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Street Sweeping Program Guidance Manual Chapter 4 Comment Responses

Summary: comments chapter 4 street sweeping manual

D3.4 Chapter 4 TAC Comment Responses
Commenter, Jurisdiction
Section
Comment and Suggested Revision
Comment Response
Comment
Shelby Giltner, ECY
Ch. 4 Title
Suggestion for the title: Establishing and Implementing Street Sweeping Programs.
Retitled to “Street Sweeping Program Components” per
TAC meeting.
Yes
Paul Marrinan
Ch. 4 Title
I think it’s a good idea to rename this section either to what you propose in your
email or: elements of a sweeping a program.
Retitled to “Street Sweeping Program Components” per
TAC meeting.
Yes
Madison Bristol, ECY
Ch. 4 Title
ECY REVIEWERS – Review due 12/20/2024. Please utilize COMMENTS and not
TRACKED CHANGES. This helps with document reconciliation. Thank you.
Retitled to “Street Sweeping Program Components” per
TAC meeting.
Yes
Larry Schaffner
Ch. 4 Title
Suggested renaming is in recognition that this chapter may also be useful for
jurisdictions with existing programs. The renaming suggestion is inspired by the
language in the last sentence of Section 4.2.
Retitled to “Street Sweeping Program Components” per
TAC meeting.
Yes
Paul Marrinan
Ch.4 – Title
I think it’s a good idea to rename this section either to what you propose in your
email or: elements of a sweeping a program.
Retitled to “Street Sweeping Program Components” per
TAC meeting.
Yes
Jackie Cladwell, Vancouver
Chp. 4 Title
The chapter title is currently “Establishing Street Sweeping Programs,” however,
some of the chapter contents may be useful for jurisdictions with existing programs.
Does it make sense to rename the chapter to something like, “Street Sweeping
Program Components”? Do you have any other suggestions? We prefer the second
Retitled to “Street Sweeping Program Components” per
TAC meeting.
Yes
David Jackson, Marysville
Chp. 4 Title
Suggested chapter title: Elements of a Street Sweeping Program” to match verbiage
in the Stormwater Management Manual?
Retitled to “Street Sweeping Program Components” per
TAC meeting.
Yes
Amy B. Waterman, ECY
4.1
and maintaining
added
Yes
Abbey Stockwell, ECY
4.1
Should it be clear that the purpose of this guidance is a sweeping program for water
quality/stormwater management? – which can be combined with other sweeping
benefits/purposes and public services (aesthetics of an area, air quality, etc.)
Added to 2nd sentence in first paragraph.
Yes
Traci Pearson, ECY
4.1
[Regarding "waste disposal" in the middle of the paragraph.] If you haven't already, I
suggest checking in with Ecology's Hazardous Waste and Solid Waste Programs
about their waste management and disposal regulations related to street/sweeping
Comment noted. Comment will be moved to chapter 7
Disposing of Street Sweeping Waste.
Yes
Larry Schaffner
4.2
General comment: Given this is a guidance manual, consider whether the
references at the end of the chapter are sufficient. While citations may serve a
specific value in some instances, their frequent use throughout the document might
seem out of place (and can present a distraction) in the context of this guidance
Per TAC discussion, references will be left as is.
Yes
Jessica Schwing, ECY
4.2
[Following end of 2nd sentence]. consider adding in the additional steps in the
program- proper storage and disposal of this waste. We see many "programs" that
fail to account for these steps resulting in a re-release/re distribution of pollutants.
This also results an extreme under-estimation of the cost to implement a sweeping
Added a few words about storage and disposal along with
a reference to chp 7 for more details.
Yes
David Mora, ECY
4.2
[Following end of 3rd sentence]. might clarify : with high efficiency sweepers
Added "when high efficiency sweepers are utilized."
Yes
Xavier Gilbert, ECY
4.2
[Regarding sentence that ends in "…reduce clogging of stormwater infrastructure,
allowing for less frequent maintenance."] Just because less sediment is reaching
the BMP does not mean you can maintain it less. Water is still reaching the BMP
which causes wear and tear and warrants routine maintenance.
