. Kocher offers over 34 years of experience
implementing NPDES stormwater regulatory
compliance monitoring programs, with expertise in
stormwater BMP studies, PCBs source area
investigations, and sediment dredge materials studies for municipal, industrial, state, and federal clients throughout the San Francisco Bay Area. Since 2011, Mr. Kocher has provided stormwater monitoring services for CCCWP, creating quality assurance project plans and successfully implementing stormwater characterization studies under challenging environmental conditions. His technical capabilities include comprehensive study design, instrumentation deployment, telemetry system management, automated flow monitoring, data validation and interpretation, and preparation of technical documents, including sampling and analysis plans, evaluation plans, and monitoring reports. Mr. Kocher also brings extensive scientific oceanographic field experience aboard research vessels, conducting water current meter studies, sediment vibracoring, mussel bioaccumulation studies, dye-tracer studies, and acoustic surveys for diverse clients locally and internationally.

Lisa Austin, P.E., Geosyntec
Role: Tasks 1.1 and 3 Key Staff
Colleen Hunt, CPMSM, Stone Creek
Role: Task 2 Key Staff
Paul Salop, AMS
Role: Task 3 Key Staff
Christian Kocher, Integral
Role: Field Team Lead
LARRY WALKER ASSOCIATES PROPOSAL PREPARED FOR:

City of San Pablo

PCB TMDL Special Studies & Implementation (PCB 125) 13
Mr. Lewis is a Senior Scientist at AMS with over 17
years of professional experience in stormwater and
surface water quality monitoring across California,
serving federal, state, and local agencies, including
USACE, Caltrans, and municipalities. His expertise encompasses Phase II Permit projects, water quality studies, PCB and mercury investigations in the San Francisco Bay Area, and BMP efficacy monitoring.

Mr. Lewis is skilled in offshore sediment sampling, hydrologic equipment installation, remote monitoring station operation, stream rating equipment deployment, and data management for pollutants of concern.

His technical capabilities include stormwater and sediment sample collection, field quality control, dissolved constituent analysis, and QA/QC oversight for dredge materials projects, compleme nted by GIS mapping skills and desktop-based site assessment for permitting and site access.

Mr. Rieke is a Principal at Northgate and has 30
years of experience and leading Northgate's
stormwater management practice. He provides
technical expertise and project management
overseeing assessment studies, BMP inspections, discharge monitoring and reporting. He has been the project manager, design engineer and subject matter expert for numerous stormwater projects including the City of Oakland's Urban Green Plan, storm drainage and pipe repairs, streetscape improvement Stormwater Pollution Prevention Plan (SWPPP) reviews; the Ardenwood Creek flood control improvement; the Port of San Francisco In House Stormwater Regulatory Specialist; the State Park's Yosemite Slough Wetlands Restoration; and City of Berkeley GIS Support for GSI planning. He also provided senior-level review for Northgate's TMDL monitoring and reporting services to the City of Torrance. He has been the remediation engineer and Qualified SWPPP Developer (QSD) that oversaw the investigation and removal of PCB-impacted soil supporting stormwater compliance during the Palo Alto Medical Foundation hospital construction in San Carlos. In his role as a quality assurance expert, he assisted the Lawrence Berkeley National Laboratory Environmental Service Group with revision of it's Import Material Testing Work Plan and review of its Quality Assurance Program Plan (QAPP) for the investigation of contaminant releases. He currently manages the City As-Needed On-Call Hydrology and Stormwater Engineering contract where he oversees the Business Stormwater Inspection Program, as well as the Port of Oakland's On-Call Stormwater Compliance and Planning contract.

Mr. Torres is a Senior Scientist at Northgate and
has 24 years of experience in the fields of
stormwater compliance, hazardous materials
business plans and assessment, water and
sediment quality, Phase I environmental site assessments (ESAs), environmental impact reports (EIRs) and CEQA compliance, ecological risk assessments (ERAs), toxicology, and biology. He has supported municipalities with a variety of inspections, analyses, and reporting requirements to comply with the MRP, Phase II Permit, and IGP. Mr. Torres has conducted five years of OVTA years per the MRP and performed multiple Phase I ESAs in accordance with ASTM and USEPA Standards. He has assessed environmental impacts and identified mitigation and measures for EIRs. Mr. Torres is familiar with environmental regulations and guidance for stormwater and hazardous materials permit compliance, CEQA, NEPA, risk assessment, and site investigation (CERCLA, RCRA).

Axel Rieke, P.E., QSD/P, Northgate
Role: Field Team Lead
Kevin Lewis, CESSWI, QSP, Integral
Role: Field Team Lead
Kevin Torres, Northgate
Role: Field Team Lead
LARRY WALKER ASSOCIATES PROPOSAL PREPARED FOR:

City of San Pablo

PCB TMDL Special Studies & Implementation (PCB 125) 14

5.0 PROJECT MANAGEMENT
The LWA Team's overall approach to project management and successfully providing project administration, grant management, and technical support is based on 1) providing the necessary communication mechanisms and check-in points to ensure that the Project Team is meeting expectations and needs; 2) completing tasks on schedule; 3) leveraging existing collaborative mechanisms to streamline approaches, and 4) completing work within the agreed budget. The LWA Team has available and qualified staff as well as management efficiency and flexibility to meet the needs of the City and the Regional Partners. The basic components of the LWA Team's approach to managing and completing the Project include the following:

Project Management – The LWA Project Manager (PM), Elizabeth Yin, will provide overall project management of all four tasks identified in the Scope of Work and will work closely with assigned task leads to ensure that the work meets project outputs and outcomes. Task leads are assigned based on their extensive expertise and leadership within each Task's Scope of Work. Given the regional and distributed nature of the Scope of Work, Task leads will develop work scopes and budgets alongside the Regional Partners and report to the LWA PM. Task leads will maintain regular consultations with the LWA PM on project approaches, risks, and solutions while offering direct communication channels to key stakeholders. Their role includes quality assurance review of deliverables and communication materials, as well as contributing additional technical expertise and institutional knowledge to support project success.

Schedule & Budget Management – Ms. Yin will maintain a master schedule with the due dates and budgets for all grant-funded tasks in the Project. The LWA PM will promptly notify the City PM of any changes in the project progress. Brief progress reports and budget summaries will be submitted with invoices to assist the City PM in understanding work completed and budget status. With this streamlined approach to project management, the LWA PM can ensure that the Project remains in compliance with the USEPA Grant Agreement and Workplan.

Coordination & Communication – The LWA PM will serve as the primary point of contact for the duration of the Project. The LWA PM will maintain close contact with the City, Regional Partners, and the LWA Team to ensure that all parties have a clear understanding of the project tasks, and that work is focused on achieving project objectives. With the LWA PM as the primary point of contact for the City, the LWA PM will work to identify key lines of communication with the Regional Partners and Project Management Team (PMT). The LWA PM will arrange project meetings with the City, the Regional Partners, or the Project Management Team, at critical check-in points as needed. The LWA PM will coordinate with the LWA Team to provide timely progress reports as needed to fulfill elements of the USEPA Grant Agreement.

Administrative – The LWA PM will be responsible for administrative tasks associated with the Project, including task orders, scopes, and contracts. Ms. Yin will also maintain budgets for services provided as in-kind matches in order to monitor progress and prepare reports to meet the requirements of the USEPA Grant Agreement.

6.0 PROJECT APPROACH
Task 1.0 Regional PCB Monitoring Program
This task will support ongoing monitoring to address five priority PCBs management information needs identified in MRP Provision C.8.f. (i.e., source identification, contributions to Bay impairment, management action effectiveness, loads and status, and trends).

Task 1.1 Small Tributary Monitoring Stations Monitoring The LWA Team, in collaboration with the countywide stormwater programs and the RMP, will locate and install four fixed monitoring stations (one each in Alameda, Contra Costa, San Mateo, and Santa Clara counties). The stations will support regional monitoring and modeling conducted by the RMP and countywide programs. The LWA Team will coordinate purchasing equipment, permitting, and installation of each station in collaboration with the countywide programs and the RMP. The countywide programs will be responsible for funding the installation of the physical components of the monitoring stations (e.g., LARRY WALKER ASSOCIATES PROPOSAL PREPARED FOR:

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pad, enclosure, security, power supply, communications, and gages) through grant matching funds. The RMP will purchase instrumentation and sensors for each station. The timing of installation is contingent on coordination with the stormwater programs and the RMP's available funding. At least one of the stations will be installed by the end of the project's second year, and the remaining stations will be installed in subsequent years.

Task 1.2 Alternative Source Property Investigation
The LWA Team, in collaboration with the PMT, will develop and pilot test alternative source property investigation tools, including the use of canine detection dogs and passive samplers to rapidly screen areas for sources of PCBs and elevated PCBs loading. The detection dog pilot study will be conducted in collaboration with FieldLab LLC (or a suitable alternative) and will assess the feasibility of working with a detection dog to screen old industrial areas for moderate/high PCBs in combination with verifi cation monitoring using traditional methods. FieldLab LLC has proven its PCBs detection dog capabilities in Washington State. In this pilot study, the LWA Team will support the FieldLab LLC team to survey old industrial areas in one or several Bay Area locations with moderate or high concentrations of PCBs, and in one or more locations that are not yet known to have elevated PCBs. The pilot study will combine field deployment of the detection dog with the collection and PCBs analysis of sediment samples to verify positive (or negative) source identification. In addition, the LWA Team will implement a pilot study to investigate water monitoring screening tools to identify high PCBs source areas rapidly and economically.

The pilot study will test different passive samplers and deployment techniques during storm events to assess their potential to differentiate between catchments associated with higher and lower loadings of PCBs. The study area will focus on an approximately 77-acre zone in West Oakland that generated a composite sediment sample of over 50 µg/kg dw total PCBs in 2024 sampling and will incorporate a rigorous QA/QC program to help ensure the reliability of the method.

Deliverables: Monitoring Plans for the Detection Dog and Rapid Screening Tool pilot studies and amended overall project Quality Assurance Project Plan (QAPP, see Task 3.2); conducting the pilot studies; and technical reports that comprehensively assess the alternative monitoring methods studied and provide guidance on how the Project Partners could use these methods for identifying source areas.

Task 2.0 Phase II Permittee PCBs Program Development and Monitoring San Francisco Bay Area Phase II permittees will be required to implement PCBs control programs when the Phase II Permit is reissued. Control programs would be scaled based on similar programs required of the Phase I permittees under the MRP to reduce PCBs loads to the San Francisco Bay. The LWA Team's approach incorporates flexibility in the planned work tasks given that the final PCBs control programs will not be established until the permit is reissued. The team members will leverage their knowledge of the MRP PCBs control program and experience with the Phase II Permit and the participating permittees. At the outset of each task, the LWA Team will meet with the permittees to establish a workplan for the task and identify any changes to the general task scope based on regulatory requirements and permittee needs. Tasks are scheduled to initiate efforts on programs most likely to be in the reissued permit earlier in the project. Early tasks will establish the foundation for implementation of the control progr ams at the local level by providing guidance, planning, and mapping needed to identify potential PCBs source areas and properties.