Attempting to run a street sweeper in the hopes of cutting corners in other
maintenance areas will do more harm than good.
Revised sentence to provide clarification that sweeping
has the potential to reduce the amount of maintenance
needed and the BMP lifecycle.
Yes
Jessica Schwing, ECY
4.2
[Regarding sentence that ends in "…allowing for less frequent maintenance."] Has
"less frequent maintenance" been demonstrated?
Revised sentence to provide clarification that sweeping
has the potential to reduce the amount of maintenance
Yes
Page 1
D3.4 Chapter 4 TAC Comment Responses
Commenter, Jurisdiction
Section
Comment and Suggested Revision
Comment Response
Comment
Paul Marrinan
4.3
Add permitting to this list and to the bullet points below. We are required to
maintain a health department permit and test the waste prior to disposal to ensure
that it is not hazardous.
This is correct, added reference to applicable health
department permits; will elaborate more on this in Chapter
Yes
Larry Schaffner
4.3
General thought to consider: Subsections in 4.3 includes language such as “See
Chapter/Section X for further discussion on Y”. This makes me wonder how to
efficiently present information (or where best to present it) without being
We will revisit this after the entire manual has been pulled
together and if needed make adjustments in the draft
compiled manual. This may include removing some
Yes
Abbey Stockwell, ECY
4.3
[Regarding second sentence] . I am not sure this is a "but" statement. Recommend:
Jurisdictions with a Phase I or Phase II MS4 Permit are required to conduct street
sweeping. Other considerations such as safety or maintenance concerns and public
perception may also factor into goals.
Changed "but" to "and"
Yes
Abbey Stockwell, ECY
4.3
[End of second to last sentence in first paragraph] . and permit requirements?
added
Yes
Brent Dhoore
4.3.1
This can also include local Health Department permit requirements for handling and
storage which include ongoing permit compliance admin.
added
Yes
Amy B. Waterman, ECY
4.3.1
if they are planning to purchase their own sweeping equipment.
Added a few words about deciding whether or not to
purchase a sweeper.
Yes
Larry Schaffner
4.3.1
In addition, coordinating externally could come into play with effected businesses
and special events.
added
Yes
Zackary Holt
4.3.1
Could we consider something less procedural than an SOP? In my experience,
operators tend to disregard these unless they are super simplified, such as flip
books that are 1-2 pages tops? Or maybe a combination of the two?
Added separate bullet for corollary instructions.
Yes
David Mora, ECY
4.3.1
[Regarding Sweeping locations and routes and Sweeping schedule bullets] . I would
consider the how to of routes and scheduling, waste disposal, and tracking as part
of your SOP
Yes, these aspects will likely be included in SOPs, but we
wanted to call out these items as their own specific
considerations. Designing street sweeping routes will be
included in Chapter 5 – Optimizing Street Sweeping
Practices. Scheduling is discussed later in this chapter.
Waste disposal is discussed in Chapter 7 – Disposing of
Street Waste. Tracking is included in Chapter 6 – Data
Collection and Reporting.
Yes
Xavier Gilbert, ECY
4.3.1
[Regarding Sweeping locations and routes and Sweeping schedule bullets]. What
does this mean? Do they know WHY they are sweeping this area? Do they know what
pollutants are of concerns in each area?
The process behind selecting areas to sweep is explained
in Chapter 3 – Selecting Priority Areas. Pollutants of
concern are discussed in Chapter 2 – Street Sweeping
Yes
Sarah Ponte, ECY
4.3.1
[Regarding Equipment selection and maintenance protocol bullet]. Consider
including/taking into consideration maintenance costs in the budget allocation
This is addressed in chapter 8.
Yes
Rachel Yonemura, ECY
4.3.1
[Regarding Equipment selection and maintenance protocol bullet]. it might be good
to make a quick note about making a plan for if/when a sweeper is down. sometimes
sweepers can be down for a long period of time, but sweeping still needs to be done.
Added consideration and examples of contingency plans
for equipment downtime to Section 4.6.2.
Yes
Jessica Schwing, ECY
4.3.1
[Regarding Waste disposal process bullet]. What about storage and
calculating/estimating your storage needs? Almost all the other factors hinge on
knowing how much material you have to physically move around, store, dump etc.
This will be addressed in chapter 7.
Yes
Xavier Gilbert, ECY
4.3.1
[Regarding Data collection and documentation bullet]. This is a great way to figure
out where your hot spots are and adjust your sweeping intervals accordingly.
Agree. Data collection for use in identifying areas to street
sweep, including hot spots, is included in Chapter 3 –
Yes
Abbey Stockwell, ECY
4.3.2
[Regarding first sentence of the section] . Consider adding GIS staff to this list for
route mapping, updates, route optimization and analysis
Added GIS staff to list.
Yes
Page 2
D3.4 Chapter 4 TAC Comment Responses
Commenter, Jurisdiction
Section
Comment and Suggested Revision
Comment Response
Comment
Xavier Gilbert, ECY
4.3.2
[Regarding Mechanic bullet]. If you are running an in-house street sweeping
program, this is a key piece of the puzzle to keep things running smoothly.
Comment noted.
Yes
Zackary Holt
4.3.2
[Regarding Crew Leader bullet] . Responsible for data collection as well?
Added "may also be responsible for data collection".
Yes
Abbey Stockwell, ECY
4.3.3
Delete “high”, can match PH II language as below
left as is for consistency with other manual sections.
Yes
Larry Schaffner
4.3.3
Seems redundant with the previous sentence.
Sentence deleted.
Yes
Zackary Holt
4.3.3
[Regarding Selbig & Bannerman 2007 citation] . Local? If not, in which area was the
Added study location and climate. Moved section to
Yes
Larry Schaffner
4.3.3
May be less relevant in western WA (at the lower elevations) given the relatively mild Added a sentence about seasonal sweeping for WWA.
Yes
Larry Schaffner
4.3.3
In drawing conclusions, suggest considering the climatic conditions where these
studies took place.
Added and moved section to Section 2.2.3 Removal
Efficiency.
Yes
Larry Schaffner
4.3.3 Table 4-1
Does the study describe what “hot spot areas” entail? If so, suggest adding that
description in a footnote to this table.
Added definition for hotspots. Moved section to Section
2.2.3 Removal Efficiency.
Yes
David Mora, ECY
4.3.3 Table 4-1
[Regarding Arterials info] . Perhaps optimal if your objective is to keep other BMPS
working. If optimal is getting anywhere near the efficiencies hoped for to curb 6PPD-
Waiting to hear back from Ecology regarding a source for
this.
Larry Schaffner
4.3.3
Great information in this section
Comment noted.
Yes
Jessica Schwing, ECY
4.3.3
[Regarding sentence in paragraph before table 4-1] Research studies also provide
recommendations for street sweeping frequency]. to address specific pollutants or
environmental conditions.
Added "to address water quality." Moved section to
Section 2.2.3 Removal Efficiency.
Yes
Larry Schaffner
4.3.3
I understand how this could be the case on arterials, but residential areas too?
In residential areas, street parking maybe will be greater –
Yes
Zackary Holt
4.3.3
In my experience, planning for and implementing no parking sign placement can be
a significant lift (site dependent, neighborhood design, etc.) with notification
requirements, parking alternatives, etc. Is this discussed later?
Addressed in Section 4.8.5 and Section 8.2.4.4
Yes
Amy B. Waterman, ECY
4.3.3
Any more recent ones? Also this section does not address PNW specific situation,
with most of rainfall in the fall and winter. This was a major consideration in Permit
requirements to sweep before the onset of these rain events.
We did not find more recent studies, but we did find a
resource relevant to WWA climate. Added a sentence
about seasonal sweeping for WWA. Moved section to
Section 2.2.3 Removal Efficiency.