Task 2.1 Green Infrastructure Planning
Permittees will be required to implement green infrastructure (GI) that incorporates low -impact development drainage design. GI Plans will serve as an implementation guide and reporting tool for the shift from traditional storm drain infrastructure toward GI. The LWA Team will reference GI Plans and templates developed by MRP permittees and work with the Phase II permittees to customize a GI Plan template that reflects community goals and permit requirements. The schedule allows ample time for internal review of the template.

Deliverables: GI Plan template; training materials for municipal staff; outreach for municipal officials.

Task 2.2 PCB-Containing Building Materials and Waste Control Program PCBs-containing building materials are a potentially significant source of PCBs that can be abated through controls implemented when buildings containing these materials are demolished. MRP LARRY WALKER ASSOCIATES PROPOSAL PREPARED FOR:

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permittees created protocols to identify buildings likely to have PCBs containing materials and require project proponents to assess buildings and remove the PCBs containing materials prior to demolition. The LWA Team will adapt the protocols and procedures developed by MRP permittees for building demolition and develop guidance for enhancing construction site control programs to account for recommended best management practices and inspection procedures. The work plan for this task is structured to allow ample time for permittees to review and internally vet the proposed protocols with building officials.

Deliverables: PCBs Demolition Program documents; model ordinance and staff report; training materials for municipal staff; outreach for municipal officials.

Task 2.3 Identification of PCB Source Properties and Areas The reissued Phase II Permit will require permittees to identify and investigate land areas likely to contribute PCBs to municipal storm drainage systems. The process involves a multi -step, iterative process that can vary based on watershed and data availability. Some of the par ticipating permittees conducted preliminary geospatial evaluations of potential source areas while others need to conduct similar preliminary evaluations. The LWA Team will coordinate with permittees to gather and compile existing geospatial data and develop the source area and property investigation protocols based upon similar protocols developed by MRP permittees and foundational work initiated by MCSTOPPP, NCSPPP and Benica. The LWA Team will conduct a geospatial analysis to identify priority areas for desktop evaluation. After consulting with permittees, the LWA Team will conduct the desktop evaluations, which will identify and prioritize source areas for field evaluation. Once priority areas are identified, the LWA Team will amend the overall project QAPP (see Task 3.2), which will be submitted to EPA for approval prior to the start of monitoring. The LWA Team will conduct a pilot evaluation of prioritized source areas, which will include collecting and compositing street sediment from the public rights of way (ROW) to assess areawide PCBs concentrations. The pilot effort will include up to 10 source areas distributed among the participating permittees. Final site selection will be coordinated with and approved by the permittees. Following evaluation of the sediment sampling results, recommendations for the next steps will be developed. Findings from the evaluation will be documented in a summary report.

Deliverables: Source area and property investigation protocols; preliminary report of the prioritized areas and results of the desktop analysis; amended project QAPP; monitoring of 10 prioritized source areas; final summary report of the investigation results with exhibits and geospatial data layers.

Task 2.4 Controlling PCBs from Bridges and Overpasses
Like buildings, bridges potentially have PCBs-containing materials in expansion joints. In 2024, Caltrans developed a Standard Operating Procedure (SOP) for evaluating bridges and removing materials during roadway replacement or major repairs. The LWA Team will develop an inventory of bridges that includes bridge ownership, and a replacement/repair schedule based on the Caltrans National Bridge Inventory.

The LWA Team will develop guidelines for permittees to implement the Caltrans SOP when pl anning and conducting bridge roadway replacement or major repair.

Deliverables: Bridge inventories for participating permittees and instructions for accessing the NBI database; guidelines to implement the Caltrans SOP.

Task 2.5 Mercury Collection and Recycling Program
The reissued Phase II Permit will require permittees to promote and facilitate programs that collect and recycle mercury-containing consumer products and equipment. Recycling programs are typically handled by county health departments. The LWA Team will evaluate existing recycling programs , including outreach materials and reporting systems. The LWA team will develop a strategy to improve outreach and develop a tool to track the collected amount of mercury. A final report will summarize guidance and information to facilitate the maintenance of the program and ongoing tracking.

Deliverable: Guidance document for tracking and ongoing maintenance of the program.

Task 2.6 PCB Risk Reduction Program
The reissued Phase II Permit will require permittees to conduct or participate in an ongoing risk reduction program to address the public health impacts of PCBs in San Francisco Bay. The LWA team will research the existing programs, identify the at-risk populations within the Phase II jurisdictions, and work with LARRY WALKER ASSOCIATES PROPOSAL PREPARED FOR:

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permittees to develop a strategy and guidance to implement a program that is focused on people and communities most likely to consume San Francisco Bay-caught fish.

Deliverable: Fish risk reduction program strategy and guidance.

Task 2.7 TMDL Water Quality Monitoring
Discussions with Regional Water Board staff did not reach a conclusion regarding monitoring requirements for the PCBs TMDL. This scope is based on the last meeting in which permittees proposed monitoring focused on identifying source areas and properties. Pilot scale monitoring of source areas is part of Task 2.3. This task proposes pilot scale monitoring of individual potential source properties. Work on this task is proposed to start after the anticipated adoption of the permit and the LWA Team will work with permittees to rescope this work effort if the adopted permit requires a different monitoring approach.

Under Task 2.3, the next steps will be identified for the prioritized source areas, which is expected to recommend an investigation of potential source properties. The LWA Team will amend the overall project QAPP (see Task 3), which will be submitted to EPA for approval prior to the start of monitoring efforts.

The LWA Team will conduct a pilot source property investigation, which will include an inspection following the procedure developed in Task 2.3 and the collection of sediment from the property to assess PCBs concentrations. The pilot effort will include inspection and sampling of up to 10 source properties, distributed among the participating permittees. Final property selection will be coordinated with and approved by the permittees. Summary reports of the inspections and sampling results will be developed for each jurisdiction. These reports can form the basis of source property referrals to th e Regional Water Board.

Deliverables: Amended project QAPP; monitoring of 10 prioritized source properties; final summary report of the investigations.

Task 2.8 Regional Load Reduction Accounting Framework
Permittees will be required to develop a methodology to account for the PCBs loads reduced through the implementation of control measures. The framework will encompass all the control measures required by the Phase II Permit. Following Regional Water Board staff guidance, the framework will be developed using the assessment methodologies described and cited in the MRP Fact Sheet. The methods cited were based on the BASMAA Source Control Load Reduction Accounting for RAA s. The LWA Team will use these approaches to customize a framework for the Phase II Permit's TMDL requirements and create a tracking tool (e.g., spreadsheet) to calculate actual and predicted load reductions by each permittee.

Guidance will be developed to provide instructions on the tool's use and inform permittees what data they will need to track to demonstrate cumulative PCBs load reduced from each control measure implemented.

Deliverables: Load reduction accounting framework and tracking tool.

Task 3.0 Phase I Permittee PCBs Monitoring, Mapping, and Control Measure Planning To assist local public agencies in identifying areas that contribute high, moderate, and low levels of PCBs to the Bay via stormwater runoff, the MRP countywide programs have developed GIS maps and databases that identify the types of land areas, facilities, and activities that may generate PCBs. The MRP countywide programs have also developed Old Industrial Area Control Measure Plans (OICMPs) designed to control PCBs in stormwater from areas containing known or suspected sources or areas with evidence of moderate to high PCBs. This task will conduct additional monitoring, mapping, and control measure planning in support of OICMP implementation by MRP permittees.

Task 3.1 Workplan
The LWA Team will develop countywide program-specific workplans in collaboration with each program (i.e., ACCWP, CCCWP, SMCWPPP, SCVURPPP, and SSA). In project year 1, the LWA Team will develop a general workplan that reflects the county-specific priorities that will be completed over the duration of the Project. In addition, each year of the grant project, the LWA Team will prepare county - specific annual budgets to provide details on the scope of work (SOW) to be conducted by the LWA Team and the countywide programs in that project year. The general workplan and annual budgets will detail the tasks to be conducted by the LWA Team and the countywide programs within the allocated LARRY WALKER ASSOCIATES PROPOSAL PREPARED FOR:

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grant budget and matching funds for Task 3. The SOW included in the general workplans, and the annual budgets will be consistent with the tasks described in Tasks 3.2 through 3.6, unless approved by the PMT and the EPA Grant Manager.

Deliverables: One general workplan for each countywide program (5 total) and an annual budget for each countywide program each year (5 total each year).

Task 3.2 Monitoring in Support of MRP Compliance (RFP Tasks 3.1, 3.2 and 3.3) Monitoring tasks in the general workplans and annual budgets will include one or more of the following, as selected by each countywide program:
• Large-scale public ROW and private property sampling. Using sediment or water monitoring, investigate and identify sources of PCBs in catchments with old industrial land uses, or catchments where previous monitoring data have found elevated PCBs, but the source(s) have not yet been identified (i.e., MRP Provision C.12.b sampling). • Low-priority catchment verification water sampling. Implement watershed or catchment-scale stormwater monitoring at sites where previous data have found low PCBs, and/or where PCBs sources are not suspected to further verify the watershed or catchment is not producing moderate or high levels of PCBs (i.e., MRP Provisions C.8.f and C.12.b sampling). • Load reduction verification. Develop and implement a study to evaluate the impacts of PCBs controls on load reductions at the watershed, catchment, or property-specific scale in support of county-specific OICMP implementation (i.e., supports MRP Provision C.12.a accounting methodology development, and C.8.f / C.12.c sampling).

The monitoring priorities for each countywide stormwater program are provided in Table 2.

The LWA Team will also develop an overall project QAPP. The QAPP will be submitted to EPA for approval prior to the start of field monitoring efforts. The overall project QAPP will be amended as needed to address additional monitoring efforts.

Deliverables: County-specific monitoring plans documented in the annual budget updates (Task 3.1); overall project QAPP and QAPP amendments as needed; conducting the monitoring studies; CEDEN compatible monitoring data submittals for data collected during the previous Water Year and monitoring status updates reported in each countywide program's annual UCMR; and status updates and results on Task 3.2 implementation during the previous fiscal year reported in each countywide program's Annual Report. Documentation of the Task 3.2 project activities and the outcomes achieved over the entire project period will be reported in the Final Project Report (Task 4).

Task 3.3 Mapping in Support of MRP Compliance (RFP Task 3.4) Mapping tasks may include correcting and improving the existing GIS maps and databases to better quantify loads reduced through control measure implementation. Specific mapping tasks, to be selected by the countywide programs, may include: 1) Map direct discharge properties; 2) Map non-MS4 permitted land areas; 3) Map structural and source controls; 4) Map storm drain catchments; and 5) Revisions/corrections to land use category base maps. The mapping priorities for each countywide program are provided in Table 2.

Deliverables: Improved GIS maps and databases. Documentation of Task 3.3 project activities and the outcomes achieved over the entire project period will be reported in the Final Project Report (Task 4).

Task 3.4 Implement Programs to Control PCBs Discharges from Private Properties (RFP Task 3.5) The LWA Team will implement the source area control programs described in the countywide Old Industrial Control Measure Plans. These programs identify parcels that disproportionately contribute moderately elevated PCBs concentrations to the MS4 through onsite inspections and monitoring and address the moderate source through voluntary actions by the responsible party or enforcement actions taken by a permittee. Moderate parcels to be inspected will be identified using existing data and through the source property monitoring conducted in Task 3.2. This task will include: 1) desktop evaluation to identify properties for inspections/monitoring; 2) conduct inspections and monitoring to identify properties LARRY WALKER ASSOCIATES PROPOSAL PREPARED FOR:

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contributing elevated PCBs to MS4s; 3) property-specific control measure assessments to identify potential on-site controls; 4) follow-up with property owners to document implementation of on-site controls to prevent release of PCBs to MS4s; and 5) reporting.

Deliverables: CEDEN compatible monitoring data submittals for all data collected during the previous Water Year and monitoring status updates reported in each countywide program's UCMR; reporting on Task 3.4 implementation during the previous fiscal year in each countywide program' s Annual Report.

Documentation of Task 3.4 project activities and the outcomes achieved over the entire project period will be reported in the Final Project Report (Task 4).

Table 2. Countywide Stormwater Program Priorities1
Task Description ACCWP CCCWP SCVURPPP SMCWPPP SSA

3.1 Workplan Development H H H H H

3.2 Monitoring in Support of MRP Compliance
Source property investigation H H H H H
Low-priority catchment verification water sampling M M M M M Load reduction verification monitoring L L H H L

3.3 Mapping
Map direct discharge properties L L M H H
Map non-MS4 permitted land areas L L L L H
Map structural and source controls M M M M H
Map storm drain catchments L H L L H
Revisions/corrections to land use category base map L H L L H

3.4 Implement Programs to Control PCBs Discharges from
Private Properties H H H H L

3.5 Develop and Implement Programs to Control PCBs
Discharges Through MS4 Operations and
Maintenance Practices

H H H M M

3.6 Plan and Design Stormwater Treatment Systems H H L L M 1 H = High Priority; M = Medium Priority; L = Low Priority.

Task 3.5 Develop and Implement Programs to Control PCBs Discharges through MS4 Operations and Maintenance Practices (RFP Task 3.6)
The LWA Team will develop and assist with the implementation of county-specific programs to use enhanced operation and maintenance practices to control PCBs in storm drain system infrastructure.

Potential methods include street sweeping; cleaning of locations in the storm drain system where sediments with PCBs accumulate (e.g., inlets and targeted pump station sumps); and street or storm drain flushing, collection of the wastewater and sediment, and routing to the sanitary sewer for treatment.

Deliverables: County-specific programs identified in the annual budgets (Task 3.1), potential implementation of the action items included in the programs; CEDEN compatible monitoring data submittals for any data collected during the previous Water Year and status updates reported in each countywide program's annual UCMR; and reporting on Task 3.5 implementation during the previous fiscal year in each countywide program's Annual Report. Documentation of Task 3.5 project activities and the outcomes achieved over the entire project period will be reported in the Final Project Report (Task 4).

Task 3.6 Plan and Design Stormwater Retrofit Treatment Systems (RFP Task 3.7) Retrofit projects provide treatment control for existing developed areas without redeveloping the tributary area. Treatment controls may include green stormwater infrastructure (GSI) or non -GSI treatment. The LWA Team will develop conceptual designs for stormwater treatment systems that may be identified by the countywide stormwater programs as potential projects to address old industrial or moderate PCBs areas.

Deliverables: 10% concept designs for PCBs treatment measures identified by the countywide stormwater programs and summary reports documenting justification for concept design at the chosen location(s), results of preliminary investigation, identification of treatment type and sizing, preliminary schematics, and high-level cost estimate, as budget allows. Documentation of Task 3.6 project activities LARRY WALKER ASSOCIATES PROPOSAL PREPARED FOR:

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and the outcomes achieved over the entire project period will be reported in the Final Project Report (Task 4).

Task 4.0 Program Administration and Management
The LWA Team will perform all activities associated with Task 4 throughout the project period. LWA has prepared a team of individuals who have 30 years of experience leading Bay Area stormwater programs and supporting stormwater programs across California. Key LWA staff assigned to this project currently manage grant projects for CCCWP and support the implementation and management of grant projects for Bay Area stormwater permittees and other water sectors. The LWA Team draws from experience in both countywide stormwater program and grant management to integrate best practices in program coordination, budgeting, and scheduling.

In addition to sound, effective, technical work, effective execution of the PCBs TMDL WQIF Grant requires strong project management, transparent communication, and full compliance with grant requirements. Task 4 is designed to ensure that the LWA Team works efficiently, meets the requirements of the Grant Agreement, and remains responsive to and collaborative with stakeholder priorities through its duration. A robust project management framework will be implemented to maintain clear scheduling, milestone tracking, and internal coordination across multiple technical tasks. The LWA Team will have project team check-ins to ensure compliance with WQIF grant requirements while also leveraging existing BAMSC and regional meetings to streamline task implementation, document production, and regional collaboration.

The LWA Team PM will coordinate and serve as the primary point of contact for BAMSC stakeholders (including the PMT), permittees and countywide programs throughout the duration of the project period.

The Team has well-established relationships with all the participating partners and will draw from decades of experience to ensure effective program coordination. Key communication mechanisms and check -in points with BAMSC agencies will leverage existing regular meetings to streamline communication throughout the project period. As needed, the LWA Team will meet to review the scope, budget, and schedule, facilitate feedback and coordination among collaborators, and document progress on a monthly or quarterly basis.

The LWA Team has a strong track record of on-time and on-budget project delivery. The PM will manage the in-kind match by developing a match management tracking spreadsheet, compiling a quarterly budget, and completing a quarterly In-Kind Match Summary Report. The In-Kind Match Summary Report will include all match documents from each partner agency to be provided to San Pablo for auditing purposes. To ensure that tasks and grant requirements are achieved, the PM will maintain a master schedule with timelines, due dates, and budgets for tasks under the Project, perform monthly invoice reconciliation, and complete monthly progress reports to be submitted with invoices.

Finally, the LWA Team will support San Pablo with all aspects of grant management, reporting and invoicing, including the development of all content for quarterly progress reports, the annual Federal Financial Report and Minority Business Enterprise/Women Business Enterprise (FFR and MBE/WBE )
reports to the EPA for review and submittal by San Pablo. The LWA Team's proven management approach will ensure that the Project remains compliant with the Grant Agreement requirements, including maintaining clear records of expenditures, task completion, and project challenges, allowing for transparent project administration. At the end of the project period, the LWA Team will draft the Final Project Report in accordance with the Notice of Award, including details of project activities and achievements over the project period.

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7.0 SCHEDULE OF WORK
The LWA Team has developed a project schedule to meet both the City and the USEPA Grant Agreement timeline requirements, with work commencing on June 1, 2025, and concluding by December 30, 2029. Our comprehensive schedule reflects a measured approach that accounts for seasonal considerations essential for field work, appropriate sequencing of monitoring activities, and adequate time for stakeholder engagement and review processes. This proposed timeline demonstrates our ability to meet all project deadlines efficiently, with specific milestones and regular communication for each deliverable aspect of the Project aligned with existing regional stakeholder processes. We recognize the importance of regular communication, and our approach emphasizes efficient coordination among team members, the City, the USEPA Project Officer, and the Regional Partners. Critical path elements have been carefully mapped to ensure that the Project maintains momentum while allowing for thorough review at each stage of work.

Table 3. Schedule of Work

8.0 COST PROPOSAL
The LWA Team's approach emphasizes cost efficiency while delivering comprehensive, high- quality service that meets all scope of work elements outlined in the RFP and the EPA WQIF Grant Application. We have carefully structured our budget to align with the EPA Grant Application Task Budget and estimated cost identified in the RFP. Resources for each task have been appropriately allocated based on Regional Partner allocations and expected match contributions. The LWA Team developed the cost proposal to include 1: Task-by-task cost estimates with associated team member allocation; comprehensive cost for all tasks and sub- tasks as specified in Section B, Item #3; itemization of project expenses and sub-consultant fees, including our proposed markup. We confirm our readiness to submit certified payroll records as required. Our T eam is committed to delivering exceptional value within the proposed budget framework while maintaining flexibility to address evolving project needs.

1 Individual staff allocations and rates for each team can be made available upon request. For the cost proposal, a five-year average of each staff rate (detailed in Section 8.1) was used to estimate the level of effort for the duration of the project.

Deliverable Development
Deliverable Due Date
Meetings/Communication
Permittee Comment/Response Period

LARRY WALKER ASSOCIATES PROPOSAL PREPARED FOR:

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PCB TMDL Special Studies & Implementation (PCB 125) 22 Table 4. Cost Proposal1,2

1. The distribution of Program-specific budget allocations within Task 3 across the various sub-tasks is preliminary; the final budget distribution across Task 3 sub-tasks for each stormwater program will be determined in consultation with Program and Permittee Staff as part of the workplan development, and will likely be iterative over the course of the Project. The program-specific annual budget workplans will define the budget allocation across the various Task 3 sub-tasks during each year of the grant.

2. Individual staff allocations and rates for each team can be made available upon request. For the cost proposal, a five-year average of each staff rate (detailed in Section 8.1) was used to estimate the level of effort for the duration of the project. 5% 5%
Labor Cost ODC Markup
Subconsultant
Markup

1.0 Regional PCB Monitoring Program 0 57 318 0 867 464 0 1,706 368,474$ $ 284,002 $ 14,200 $ 33,334 700,009$

1.1 Four (4) Small Tributary Monitoring Stations Monitoring 0 57 48 0 747.2 16 0 868 179,362$ $ 192,000 $ 9,600 $ 19,048 400,010$

1.2 Alternative Source Property Investigation 0 0 270 0 120 448 0 838 189,112$ $ 92,002 $ 4,600 $ 14,286 300,000$

2.0 Phase II Permittee PCBs Program Development and Monitoring 2834 152 0 711 0 570 100 4,367 1,062,671$ $ 17,844 $ 892 $ 20,456 1,101,863$