Yes
Larry Schaffner
4.3.3 – Figure 4-1
Did the study involve similar climatic conditions as found in eastern and/or western WAdded context of study location and climate. Moved
section to Section 2.2.3 Removal Efficiency.
Yes
David Jackson, Marysville
4.3.4
[RE: Have any jurisdictions scheduled street sweeping around needle drop? If so,
can you provide what time of year is best for different species of conifers?]Our sweeping is based on high traffiic areas and annual coverage.
Comment Noted.
Yes
Larry Schaffner
4.3.4
Is this intended to imply utilizing an in-house mechanic? If not, is seems redundant
with utilizing a private contractor.
Revised sentence to provide clarification.
Yes
Larry Schaffner
4.3.4
The relevance of this portion of the sentence isn’t clear to me.
Deleted portion of sentence.
Yes
Zackary Holt
4.3.4
Debris that has accumulated on the vehicle? Roadside debris or CB debris such as
leaves, etc.? Or is this referring to the process of sweeping?
Refers to cleaning debris out of sweepers after each
sweeping event. Change to “vehicle cleaning” to clarify.
Yes
Larry Schaffner
4.3.4
Does this refer to leaks on the pavement or reducing the likelihood of leaks from the
sweeper?
Added "from the sweeper".
Yes
Zackary Holt
4.3.5
Does this include decanting processes? It sounds like only solids are addressed.
WWA has a lot of juicy street waste that in many instances requires some form of
Revised section to address TAC comments which includes
reference to decanting. More details are provided in chp 7.
Yes
Paul Marrinan
4.3.5
Maybe include potential permitting language in the disposal section instead of
creating a distinct section.
Revised section to address TAC comments.
Yes
Page 3
D3.4 Chapter 4 TAC Comment Responses
Commenter, Jurisdiction
Section
Comment and Suggested Revision
Comment Response
Comment
Amy B. Waterman, ECY
4.3.5
I know there will be more detail on Chapter 7, but this section should acknowledge
the fact that there are liquid and solid wastes from street cleaning. The MS4 Permits
(Appendix 6) have requirements for street waste liquids, which is Ecology's
jurisdiction. Street waste solid disposal is permitted by the County Health
Revised section to address TAC comments which includes
reference to decanting and county health department
permits.
Yes
Abbey Stockwell, ECY
4.3.6
[Regarding 3rd sentence in the first paragraph]. Should this include a discussion on
technology for sweepers that can do some of this documentation?
Add more text with reference to Chapter 6 which includes
details on using sweeper technology for documentation.
Yes
Amy B. Waterman, ECY
4.3.6
[Regarding Bullet: Other documentation requirements: Street sweeping training
performed and staff trained] . including training to prevent or minimize impacts to
water quality.
Section modified and the bullet commented on is not
longer in this section. Comment moved to chapter 6.
Yes
Abbey Stockwell, ECY
4.3.6
Some items in the…

Street Sweeping Program Guidance Manual Final Manual Outline

Summary: street sweeping manual final outline

Street Sweeping Manual
Detailed Manual Outline
July 2024
Street Sweeping Manual | Detailed Manual Outline
Table of Contents
Table of Contents …………………………………………………………………………………………………………………………. i
Chapter 1.
MANUAL INTRODUCTION …………………………………………………………………………………………. 1
1.1
Introduc#on ………………………………………………………………………………………………………………… 1
1.2
Manual Background and Purpose ………………………………………………………………………………….. 1
1.3
MS4 Permit Requirements …………………………………………………………………………………………….. 1
1.4
Manual Organiza#on ……………………………………………………………………………………………………. 1
Chapter 2.