2.1 Green Infrastructure Planning 46 0 0 143 0 0 0 189 55,594$ $ - $ - $ 2,088 57,682$

2.2 PCB-Containing Building Materials and Waste Control Program 194 0 0 16 0 0 0 210 46,564$ $ - $ - $ 234 46,798$

2.3 Identification of PCB Source Properties and Areas 1781 28 0 98 0 276 0 2,183 515,810$ $ 8,372 $ 419 $ 5,380 529,981$

2.4 Controlling PCBs from Bridges and Overpasses 4 0 0 78 0 0 0 82 19,493$ $ - $ - $ 902 20,395$

2.5 Mercury Collection and Recycling Program 4 0 0 164 0 0 0 168 37,541$ $ - $ - $ 1,804 39,345$

2.6 PCB Risk Reduction Program 4 0 0 138 0 0 0 142 33,909$ $ - $ - $ 1,623 35,531$

2.7 TMDL Water Quality Monitoring 211 32 0 18 0 294 100 655 160,809$ $ 9,472 $ 474 $ 5,912 176,667$

2.8 Regional Load Reduction Accounting Framework 590 92 0 56 0 0 0 738 192,951$ $ - $ - $ 2,513 195,465$

3.0 Phase I Permittee PCBs Monitoring, Mapping, and Control Measure Planning 0 2246 0 0 0 2429 330 5,005 1,242,894$ $ 241,948 $ 12,097 $ 74,847 1,571,786$

3.1 Workplan Development 0 85 0 0 0 0 0 85 28,621$ $ - $ - $ 1,431 30,052$

3.2 Conduct Monitoring Studies 0 81 0 0 0 1819 0 1,900 407,549$ $ 113,275 $ 5,664 $ 26,324 552,812$

3.3 Mapping in Support of MRP Compliance 0 354 0 0 0 0 0 354 94,114$ $ - $ - $ 4,706 98,820$

3.4 Implement Programs to Control PCBs Discharges from Private Properties 0 962 0 0 0 610 330 1,902 486,200$ $ 123,673 $ 6,184 $ 30,803 646,859$

3.5 Develop and Implement Programs to Control PCBs Discharges Through MS4 Operations and Maintenance Practices 0 354 0 0 0 0 0 354 102,510$ $ 2,500 $ 125 $ 5,257 110,392$

3.6 Plan and Design Stormwater Treatment Systems 0 410 0 0 0 0 0 410 123,900$ $ 2,500 $ 125 $ 6,326 132,851$

3.0 Phase I Permittee PCBs Monitoring, Mapping, and Control Measure Planning 0 1563 0 0 2404 0 0 3,967 823,117$ $ 217,471 $ 10,874 $ 52,573 1,104,035$

3.1 Workplan Development 0 67 0 0 0 0 0 67 23,946$ $ - $ - $ 1,197 25,143$

3.2 Conduct Monitoring Studies 0 81 0 0 1875.9 0 0 1,957 329,157$ $ 162,995 $ 8,150 $ 25,015 525,317$

3.3 Mapping in Support of MRP Compliance 0 292 0 0 0 0 0 292 77,096$ $ - $ - $ 3,855 80,951$

3.4 Implement Programs to Control PCBs Discharges from Private Properties 0 580 0 0 528 0 0 1,108 233,148$ $ 54,476 $ 2,724 $ 14,517 304,865$

3.5 Develop and Implement Programs to Control PCBs Discharges Through MS4 Operations and Maintenance Practices 0 224 0 0 0 0 0 224 64,760$ $ - $ - $ 3,238 67,998$

3.6 Plan and Design Stormwater Treatment Systems 0 319 0 0 0 0 0 319 95,010$ $ - $ - $ 4,751 99,761$

3.0 Phase I Permittee PCBs Monitoring, Mapping, and Control Measure Planning 0 0 3959 0 2747 0 0 6,706 1,438,834$ $ 221,904 $ 11,095 $ 83,592 1,755,425$

3.1 Workplan Development 0 0 236 0 0 0 0 236 63,576$ $ - $ - $ 3,179 66,755$

3.2 Conduct Monitoring Studies 0 0 112 0 0 0 0 112 614,340$ $ 116,525 $ 5,826 $ 36,835 773,526$

3.3 Mapping in Support of MRP Compliance 0 0 466 0 0 0 0 466 113,004$ $ 379 $ 19 $ 5,670 119,072$

3.4 Implement Programs to Control PCBs Discharges from Private Properties 0 0 1408 0 1217 0 0 2,625 552,454$ $ 105,000 $ 5,250 $ 33,135 695,839$

3.5 Develop and Implement Programs to Control PCBs Discharges Through MS4 Operations and Maintenance Practices 0 0 382 0 0 0 0 382 95,460$ $ - $ - $ 4,773 100,233$

3.6 Plan and Design Stormwater Treatment Systems 0 0 0 0 0 0 0 - -$ $ - $ - $ - -$

3.0 Phase I Permittee PCBs Monitoring, Mapping, and Control Measure Planning 0 0 1488 0 1173 0 0 2,661 575,780$ $ 93,440 $ 4,672 $ 33,695 707,587$

3.1 Workplan Development 0 0 156 0 0 0 0 156 44,596$ $ - $ - $ 2,230 46,826$

3.2 Conduct Monitoring Studies 0 0 638 0 653 0 0 1,291 273,318$ $ 48,950 $ 2,448 $ 16,236 340,951$

3.3 Mapping in Support of MRP Compliance 0 0 130 0 0 0 0 130 32,252$ $ 490 $ 25 $ 1,638 34,405$

3.4 Implement Programs to Control PCBs Discharges from Private Properties 0 0 494 0 520 0 0 1,014 206,452$ $ 44,000 $ 2,200 $ 12,633 265,285$

3.5 Develop and Implement Programs to Control PCBs Discharges Through MS4 Operations and Maintenance Practices 0 0 70 0 0 0 0 70 19,162$ $ - $ - $ 958 20,120$

3.6 Plan and Design Stormwater Treatment Systems 0 0 0 0 0 0 0 - -$ $ - $ - $ - -$

3.0 Phase I Permittee PCBs Monitoring, Mapping, and Control Measure Planning 0 0 212 0 0 640 0 852 189,812$ $ 54,388 $ 2,719 $ 12,346 259,265$

3.1 Workplan Development 0 0 33 0 0 16 0 49 14,122$ $ - $ - $ 706 14,828$

3.2 Conduct Monitoring Studies 0 0 20 0 0 580 0 600 126,950$ $ 29,388 $ 1,469 $ 7,890 165,698$

3.3 Mapping in Support of MRP Compliance 0 0 55 0 0 44 0 99 20,948$ $ - $ - $ 1,047 21,995$

3.4 Implement Programs to Control PCBs Discharges from Private Properties 0 0 0 0 0 0 0 - -$ $ - $ - $ - -$

3.5 Develop and Implement Programs to Control PCBs Discharges Through MS4 Operations and Maintenance Practices 0 0 88 0 0 0 0 88 22,896$ $ - $ - $ 1,145 24,041$

3.6 Plan and Design Stormwater Treatment Systems 0 0 16 0 0 0 0 16 4,896$ $ 25,000 $ 1,250 $ 1,557 32,703$

4.0 Program Administration and Management 2565 0 0 0 0 0 0 2,565 630,029$ $ - $ - $ - 630,029$

4.1 Stakeholder Coordination 422 0 0 0 0 0 0 422 115,559$ $ - $ - $ - 115,559$

4.2 Project Management, Grant Management, Annual Requirements 775 0 0 0 0 0 0 775 178,633$ $ - $ - $ - 178,633$

4.3 Quarterly Reports and EPA Coordination 1082 0 0 0 0 0 0 1,082 266,359$ $ - $ - $ - 266,359$

4.4 Final Project Report 286 0 0 0 0 0 0 286 69,477$ $ - $ - $ - 69,477$ 5400 4018 5977 711 7191 4103 430 27,830$ 6,331,610$ 1,130,997$ 56,550$ 310,842$ 7,829,999$ Task Hours
Totals ODCs
LWA Geosyntec EOA Stone
Creek Integral AMS Northgate
Total Cost
Totals

SCVURPPPSMCWPPPSSA
Task No. Task Description

ACCWPCCCWP
LARRY WALKER ASSOCIATES PROPOSAL PREPARED FOR:

City of San Pablo

PCB TMDL Special Studies & Implementation (PCB 125) 23

8.1 TEAM RATES
The following table presents the rates for all staff on the LWA Team. The LWA Team requests a uniform rate increase each fiscal year using a fixed annual escalation of 3% from the rates displayed in this table.

A five-year average of each staff rate, using the specified 3% increase, was used to estimate the level of effort for the duration of the Project.

Table 5. LWA Team Rates
Firm Classification Rates
(2025-2026) Classification Rates
(2025-2026)
Larry Walker
Associates
President $368 Project Staff II-A $221
Senior Executive $357 Project Staff II-B $202
Executive Vice President $342 Project Staff I-A $176
Vice President $324 Project Staff I-B $150
Associate II $304 Project Staff I-C $142
Associate I $289 Graphic Designer $155
Senior Staff II $269 Contract Manager $155
Senior Staff I $248 Administrative $82
Geosyntec
Senior Principal $361 Designer $201
Principal $340 Staff Professional $191
Senior Professional $314 Drafter/CADD Operator/Artist $180 Project Professional $283 Senior Drafter/Senior CADD Operator $175 Professional $252 Project Administrator $108
Senior Designer $232 Clerical $88
Senior Staff Professional $221
EOA
Principal $330 Senior Engineer/Scientist II $243
Senior Managing Engineer/Scientist I $325 Senior Engineer/Scientist I $222 Managing Engineer/Scientist III $321 Associate Engineer/Scientist III $212 Managing Engineer/Scientist III $303 Associate Engineer/Scientist II $202 Managing Engineer/Scientist I $288 Associate Engineer/Scientist I $171 Senior Project Manager $282 Associate Engineer/Scientist $154 Senior Technical Specialist $278 Technician, Administrative Manager $130 Senior Engineer/Scientist III $268 Clerical/Computer Data Entry $95 Stone Creek
Environmental
Quality Assurance $317 Field Inspector $192
Principal Compliance Specialist $292 Intern $114
Compliance Specialist II $205 Administrative Assistance $114 Compliance Specialist I $185
Integral
Principal $232 Technical Specialist $97
Senior Scientist $194 Senior Technical Editor $142
Project Scientist $171 Senior Project Specialist $116
Scientist $147 Project Specialist $90
Assistant Scientist $117 Certified Industrial Hygienist $259 AMS Senior Principal Scientist $262 Staff Scientist $146 Senior Scientist $152 GIS Specialist $152
Northgate
Principal III $386 CAD/GIS/Web Specialist I $210
Principal II $333 GIS/Data Analyst II $195
Principal I $322 GIS/Data Analyst I $168
Project Manager $322 CAD Operator II $184
Associate II $314 CAD Operator I $168
Associate I $293 Database Manager $168
Senior II $271 Contract Manager $168
Senior I $254 Field Technician II $136
Project II $231 Field Technician I $113
Project I $210 Project Assistant III $161
Senior Field Geologist $201 Project Assistant II $147 Staff II $174 Project Assistant I $113
Staff I $148 Administrative Assistant $94
CAD/GIS/Web Specialist II $226 Technical Editor $151
Reimbursable Costs
Direct Expenses Cost plus 5%
Subcontract Services Cost plus 5%
Personal Automobile (per mile) Current Gov't Rate
Photocopies (per page) $0.25
LARRY WALKER ASSOCIATES PROPOSAL PREPARED FOR:

City of San Pablo

PCB TMDL Special Studies & Implementation (PCB 125) 24

9.0 METHOD OF PAYMENT
Per Addendum 1, released on April 16, 2025, our Team fully understands and accepts the method of payment for this contract as time and materials with a not-to-exceed amount.

10.0 REFERENCES
LWA's extensive portfolio demonstrates our commitment to excellence across diverse programs and client needs, regulatory frameworks, and stakeholder environments. The following references highlight our proven expertise with related projects and clientele.

Reference 1. MRP Compliance Support
Client Name Alameda Countywide Clean Water
Program
Client Type Public
Years of Service 2010-Present
Reference Sharon Gosselin, ACCWP Management Committee Chair [email protected] ; (510) 670-6547
Type of
Project/Development
Program Implementation /
Administrative Support
Geographic
Area Size/Scale
Countywide program of
17 Permittees
Description of Services See Project 1 for a full description.

Reference 2. Technical Services and Staff Augmentation
Client Name Contra Costa Clean Water Program Client Type Public Years of Service 2014-Present
Reference Andrea Bullock, CCCWP Administrative Analyst
[email protected]; (925) 313-2194
Type of
Project/Development
Program Implementation /
Administrative Support
Geographic
Area Size/Scale
Countywide program of
21 Permittees
Description of Services See Project 2 for a full description.

Reference 3. Phase II Permit Compliance Support
Client Name Marin Countywide Stormwater
Pollution Prevention Program
Client Type Public
Years of Service 2013-Present
Reference Rob Carson, MCSTOPPP Program Administrator
[email protected]; (415) 473-2745
Type of
Project/Development
Permit Implementation /
Program Support
Geographic
Area Size/Scale
Countywide program of
12 Permittees
Description of Services See Project 3 for a full description.

11.0 CONSULTANT CONTRACT STATEMENT
LWA and its subconsultants accept the terms of the City's Agreement sample found in Attachment 1 of the RFP and do not request exceptions.

12.0 SPECIAL REQUIREMENTS
LWA acknowledges that this Project is funded in whole or in part by the federal government and requires compliance with all applicable DBE requirements as specified in 2 CFR § 200.321(b). Our organization is fully committed to taking all necessary affirmative steps to ensure that minority businesses, women's business enterprises, and labor surplus area firms are utilized whenever possible throughout this P roject.

Our Team includes small businesses and women-owned business enterprises.

Appendix 1.

Resumes

Personnel Experience & Qualifications
Ms. Yin is a Senior Scientist I with Larry Walker Associates. She has a B.S. in Ecology & Evolutionary Biology from Rice University and a Master of Environmental Management from Duke University. Ms. Yin joined LWA after completing her Master’s degree, where she concentrated in Ecotoxicology & Environmental Health, emphasizing water resources management. Ms. Yin’s unique combination of skills allows her to address water quality issues through artful solutions and clear communication. At LWA, Ms. Yin has provided both technical support and project management on projects across multiple sectors, including stormwater regulatory assistance and compliance; wastewater regulatory compliance, pollution prevention; and watershed management.

Technical Support and Staff Augmentation, Contra Costa Clean Water Program. 2019- Present. Martinez, CA.

Project manager providing senior-level operations management to support the ongoing and day-to-day operational needs of the Clean Water Program. Facilitates permittee communications and coordination, leads the Administrative and Management Committees, supports the Municipal Operations Committee, provides regulatory insight and permit implementation support on Municipal Regional Permit (MRP) 3.0 Provisions C.2, C.4, C.5, C.9, C.10, C.17, developed comments on those provisions in MRP 3.0, and provides technical support on an as-needed basis. Leads a specialized workgroup focused on assessing the Clean Water Program’s ArcGIS Online System (AGOL) and assessing Permittee needs associated with MRP 3.0. Provides CCCWP representatio n
a
nd support for work performed at the regional level through BAMSC Steering Committee and Subcommittees. Tasks include: planning meetings and agendas, supporting Permittees with permit implementation and compliance, developing schedules for implementation, conducting research and writing reports, preparing and managing budgets, presenting findings to Program staff and Management Committees, and developing recommendations.

Provides the Contra Costa Clean Water Program with on-call regulatory and technical support to facilitate members’ stormwater needs. Technical support tasks include leading and developing grant applications for Program and Permittee projects; finalizing the CCCWP Stormwater Resource Plan; the principal author of the City of San Pablo’s successful application for the Proposition 1 Stormwater Grant Program Implementation Plan Round 2. Serves as the Grant Project Manager for the Clean Watersheds for All (CW4A) project, overseeing the Project Team, reviewing and coordinating grant deliverables, and coordinating with the EPA Grant Administrator. Represents the Clean Water Program on the regional project, Watching Our Watersheds (WOW) through participation on the Project Management Team, distribution of project deliverables, reviewing workplans, and coordinating responses for the Program.

Elizabeth Yin, M.E.M.

Senior Scientist I

EDUCATION
M.E.M., Ecotoxicology &
Environmental Health, 2014,
Duke University,
Durham, NC
B.S. Ecology & Evolutionary
Biology, B.A., Environmental
Science, 2010,
Rice University,
Houston, TX

REGISTRATIONS
Certificate of Geospatial
Analysis, Duke University, NC
2014

YEARS OF EXPERIENCE
With LWA: 11 years
With other Firms: 1 year

SPECIALIZED TOOLS
ArcGIS v. 10.x
QGIS
ENVI
R / RStudio

PROFESSIONAL

AFFILIATIONS
Member, Society of
Environmental Toxicology and
Chemistry (SETAC), Northern
California Chapter
Member, California Stormwater
Quality Association (CASQA)

Personnel Experience & Qualifications
Elizabeth Yin, M.E.M.

Senior Scientist I
Municipal Regional Permit Support Services, Alameda Countywide Clean Water Program (ACCWP). 2022-Present. Hayward, CA
Facilitator for the ACCWP Data Management and GIS Subcommittee. Coordinating internal and external communications, representing the program on regional workgroups and committees, provided technical assistance for the reissuance of the MRP, coordinating training workshops for the subcommittee, alongside co-sponsored topics and themes with other ACCWP subcommittees, overseeing the development of a Data Management Plan. Tasks include: tracking MRP 3.0 requirements, planning meetings and agendas, developing processes for evaluation, conducting research and writing reports, presenting findings to Committee agencies, staff and Management Committees, and developing recommendations.

Phase II Permit Implementation, Multiple Clients. 2014-Present. CA.

Task lead in providing Phase II Stormwater Permit implementation support for multiple Small MS4 clients throughout the San Francisco Bay Region and the Central Valley. Experience in the development and implementation of tools to support various permit requirements, including Public Education and Outreach, Municipal Operations, Construction Requirements, and Illicit Discharges.

Led the development of a preliminary evaluation of PCBs and Mercury load reductions in multiple San Francisco Bay Region Phase II communities. Evaluated and quantified the pollutant load reduction value of public and private projects green infrastructure constructed and installed throughout Napa and Marin Counties using geospatial techniques. Developed a baseline estimate of the load reduction value of green infrastructure projects. Drafted figures and reports, participated in stakeholder group discussions, developed additional information to assist Phase II communities in program planning efforts.

Statewide Trash Amendments Regulatory and Compliance Support for the Stockton Urbanized Area.

City of Stockton / County of San Joaquin. 2017-Present. Stockton, CA.

Task lead to the City of Stockton and the County of San Joaquin in a joint effort to address the Phase I Stockton Urbanized jurisdictional area requirements for compliance with the Statewide Trash Amendments and conducted compliance assessment of the Statewide Trash Amendments Track 1 and Track 2 to determine cost-effective and efficient pathways for compliance. Developed cost estimates and regulatory comparisons of the compliance pathways, assessed and refined Priority Land Uses, evaluated trash best management practice (BMP) implementation feasibility and performance, and developed strategies for prioritizing the City and County’s current programmatic efforts and resources.

Identifying and prioritizing catch basins for trash BMP implementation. Developed a novel approach to identify and refine Priority Land Uses (PLUs) and prioritize City and County programmatic efforts and resources. Evaluated trash control measures, sited catch basins for BMP implementation, identified potential multi-benefit treatment controls for retrofit activities, and developed a cost analysis to implement full-capture systems within priority implementation areas. Produced the Trash Amendments Track 2 Implementation Plan for the City and County’s Phase I jurisdictional area and authored the County of San Joaquin’s Phase II Trash Amendments Track 2 Implementation Plan. Currently assisting the City and the County in developing implementation tools for compliance with the Statewide Trash Amendments and providing monitoring planning and support for the County’s baseline On-Land Visual Assessments.

Personnel Experience & Qualifications
Ms. Mathews serves as a Project Manager for LWA’s work in the stormwater field and has over 30 years of experience developing and implementing water quality compliance programs. She has developed and successfully implemented industrial, construction, and municipal stormwater programs. In 2008, CASQA recognized her contributions to the stormwater profession with its Leadership Award.

Small Municipal Stormwater Assistance, 2013-Present.

Project Manager or technical advisor providing on-call services to multiple Phase II municipalities in the San Francsico Bay Area including: the Cities Benicia, Petaluma; the Marin and Napa countywide programs; and the Ports of San Francisco and Oakland.

Work varies by permittees and has involved developing tools and approaches for all aspects of the permit including legal authority, public outreach and participation, staff training, illicit discharge control, construction stormwater control, municipal operations, program effectiveness assessments, annual reporting, TMDL monitoring and status reporting, and trash reduction planning, and geospatial analyses to support pollutant reduction planning
• Marin Countywide Stormwater Pollution Prevention Program. 2013-Present. • Napa Countywide Stormwater Pollution Prevention Program. 2014-Present. • City of Benicia. 2014-Present.
• Port of Oakland. 2013-Present.
• City of Petaluma. 2021-2022.
• Port of San Francisco. 2018-Present.

Regulatory Assistance Services, California Stormwater Quality Association (CASQA). 2019-2022, 2024-2025. Redondo Beach, CA.

Led the CASQA team providing early input and language to the State Water Board on the pending reissuance of the Phase II Stormwater Permit. Coordinating with two stakeholder committees to develop proposed changes to the existing permit language and develop conceptual language for new sections on Asset Management, Trash, and Compliance Pathways for Receiving Water Limitations. Led the effort to coordinate the input from CASQA members on the informal draft permit, identified key high-level comments for the comment letter and integrated specific, red-lined comments into the 400+ page permit and subsequent negotiations with State Water Board staff.

Municipal Regional Permit Support Services, Alameda Countywide Clean Water Program (ACCWP). 2010-2015; 2015-2020; 2020-Present. Fremont, CA.

Project Manager leading the team providing stormwater permit services to ACCWP for three consecutive five-year contracts. Work has included supporting various program components including serving as the Program Manager (since 2022); facilitating the New Development Subcommittee coordinating quarterly permittee meetings and developing technical materials to support the implementation of the construction and post-construction requirements of the Municipal Regional Stormwater Permit (MRP).