STREET SWEEPING BENEFITS……………………………………………………………………………………… 2
2.1
Chapter Introduc#on ……………………………………………………………………………………………………. 2
2.2
Literature Synthesis ……………………………………………………………………………………………………… 2
2.2.1
Sources of Street Waste ……………………………………………………………………………………………. 2
2.2.2
Physiochemical Characteris#cs ………………………………………………………………………………….. 2
2.2.3
Removal Efficiency ……………………………………………………………………………………………………. 2
2.2.4
Street Pollutant Transport …………………………………………………………………………………………. 2
2.2.5
Water Quality Benefits ……………………………………………………………………………………………… 2
2.3
Co-Benefits …………………………………………………………………………………………………………………. 2
Chapter 3.
IDENTIFYING PRIORITY STREET SWEEPING AREAS ………………………………………………………… 5
3.1
Chapter Introduc#on ……………………………………………………………………………………………………. 5
3.2
Literature Synthesis ……………………………………………………………………………………………………… 5
3.3
Applicable Permit Requirements ……………………………………………………………………………………. 5
3.4
Iden#fying and Selec#ng Priority Street Sweeping Areas ………………………………………………….. 5
3.4.1
Using Collected Data to Iden#fy Priority Street Sweeping Areas …………………………………….. 5
3.4.2
Using Literature Findings to Iden#fy Priority Street Sweeping Areas ………………………………. 5
3.5
Other Jurisdic#onal Priority Areas for Street Sweeping …………………………………………………….. 5
Chapter 4.
ESTABLISHING STREET SWEEPING PROGRAMS …………………………………………………………….. 7
4.1
Chapter Introduc#on ……………………………………………………………………………………………………. 7
4.2
Street Sweeping Overview …………………………………………………………………………………………….. 7
4.3
Program Elements ……………………………………………………………………………………………………….. 7
4.3.1
Administra#on …………………………………………………………………………………………………………. 7
4.3.2
Staffing……………………………………………………………………………………………………………………. 7
4.3.3
Scheduling ………………………………………………………………………………………………………………. 7
4.3.4
Opera#ons and Maintenance …………………………………………………………………………………….. 7
Table of Contents
Street Sweeping Manual | Detailed Manual Outline
4.3.5
Street Waste Disposal ………………………………………………………………………………………………. 7
4.3.6
Documenta#on & Repor#ng ……………………………………………………………………………………… 7
4.3.7
Training …………………………………………………………………………………………………………………… 7
4.4
Program Sizing …………………………………………………………………………………………………………….. 7
4.5
Program Organiza#on …………………………………………………………………………………………………… 8
4.6
Street Sweeping Equipment ………………………………………………………………………………………….. 8
4.6.1
Equipment Selec#on ………………………………………………………………………………………………… 8
4.6.2
Equipment Maintenance …………………………………………………………………………………………… 8
4.6.3
Equipment Replacement …………………………………………………………………………………………… 8
4.7
Contrac#ng vs. In-House Street Sweeping ………………………………………………………………………. 8
4.8
Other Program Considera#ons ………………………………………………………………………………………. 8
4.8.1
Sweeping Nonstandard Curb Lines……………………………………………………………………………… 8
4.8.2
Wet Weather Prac#ces ……………………………………………………………………………………………… 8
4.8.3
Tree Impacts ……………………………………………………………………………………………………………. 8
4.8.4
Parking Restric#ons and Enforcement ………………………………………………………………………… 8
4.8.5
Interlocal Agreements and Partnerships ……………………………………………………………………… 9
Chapter 5.
OPTIMIZING STREET SWEEPING PRACTICES ………………………………………………………………. 11
5.1
Chapter Introduc#on ………………………………………………………………………………………………….. 11
5.2
Literature Synthesis: Variables that Impact Sweeping Efficiency and Efficacy …………………….. 11
5.3
Performance Measures for Street Sweeping Ac#vi#es ……………………………………………………. 11
5.4
Improving Efficiency and Efficacy of Street Sweeping Prac#ces ………………………………………… 11
5.5
Designing Street Sweeping Routes ……………………………………………………………………………….. 11
5.5.1
Considera#ons when Designing Street Sweeping Routes …………………………………………….. 11
5.5.2
Grids …………………………………………………………………………………………………………………….. 11
5.5.3
Areas …………………………………………………………………………………………………………………….. 11
5.6
Addressing Common Street Sweeping Challenges ………………………………………………………….. 11
Chapter 6.