Sandy Mathews, CPESC, QSD/QSP
Vice President

EDUCATION
Master’s Program,
Environmental and Waste
Management,
State University of New York at
Stony Brook
B.A. Liberal Arts, History of
Science; Technology and
Society; Linguistics, 1988,
State University of New York at
Stony Brook

REGISTRATIONS
CPESC, No. 6131;
QSD/QSP No. 00001;
CGP ToR;
IGP QISP ToR 077;
10-hour OSHA Construction
Safety (29 CFR 1926)

YEARS OF EXPERIENCE
With LWA: 16 years
With other Firms: 18 years

PROFESSIONAL

AFFILIATIONS
CASQA
Chair, 2001-03
Director 2001-06; 2014-19
Chair Construction Sub-
Committee, 1998-2001;
2006-15
Member: EPC and Strategic
Planning Committees; BMP,
Industrial, Phase II Sub-
Committees
Member, 1992-Present
IECA
Director/Secretary 2008-13
Member 1996-Present
Western Chapter Director,
2000-07
Western Chapter President
2002-03
Member: SWCS, CWEA, WEF,
Stormwater Institute

Personnel Experience & Qualifications
Sandy Mathews, CPESC
Vice President
Led the development of the 2021-22 through 2023-24 Program Annual Reports. Over the course of the contracts, coordinated more than 25 training workshops for New Development, Industrial and Illicit Discharge, and Maintenance subcommittees. Oversaw the development of the ACCWP Stormwater Resource Plan (SWRP).

Stormwater Technical and Staff Augmentation Services, Contra Costa Clean Water Program (CCCWP). 2014-Present. Martinez, CA.

Project Manager providing technical support services to CCCWP on the implementation of the MRP.

Provide guidance and recommendations to the program staff on various technical studies, and regulatory initiatives that will affect permits. Assist with program budgeting and filling staff shortages.

Led a team of five consulting firms that developed the Contra Costa Watersheds SWRP and provided grant management support. Design and present biennial training workshops for municipal staff on the construction stormwater program requirements. Led the successful effort to acquire a Prop 1 planning grant (~$500,000) to develop the SWRP. Oversaw the grant application work that secured a $1.56 million grant for the City of San Pablo’s Sutter Green Street Project.

PCBs in Caulk Project, San Francisco Estuary Partnership. 2010-2011. Oakland, CA.

Led a team of consultants in the first known attempt to create a model regional regulatory process to manage PCBs in building caulks and sealants to protect water quality. Created a set of model tools for Bay Area municipalities including recommended BMPs, a model implementation process (regulatory process), and a training program for municipal staff. The project set the groundwork for compliance with PCBs load reduction provisions of the PCBs TMDL for San Francisco Bay.

PCBs in Building Materials, Bay Area Stormwater Management Agencies Association (BASMAA). 2017- 2019. Menlo Park, CA.

Assisted BASMAA to develop a program to control potential releases of PCBs during building demolition leading tasks to prioritize building materials of concern; assembled and reviewed existing information and regulatory drivers; and develop a model demolition permit applicant package. Served as the primary contact for stakeholders and project advisors, and coordinated communication with industry, regulatory, and municipal stakeholders. Under Bay Area Municipal Stormwater Collaborative (BAMSC) direction, subsequently updated the program to reflect changes required by the reissued Municipal Regional Permit (MRP). Created a menu of construction program enhancements to be customized by each permittee. Coordinated with the regional steering committee and permittee workgroup on the development of the updates
Stormwater Technical Support, San Mateo County Water Pollution Prevention Program (SMCWPPP). 2015-2022. Redwood City, CA.

Project Manager leading a team of consultants to provide technical support services to SMCWPPP on the implementation of the MRP. Coordinated efforts to develop the SWRP and Green Infrastructure Plan framework. Led the effort to submit two successful Proposition 1 implementation grant applications for multiple green streets projects in Redwood City and San Mateo.

Best Management Practice Handbooks, California Stormwater Quality Association (CASQA). 2009- 2014; 2023-Present. Redondo Beach, CA.

Project Manager for the 2009-2012 updates of CASQA’s Construction and Industrial Best Management Practice (BMP) Handbooks and the 2023 update of the Construction BMP Handbook for the 2022 CGP.

Personnel Experience & Qualifications
Dr. Smith is a Project Scientist with Larry Walker Associates. She brings 2.5 years of experience supporting groundwater, stormwater and wastewater projects across California, and 6 years of experience prior to LWA managing organic biogeochemistry and climate change research projects for her PhD . As a Project Scientist at LWA, she provides project management and technical support to projects in San Joaquin County and Contra Costa County. Dr. Smith has played a major role in writing and implementing numerous grants in support of the Sierra Valley Groundwater Sustainability Plan.

San Joaquin County Region Storm Water Resource Plan (SWRP). 2023-2024.

Assistant Project Manager responsible for co-developing the San Joaquin County Region Storm Water Resource Plan on behalf of the County of San Joaquin and the cities of Stoctkon, Manteca, Tracy and Lodi. Lead several client meetings and presented information on the SWRP to regional watershed management groups and interested parties. Sought guidance from Tribal Liaisons within the California Department of Water Resources to identify respectful and inclusive ways to build government-to-government collaboration around the SWRP. Developed outreach materials for Tribal and non-Tribal Partners, including letters, emails, flyers, and content for the County website.

Sierra Valley Groundwater Sustainability Plan Implementation. 2023-Present.

Co-developed multiple grant applications on behalf of the Sierra Valley Groundwater Management District to enable implementation of pilot groundwater recharge projects in the Sierra Valley. Grants were awarded funding in 2023. Actively manages the acquisition of complex groundwater recharge permits, and serves as assistant manager of field team members and subcontractors during permit implementation. Regularly meets with State Water Resources Control Board and the California Department of Fish and Wildlife (CDFW) staff during permit development and implementation.

Responsible for the development of multiple technical memorandums of potential aquatic and terrestrial wildlife species occurring near and around proposed points of diversion. Proactively coordinates with representatives of the Oroville Dam and regional water masters to ensure protection of downstream beneficial uses during recharge implementation.

Contra Costa County Visual Assessments, Contra Costa County. 2023-Present.

Regularly performs on-land visual trash assessments (OVTAs) for Contra Costa County as part of ongoing monitoring to demonstrate compliance with the Municipal Regional Stormwater Permit.

Rebecca Smith, MSc, PhD
Project Scientist I-A

EDUCATION
PhD, Geosciences, 2023,
University of Massachusetts
Amherst,
Amherst, MA

MSc, Geosciences, 2018,
University of Massachusetts
Amherst,
Amherst, MA

B.S., Geology, 2016
Concentrations in
Water and Society &
Field Studies
Bates College,
Lewiston, ME

YEARS OF EXPERIENCE
With LWA: 2.5 years
With other Firms: 0
With UMass Amherst: 6 years

PROFESSIONAL

AFFILIATIONS
American Geophysical Union
Sigma Xi, Scientific Honors
Society
Geological Society of America
Groundwater Resource
Association of California
The Water Research
Foundation

SPECIALIZED TOOLS
R Statistical Analysis
Matlab
GitHub
ArcGIS
Ocean Data View
Panoply
Adobe Suite (Illustrator &
InDesign)

Personnel Experience & Qualifications
Dr. Rebecca Smith
Project Scientist
MS4 Annual Monitoring Reports, Select Watersheds, Los Angeles County, CA. 2023-Present.

Routinely performs data cleaning and exceedance analyses for the Dominguez Channel Watershed Management Group, the Santa Monica Bay Jurisidictional Group 7, and the Santa Monica Bay Jurisdictional Group 2/3, as part of receiving water and stormwater outfall monitoring requirements for the Los Angeles MS4 NPDES Permit. Data cleaning involves checking reported units and performing calculations for sums of specific constituents with applicaple water quality objectives (namely, Chlordanes, DDTs, PAHs, and PCBs).

Malibu Creek Nutrient TMDL Special Study, City of Agoura Hills. Los Angeles County, CA. 2025-Present.

Assists in the implementation of a special study on behalf of the Malibu Creek Watershed (MCW) Watershed Management Program (WMP) Group that is reevaluating key assumptions of TMDLs for nutrient, algal, and benthic macroinvertebrate (BMI) condition impairments in the MCW. The goal of the study is to identify and justify regulatory changes that would support more effective and efficient implementation. Currently supporting Phase 2 of the study, which involves conducting a comprehensive compilation of available data in the watershed (e.g., water quality, BMI condition, flow, physical habitat) from a wide variety of sources and agencies, conducting analyses of compiled data using custom R- scripts to evaluate drivers of algal biomass and BMI condition, and presenting findings from all analyses in a Phase 2 report to the MCW WMP Group and Los Angeles Regional Water Quality Control Board.

Marin Countywide Stormwater Pollution Prevention Program (MCSTOPPP). 2023.

Revised and updated the MSCTOPPP Annual Program Effectiveness Assessment (EA) and TMDL Status Report. The EA report compiles information on efforts of 12 MCSTOPPP members to reduce priority pollutants, namely pathogens, sediments and pesticides, and evaluates the long-term effectiveness of the best management practices and control programs.

Delta-Mendota Canal Constituents of Emerging Concern Study, North Valley Regional Recycled Water Program. 2024-Present. Tracy, CA.

Performs quarterly fieldwork for the Delta-Mendota Canal (DMC) Constituents of Emerging Conern (CEC) Study. The DMC CEC Study is a requirement of the National Pollutant Discharge Elimination System permit, which regulates discharges of municipally treated wastewater from both the City of Turlock’s Regional Water Quality Control Facility and the City of Modesto’s Water Quality Control Facility to the DMC. Responsibilities include developing and maintaining field standard operating procedures (SOPs), collecting samples for chemical analysis, and performing field and flow measurements at four locations along the Canal.

Cost of Compliance White Paper, Central Valley Clean Water Association (CVCWA). 2023. Central Valley, CA.

Conducted literature review and synthesized information on the potential greenhouse gas impacts associated with advanced wastewater treatment options, such as reverse osmosis, for removal of nutrients (nitrogen and phosphorus) and PFAS.

RESUMES

Chris Sommers, M.S.

President
[email protected]
Chris has over 25 years of consulting and project management experience and specializes in all aspects of stormwater management and assessment, including pollutant control programs, monitoring strategies, and effectiveness assessments. He has provided invaluable regulatory and technical guidance to permitted agencies throughout California on stormwater management and assessment and is highly regarded as one of the leaders in stormwater management in the State. Chris has managed a number of groundbreaking stormwater management projects at the county, regional and statewide scales, including Regional Guidance on Conducting Reasonable Assurance Analyses for the SF Bay PCBs and Mercury TMDLs and statewide guidance on Trash Control Measure Implementation. These and other projects managed by Chris have assisted cities, counties and other public agencies in California with identifying pollutant sources, identifying and implementing appropriate and cost effective control measures approaches, and tracking progress towards numeric targets. Chris has the proven experience to effectively assist public agencies in developing practical and cost-effective stormwater management strategies, optimizing control measure implementation, and maintaining compliance with NPDES permit requirements.