DOCUMENTING, TRACKING, AND COLLECTING DATA FOR STREET SWEEPING ACTIVITIES .. 13
6.1
Chapter Introduc#on ………………………………………………………………………………………………….. 13
6.2
Data Collec#on ………………………………………………………………………………………………………….. 13
6.2.1
Data to be Collected ……………………………………………………………………………………………….. 13
6.2.2
Supplemen#ng Missing Data ……………………………………………………………………………………. 13
6.3
Tracking …………………………………………………………………………………………………………………….. 13
6.3.1
Informa#on to Track ……………………………………………………………………………………………….. 13
Table of Contents
Street Sweeping Manual | Detailed Manual Outline
iii
6.3.2
Manual Tracking Methods ……………………………………………………………………………………….. 13
6.3.3
Automated Tracking Methods ………………………………………………………………………………….. 13
6.4
Documenta#on and Repor#ng …………………………………………………………………………………….. 13
6.4.1
Permit Documenta#on and Repor#ng Requirements ………………………………………………….. 13
6.4.2
Addi#onal Documenta#on ………………………………………………………………………………………. 14
Chapter 7.
DISPOSING OF STREET SWEEPING WASTE …………………………………………………………………. 15
7.1
Chapter Introduc#on ………………………………………………………………………………………………….. 15
7.2
Applicable Permit Requirements ………………………………………………………………………………….. 15
7.3
Street Sweeping Waste Treatment and Disposal …………………………………………………………….. 15
7.3.1
Wastewater Treatment and Disposal ………………………………………………………………………… 15
7.3.2
Solids Disposal ……………………………………………………………………………………………………….. 15
7.4
Es#ma#ng Generated Waste and Decant Facility Size ……………………………………………………… 15
7.4.1
Es#ma#ng Generated Waste ……………………………………………………………………………………. 15
7.4.2
Decant Facility Sizing ………………………………………………………………………………………………. 15
7.5
Planning, Designing, and Opera#ng Decant Facili#es ……………………………………………………… 15
7.5.1
Decant Facility Planning ………………………………………………………………………………………….. 16
7.5.2
Decant Facility Design …………………………………………………………………………………………….. 16
7.5.3
Decant Facility Opera#ons and Maintenance …………………………………………………………….. 16
Chapter 8.
STREET SWEEPING COST CONSIDERATIONS ……………………………………………………………….. 17
8.1
Chapter Introduc#on ………………………………………………………………………………………………….. 17
8.2
Street Sweeping Staff and Resources ……………………………………………………………………………. 17
8.2.1
Workforce Development Program ……………………………………………………………………………. 17
8.3
Lifecycle Cost Es#ma#ng……………………………………………………………………………………………… 17
8.4
Funding …………………………………………………………………………………………………………………….. 17
8.5
Contrac#ng vs. In-House Street Sweeping …………………………………………………………………….. 17
Chapter 9.
OTHER CONSIDERATIONS ………………………………………………………………………………………… 19
9.1
Chapter Introduc#on ………………………………………………………………………………………………….. 19
9.2
Emerging Contaminants ……………………………………………………………………………………………… 19
9.3
Impacts of Sand and Deicers ……………………………………………………………………………………….. 19
Table of Contents
Street Sweeping Manual | Detailed Manual Outline
Chapter 1. MANUAL INTRODUCTION
Purpose: Describe the manual’s intended use and audience, relevant permit requirements, background
on why the manual was developed, and an overview of the manual organiza#on and content.
1.1
Introduc#on
Introduces manual content and background.
1.2
Manual Background and Purpose
Explains manual purpose, background, intended audience, and how the manual can be used.
1.3
MS4 Permit Requirements
Describes 2024–2029 MS4 Stormwater Permit requirements regarding street sweeping, including
Appendix 6 – Street Waste Disposal; compares Phase I, Phase II Eastern Washington, and Phase II
Western Washington requirements.
1.4
Manual Organiza#on
Lists the manual chapters and a brief descrip#on of their content, including appendices.
Figures
Figure of a street sweeper
Tables
Table comparing the Phase I, Phase II Eastern Washington, and Phase II Western Washington
street sweeping requirements
Appendices
None
Sources
Synthesis of Street Sweeping Research & Pracces Guiding Program Development &
Implementaon, Stormwater Ac#on Monitoring Round 4 Proposal
State of Pracce: Assessing Water Quality Benefits from Street Sweeping by Hixon & Dymond
(2018)
O&M Ad Hoc CommiMee White Paper by Trohimovich, et al. (2022)
Structural Stormwater Controls (SSC) Science Synthesis Project Presenta#on by Ecology (2019)
Street Sweeping Technical Sub-group Scope (2022)
City of Ellensburg Street Sweeping vs Catch Basin Cleaning Effecveness Studies Technical
Evaluaon Report (TER) by Navickis-Brasch, et. al. (2020)
Street Sweeping Manual | Detailed Manual Outline
Chapter 2. STREET SWEEPING BENEFITS
Purpose: Summarize the impacts that street waste can have on water quality and the benefits street
sweeping can provide to reduce those impacts. This chapter will also describe addi#onal benefits of
street sweeping, such as benefits to public health and safety.
2.1
Chapter Introduc#on
Introduces the chapter and summarizes its contents.
2.2
Literature Synthesis
Summarizes the compila#on of research findings regarding characteris#cs of street waste and the
impacts of street sweeping on water quality and public health.
2.2.1…

Street Sweeping Manual Draft Concept Chapter Survey Results

Summary: street sweeping manual survey, street sweeping survey results

Street Sweeping Research & Practices Synthesis:
Guiding Program Development & Implementation
Statewide Survey Questions & Results
May 29, 2024
Street Sweeping Research & Practices Synthesis: Guiding Program Development & Implementation |
Statewide Survey Questions & Results
Table of Contents
Table of Contents …………………………………………………………………………………………………………………………. i
Survey Background ……………………………………………………………………………………………………………………… 1
Survey Questions & Results ………………………………………………………………………………………………………….. 2
Street Sweeping Research & Practices Synthesis: Guiding Program Development & Implementation |
Statewide Survey Questions & Results 1
Survey Background
A statewide survey was developed to support the development of the Synthesis of Street Sweeping
Research & Practices: Guiding Program Development & Implementation project. This project aims to
develop a guidance manual that will provide information and tools Permittees can use to assist with
developing and/or improving their street sweeping program to support compliance with the anticipated
2024–2029 Municipal Separate Storm Sewer (MS4) Permit requirements. The intention of this survey
was to gain a better understanding of Permittees’ priorities to inform manual content development. Both
administrative and field staff were encouraged to respond. The statewide survey consisted of 14
questions with different response options, including multiple choice, fill in the blank, and selecting
prioritized options. A total of 46 respondents completed the survey. Each survey question and the
corresponding results are presented below. Results are shown as (number of responses, percent of total
responses). The following section is a summary of the survey questions and results.