Example Relevant Project Experience
• Reasonable Assurance Analysis (RAA) for PCBs and Mercury, BAMSAA/BAMSC (2018-2020) - Chris was the project manager for a pivotal regional project that developed regional technical guidance on conducting RAA associated with the SF Bay Area Mercury and PCBs TMDLs. The technical guidance was developed to assist Permittees subject to the Municipal Regional Permit (MRP) with standardizing RAA approaches being conducted to demonstrate pollutant load reduction potentials for different control measure scenarios. The project resulted in RAA guidance acceptable to the Regional Water Board staff and technical advisors. The guidance continues to be used by MRP Permittees.
• SF Bay Mercury and PCBs TMDL Implementation - SCVURPPP (2002 - Present) - Total Maximum Daily Loads (TMDLs) for PCBs and mercury were approved in 2008/2009 for the San Francisco Bay. From 2002 to the present, Chris has provided technical and regulatory support to SCVURPPP to address TMDL requirements for all SCVURPPP Co-permittees. Technical support has included managing and designing pollutant source identification studies, managing the implementation of pollutant source and treatment control measures, developing load reduction accounting methods, tracking the TMDL implementation process, coordinating and updating SCVURPPP managers, and negotiating stormwater-related NPDES permit language associated with the TMDLs. • Regional Mercury and PCBs Load Reduction Accounting Methodology, BASMAA/BAMSC (2016 – 2022) - Chris was a technical advisor on the Regional Mercury and PCBs Load Reduction Accounting Tool, a 2016 project managed by EOA. This project was designed to assist MRP Permittees in documenting progress towards achievement of load reduction of mercury and PCBs required by the MRP. Additionally, Chris assist with the update to the accounting methodology for stormwater source controls which was approved by the Regional Water Board in January 2022.

• Regional Clean Watersheds for a Clean Bay (CW4CB), BASMAA/BAMSC (2011 – 2017) – Chris provided technical support and advice on the BASMAA’s CW4CB project, which was designed to implement mercury and PCBs TMDL requirements included in the MRP by evaluating a variety of potential control options to reduce pollutant loads in urban stormwater runoff to the Bay. CW4CB was facilitated through a partnership among Bay Area municipalities and countywide municipal stormwater management programs and was funded by a grant to BASMAA from the United States Environmental Protection Agency (EPA).
• Countywide Stormwater Program Management, SCVURPPP (2001 – Present) - EOA provides program management services to the countywide stormwater management program in Santa Clara County (SCVURPPP). Chris serves as the Program Manager for SCVUPRPPP, and has led the monitoring, pollutants of concern, trash, GIS, and data Areas of Expertise
Stormwater Management
Trash/Litter Management
Pollutants of Concern/TMDLs
Water Quality Monitoring
Ecological Assessment
Program Effectiveness Assessment
Years of Experience
EOA: 24 Years
Prior to EOA: 6 Years
Education
M.S. Nat Resources Management
Humboldt State University
B.S. Environmental Science
Indiana University
Chris Sommers, MS

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management elements of the Program. Chris provides assistance and oversight on all institutional, regulatory, fiscal, and technical aspects of implementing the Program. • PCB Source Identification Projects – SCVURPPP (2001- Present) - Beginning in 2001, Chris has managed and/or advised and directed projects for SCVURPPP that attempt to identify PCB source properties in older industrial areas in the Santa Clara Valley. The goal of these projects is to identify PCB source properties and provide information to support referrals of those properties to the Regional Water Board or other appropriate agencies for abatement.

These projects include directing and conducting monitoring and watershed analyses to provide evidence that high concentrations of PCBs originating from these properties are entering MRP Permittee stormwater systems. The results from these projects have supported the referral of over 15 properties to the Regional Water Board for follow-up investigation and abatement.
• Trash Management Planning – City of Oakland (2016 - Present) – Chris and EOA staff provide assistance to the City on stormwater trash management planning to address MRP trash reduction goals. Chris has led the development of a trash full capture feasibility analysis for the City, where optimal locations that are the most cost-effective sites for the installation of full capture systems in the City’s storm drain system. Additionally, Chris has applied his regulatory and technical expertise in assisting the City in negotiations with the Regional Water Board and served as project manager for a number of trash control measure effectiveness studies in which the City has participated. • Phase II Stormwater Program Management – County of Lake (2001-2010) – Chris served as project lead for the establishment of the Lake County Clean Water Program (LCCWP) and the development of the first Stormwater Management Plan for the LCCWP. Chris also served as project staff for the LCCWP Advisory Committee and numerous subcommittees. Through these efforts, numerous public education and outreach pieces, stormwater treatment design standards, and BMP guidance documents were developed to assist Phase II permittees in Lake County in complying with their NPDES permit requirements. • Street Sweeping and Curb Inlet Screens as Trash Controls – Bay Area Storm Management Agencies Association (2013-2017) – In 2013, BASMAA was awarded a grant by the State Water Board to implement the Tracking California’s Trash (TCT) project. One element of the TCT project was to evaluate the effectiveness of street sweeping and/or curb inlet screening devices in reducing the transport of trash from urban streets to receiving water bodies via stormwater conveyance systems. Chris (as Project Manager) and the EOA Team determined that curb inlet screens significantly reduce the amount of trash transported to storm drain inlets from streets and sidewalks, and in combination with street sweeping achieve a level of trash reduction equivalent to a certified trash full capture system.
• San Francisco Bay Regional Trash Generation Rates - BASMAA (2009-2014) – Chris served as the project manager and lead scientist for the development of regional baseline trash generation rates in the Bay Area. Through the project, a predictive model for trash generation rates was developed based on trash characterization and monitoring conducted at over 150 sites in the Bay Area. Trash generation rates developed through the project served as the foundation for municipality-specific trash generation maps.

Professional Societies/Affiliates
• California Stormwater Quality Association (CASQA) – Board Member • Bay Area Municipal Stormwater (BAMS) Collaborative
• Water Environment Federation (WEF)
• California Resource Recovery Association (CRRA)
• California Water Environment Association (CWEA)
• Society for Environmental Toxicology and Aquatic Chemistry (SETAC)

Publications/Technical Reports – Available upon request │ 1 of 2
Lisa D. Sabin, D.Env., M.S.

Managing Scientist
[email protected]
Overview
Dr. Sabin has 20 years of experience performing science and management related to a wide range of projects that protect and restore surface water quality in California. Her areas of expertise include stormwater NPDES permit compliance, TMDL water quality restoration programs, water quality monitoring, and developing and implementing stormwater control
programs for PCBs and Mercury. She currently assists San Francisco Bay Area municipal agencies with stormwater
management, pollutant control programs and permit
compliance. Dr. Sabin develops and implements projects
designed to characterize watershed concentrations and loads, identify source areas, and evaluate control measure
effectiveness for stormwater pollutants of concern (POCs), including PCBs and other organic compounds, metals,
nutrients, and sediment. She prepared the recent TMDL
Implementation Plan for PCBs and Mercury for the Santa Clara Valley Urban Runoff Pollution Prevention Program (SCVURPPP) to demonstrate progress towards the County’s San Francisco Bay mercury and PCBs TMDL Wasteload allocations. Dr. Sabin co-authored the Bay Area Stormwater Management Agencies’ (BASMAA’s) Source Control Load Reduction Accounting for PCBs and Mercury TMDLs, and the PCBs from Electrical Utilities in San Francisco Bay Area Watersheds on behalf of BASMAA member agencies. She also led monitoring design and implementation of the BASMAA PCBs in Storm Drain Infrastructure Caulk Project that was completed to satisfy NPDES permit requirements. Dr. Sabin supported BASMAA’s development of the guidance materials to assist Bay Area municipalities develop local programs to prevent PCBs from being discharged to municipal storm drains during building demolition activities, and she currently supports municipalities with implementing these programs. For six years, Dr. Sabin assisted BASMAA with management of the Clean Watersheds for a Clean Bay project (CW4CB), a $7M project funded by a grant from USEPA that evaluated various stormwater Best Management Practices (BMPs) as part of implementing the Bay PCB and mercury TMDLs. Prior to joining EOA, Dr.

Sabin implemented a research program on atmospheric deposition of trace metals, organic compounds, and nutrients and impacts on stormwater and receiving water quality at the Southern California Coastal Water Research Project (SCCWRP).

Relevant Project Experience
Santa Clara Valley Urban Runoff Pollution Prevention Program (SCVURPPP) NPDES Permit Compliance, San Mateo Countywide Water Pollution Prevention Program (SMCWPPP) NPDES Permit Compliance Focus on PCBs and Mercury Control Programs
2011 - present
Dr. Sabin assists SCVURPPP and SMCWPPP to comply with NPDES permit provisions requiring reductions of PCBs and mercury loads to stormwater and the Bay. She leads the development and implementation of multiple pollutant control programs that include source area investigation and abatement, managing PCBs-containing materials and wastes during building demolition activities and during bridge and overpass roadway replacement or major repair, and controlling PCBs in oil-filled electrical equipment. She was the lead author of the Old Industrial Area PCBs and Mercury Control Measure Plans submitted to the Water Board for both countywide programs. She assists both counties in tracking and reporting control measure implementation and accounting for the associated POC load reductions. Major tasks have included: developing PCBs control measure programs; designing and Areas of Expertise
NPDES Permit Compliance
Mercury TMDL Compliance
PCBs TMDL Compliance
Water Quality Monitoring
Stormwater Management
Years of Experience
EOA: 13 Years
Prior to EOA: 8 Years
Education
D.Env./Environmental Science and
Engineering
University of California, Los Angeles
M.S./Environmental Health Sciences
University of California, Los Angeles
B.A./Chemistry
San Jose State University

Lisa D. Sabin, M.S., D.Env.

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implementing monitoring plans; SAP/QAPP development; managing field teams; reviewing and analyzing monitoring and modeling data; writing project reports; tracking control measure implementation and calculating and reporting the associated mercury and PCB load reductions achieved.

Lake County Clean Water Program (LCCWP) – BMP Effectiveness Calculator 2020 – 2021
Dr. Sabin developed a Best Management Practices (BMP) Effectiveness Calculator Tool to assist the LCCWP Co- Permittees in evaluating their progress towards achievement of the Clear Lake Nutrient TMDL Wasteload allocation.

Bay Area Storm Water Management Agency Association (BASMAA) Mercury and PCBs Load Reduction Accounting
2016 - 2022
Dr. Sabin developed BASMAA’s Mercury and PCBs Load Reduction Accounting Tool that was designed to assist Permittees and Stormwater Programs in documenting progress towards achievement of load reduction of mercury and PCBs required by the Municipal Regional Stormwater Permit. She also co-authored the BASMAA update to the accounting methodology for stormwater source controls which was approved by the SFBRWQCB in January 2022.

BASMAA Regional Stressor/Source Identification Project – PCBs in Electrical Utility Equipment 2019 – 2020
Dr. Sabin was the technical lead and primary author of the Regional Stressor/Source Identification Project on PCBs from Electrical Utilities in San Francisco Bay Area Watersheds developed on behalf of BASMAA member agencies.

This project evaluated PCBs in electrical utility equipment in the Bay Area and estimated the load from this potential source to urban stormwater runoff. The final project report was submitted to the SFBRWQCB in September, 2020.

BASMAA POC Monitoring for Source Identification and Management Action Effectiveness, Bay Area 2017 – 2019
Dr Sabin served as technical lead responsible for developing and implementing monitoring projects to satisfy municipal stormwater NPDES permit requirements and inform development of required Reasonable Assurance Analyses on behalf of BASMAA member agencies. The studies evaluated PCBs in storm drain infrastructure caulk and the pollutant removal effectiveness of stormwater BMPs.

BASMAA Clean Watersheds for a Clean Bay (CW4CB)
2011 – 2017
Dr. Sabin served as assistant project manager of BASMAA’s CW4CB project designed to implement mercury and PCBs TMDL requirements by evaluating a variety of potential control options to reduce pollutant loads in urban stormwater runoff to the Bay. CW4CB was facilitated through a partnership among Bay Area municipalities and countywide municipal stormwater management programs and was funded by a grant to BASMAA from the United States Environmental Protection Agency (EPA). The total project cost was $7.04 million - $5M from USEPA and $2.04M matching funds from Bay Area municipal stormwater agencies, municipal wastewater treatment agencies, and industrial dischargers. Dr. Sabin provided oversight of day-to-day project management and coordination between CW4CB project partners, managed subcontractors, wrote progress reports, lead project management team and technical advisory committee meetings, tracked budgets for both grant funds and matching contributions, and ensured timely implementation of all grant tasks within project budgets.

Southern California Coastal Water Research Project (SCCWRP), Scientist 2002 - 2010
Designed and implemented a research program on atmospheric deposition of trace metals, organics and nutrients and impacts on water quality in southern California watersheds and the coastal ocean. │ 1 of 2
Bonnie de Berry, MFS, CPSWQ
Managing Scientist
[email protected]
Ms. de Berry has over 25 years of experience managing consulting projects for both public and private sector clients. She assists San Francisco Bay Area municipal agencies with all facets of municipal stormwater NPDES permit compliance. She specializes in water quality, stormwater management, and monitoring/assessment. She directs watershed investigations and environmental analyses to address a wide variety of water related issues with an emphasis on nonpoint sources of pollution and water quality enhancement.

Bonnie focuses on NPDES permitting, TMDL compliance, and stormwater best management practice (BMP) selection. She leverages her interdisciplinary background to develop technical solutions within a dynamic regulatory setting. She designs and implements environmental monitoring plans to identify sources of pollutants and aquatic habitat stressors such as trash, PCBs, bacteria (through microbial source tracking), and nutrients. She leads field studies using state-of-the-art techniques to calibrate simulations of pollutant fate and transport in surface and groundwater systems. Bonnie is skilled at coordinating stakeholder groups, presenting complex studies to a wide variety of audiences, and writing detailed technical documents, often for the purposes of reaching mutually beneficial outcomes from negotiations. She successfully manages schedule and budget commitments for both small and large contracts. Bonnie currently serves as co-chair of the California Stormwater Quality Association (CASQA) Monitoring and Science Subcommittee.

Relevant Project Experience
San Mateo Countywide Water Pollution Prevention Program (SMCWPPP) Municipal Stormwater NPDES Permit Compliance, 2024-ongoing
As contract manager, Bonnie leads a multi-disciplinary consulting team that assists the SMCWPPP Program Manager with implementation of the Program, including overall Program planning and management, budgeting and scheduling, and facilitation of Program committees, subcommittees, workgroups, and training workshops.

Bonnie leads a team of EOA staff that assists. This includes assisting the Program’s member agencies with all facets of municipal stormwater NPDES permit compliance, including permit requirements related to new and redevelopment, green infrastructure planning, water quality monitoring, PCBs/mercury source identification and control projects, trash controls, public outreach, and annual reporting.

Santa Clara Valley Urban Runoff Pollution Prevention Program (SCVURPPP) and San Mateo Countywide Water Pollution Prevention Program (SMCWPPP) NPDES Monitoring Compliance, 2013-ongoing Ms. de Berry is assisting SCVURPPP and SMCWPPP with compliance with Provision C.8 (Water Quality Monitoring) of their municipal stormwater NPDES permit. From 2013 – 2022, monitoring was focused on bioassessment surveys, i.e., measurement of benthic macroinvertebrates, benthic algae, and physical habitat to assess biological conditions in creeks. With the reissuance of the NPDES permit in 2022, she developed new monitoring programs and associated Quality Assurance Project Plans (QAPPs) to evaluate the effectiveness of bioretention LID facilities and to measure discharges of trash from MS4 outfalls. She also coordinates pollutants of concern (PCBs and mercury) monitoring, pesticides & toxicity monitoring, and special studies to investigate sources of pollutants (low dissolved oxygen, bacteria, PCBs and mercury) and potential management actions.

Areas of Expertise
NPDES Permit Compliance
Stormwater Program Management
Microbial Source Tracking
Water Quality Monitoring
QAPP/SOP Development
Stormwater Management
Grant Writing
TMDL Compliance
Years of Experience
EOA: 12 Years
Prior to EOA: 16 Years
Education
MFS/Aquatic Chemistry
Yale University
BS/Natural Resources &
Environmental Studies
University of Minnesota
Registration/Certification
• Certified Professional in Storm
Water Quality™ #0726 - 2011

Bonnie de Berry, MFS, CPSWQ

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Bonnie represents SCVURPPP and SMCWPPP in regional workgroups and committees and prepares annual interpretive reports.

As the Local Project Manager for the SCVURPPP and SMCWPPP NPDES monitoring programs, Ms. de Berry oversees the data validation process, ensuring that data generated and reported meet data quality objectives (DQOs) identified in the regional Quality Assurance Project Plan (QAPP). She ensures that all field and laboratory data are reviewed and compiled in electronic formats using State-approved templates, such as those developed for the California State Water Resources Control Board Surface Water Ambient Monitoring Program (SWAMP).

She submits these templates to the Regional Data Center for upload to the California Environmental Data Exchange Network (CEDEN).

Sunnyvale-Mountain View Fecal Indicator Bacteria Monitoring and Source Identification, 2020-ongoing Ms. de Berry is assisting the Cities of Sunnyvale and Mountain View investigate potential sources of fecal indicator (FIB) bacteria to their MS4s and identify control measures. Ms. de Berry led the development the FIB Monitoring and Source Identification Program which includes four components: a FIB geodatabase used to understand the extent of potential FIB sources within the Cities, a conceptual model to prioritize MS4 catchments for monitoring, a field monitoring plan and Quality Assurance Program Plan (QAPP), and adaptive management measures. The field monitoring component includes monthly monitoring at prioritized MS4 outfalls, periodic creek walks for comprehensive outfall monitoring, and monthly receiving water monitoring. All samples are analyzed for FIB and human-specific (HF183) genetic markers to assess the spatial and temporal extent of these indicators. Follow-up special studies are conducted within MS4 catchments that have consistently elevated HF183 concentrations. Special studies include methods such as windshield surveys, manhole sampling, and CCTV, and have resulted in corrective actions to eliminate identified sources of HF183.

South Santa Clara County Phase II Municipal Stormwater Management and NPDES Permit Compliance, Santa Clara County, CA, 2013-ongoing
Ms. de Berry is assisting South Santa Clara County and their regional partners, the Cities of Morgan Hill and Gilroy, comply with all aspects of the 2013 Phase II NPDES Permit. Major tasks have included: development of a Regional Wasteload Allocation Attainment Program addressing the Pajaro River Fecal Coliform TMDL; design and implementation of a desktop and field based water quality monitoring program, including development of a Quality Assurance Project Plan consistent with the California Surface Water Ambient Monitoring Program (SWAMP); oversight of compliance with the “Trash Amendments;” negotiations with Central Coast Regional Water Board staff to determine mutually acceptable approaches to compliance; MS4 outfall and catchment mapping; facility mapping; public outreach strategies; and development of the Program Effectiveness Assessment and Improvement Plan (PEAIP). Ms. de Berry also prepares annual reports addressing PEAIP Implementation, TMDL Status, and Water Quality Monitoring.

POC Monitoring for Source Identification and Management Action Effectiveness, Bay Area, 2017 – 2019 For Bay Areas Stormwater Management Agencies Association (BASMAA), served as project manager responsible for overseeing the development and implementation of two study designs to satisfy municipal stormwater NPDES permit monitoring requirements and to inform development of required Reasonable Assurance Analyses on behalf of BASMAA member agencies. One study evaluates PCBs in roadway and storm drain infrastructure caulk and sealants. The other evaluates the effectiveness of stormwater retrofit BMPs. Phase I began in 2017 with development of study designs, a SAP/QAPP, and detailed cost estimates. Phase II, completed in 2018 included collection of caulk and stormwater samples, column studies using several biochar mixes, and laboratory analysis. Monitoring reports were completed in 2019.

RESUMES

LISA AUSTIN, PE stormwater management planning
stormwater BMP selection, evaluation, and design
water resource planning
TMDL compliance

EDUCATION
MS, Civil Engineering, Southern Illinois University, Carbondale, 1992 BS, Environmental Engineering, Southern Illinois University, Carbondale, 1986

REGISTRATIONS AND CERTIFICATIONS
Professional Civil Engineer (PE), California, Number 74663 Professional Civil Engineer (PE), Washington, Number 30370

CAREER SUMMARY
Lisa Austin has 35 years of experience in water quality and stormwater management. She has in-depth knowledge of both industrial and municipal National Pollutant Discharge Elimination System (NPDES) permitting; municipal stormwater program planning; green stormwater infrastructure planning and conceptual design; stormwater permit compliance ; environmental impact analysis; and total maximum daily loads (TMDL) implementation planning. Lisa’s unique mix of experience as a regulator with the state, a permittee with the city , and a consultant to both public and private clients has given her an understanding of the complex relationships between Clean Water Act regulatory programs such as the NPDES permitting program and TMDLs. Lisa’s skills include writing detailed technical documents such as technical memo randa, reports, and manuals; giving technical presentations at conferences, meetings, and hearings; and managing complex projects to meet bud gets and schedules. Lisa ’s relevant project experience is presented below.

Contra Costa County Clean Water Program On -Call Technical Support, Contra Costa County Clean Water Program, Contra Costa County, California. Lisa serves as project director and technical lead assisting the CCCWP in stormwater management planning and program implementation tasks related to monitoring and pollutants of concern. Her ongoing tasks include assisting with countywide polychlorinated biphenyls (PCBs) and mercury TMDL implementation and reporting, participating in the Bay Area Municipal Stormwater Collaboration (BAMSC) Monitoring and P ollutants of C oncern (MPC) Committee, and providing review of technical Lisa Austin, PE