Street Sweeping Research & Practices Synthesis: Guiding Program Development & Implementation |
Statewide Survey Questions & Results 2
Survey Questions & Results
1. What MS4 Permit was your jurisdiction issued or will be issued? (Select one)
2. What is the population residing within your jurisdiction's MS4 permit regulated area? (Select one)
6; 13.0%
3; 6.5%
33; 71.7%
2; 4.3%
10%
20%
30%
40%
50%
60%
70%
80%
a. Phase I Permit
b. EWA Phase II Permit
c. WWA Phase II Permit
d. WSDOT
e. Other (Unknown)
MS4 Permit Jurisdiction
0; 0.0%
18; 39.1%
14; 30.4%
4; 8.7%
10; 21.7%
10%
15%
20%
25%
30%
35%
40%
45%
a. less than 10,000
b. 10,000-50,000
c. 50,000-150,000
d. 150,000-250,000
e. greater than 250,000
Population within MS4
Street Sweeping Research & Practices Synthesis: Guiding Program Development & Implementation |
Statewide Survey Questions & Results
3. What best describes your role at your jurisdiction? (Select one)
4. The project team developed the following conceptual chapter outline before submitting the
proposal. The outline was developed based on discussions with regional stormwater work groups,
consideration for the tools needed to meet anticipated MS4 Permit requirements, and professional
judgment. On a scale of 3 being high importance and 1 being low importance, indicate the level of
importance of the following chapter concepts. If a chapter does not appear on the list that you believe
is important, please add it to the text box below.
Topic
Average Score
(1–3)
Standard
Deviation
Water quality benefits of street sweeping
2.57
0.61
Identifying high priority street sweeping areas
2.65
0.63
Establishing new street sweeping programs
1.91
0.75
Optimizing existing street sweeping programs
2.61
0.61
Documenting and Tracking Street Sweeping Activities
2.46
0.65
Street sweeping waste disposal
2.41
0.77
Street sweeping program cost considerations
2.50
0.54
24; 50.0%
14; 29.2%
6; 12.5%
1; 2.1%
20%
40%
60%
a. Stormwater Program Coordinator/Manager
b. Responsible for overseeing the street sweeping
program
c. Responsible for implementing the street sweeping
program
d. Street sweeping Operator
e. Other (Source Control Inspector, former Street
Sweeper Operator)
e. Other (Assists with Health Department Permits
for pile storage compliance)
e. Other
Responder Role in Jurisdiction
Street Sweeping Research & Practices Synthesis: Guiding Program Development & Implementation |
Statewide Survey Questions & Results
1. Water Quality Benefits of Street Sweeping
2. Identifying High Priority Street Sweeping Areas
0.00
0.50
1.00
1.50
2.00
2.50
3.00
3.50
3; 6.5%
14; 30.4%
29; 63.0%
Water Quality Benefits of Street Sweeping
1 – Low Importance
2 – Medum Importance
3 – High Importance
4; 8.7%
8; 17.4%
34; 73.9%
Identifying High Priority Sweeping Areas
1 – Low Importance
2 – Medum Importance
3 – High Importance
Street Sweeping Research & Practices Synthesis: Guiding Program Development & Implementation |
Statewide Survey Questions & Results
3. Establishing New Street Sweeping Programs
4. Optimizing Existing Street Sweeping Programs
15; 32.6%
20; 43.5%
11; 23.9%
Establishing New Street Sweeping Programs
1 – Low Importance
2 – Medum Importance
3 – High Importance
3; 6.5%
12; 26.1%
31; 67.4%
Optimizing Existing Street Sweeping
Programs
1 – Low Importance
2 – Medum Importance
3 – High Importance
Street Sweeping Research & Practices Synthesis: Guiding Program Development & Implementation |
Statewide Survey Questions & Results
5. Documenting and Tracking Street Sweeping Activities
6. Street Sweeping Waste Disposal
4; 8.7%
17; 37.0%
25; 54.3%
Documenting & Tracking Street Sweeping
Activities
1 – Low Importance
2 – Medum Importance
3 – High Importance
8; 17.4%
11; 23.9%
27; 58.7%
Street Sweeping Waste Disposal
1 – Low Importance
2 – Medum Importance
3 – High Importance
Street Sweeping Research & Practices Synthesis: Guiding Program Development & Implementation |
Statewide Survey Questions & Results
7. Street Sweeping Program Cost Considerations
If an area of importance does not appear above, please add it here.
Theme
Survey Response
Post Survey Notes
Addressed in Current Manual
Concept?
Rules and Regulations
• “Knowing and understanding the
rules or regulations”
Permit requirements will be addressed
in Chapter 1 Manual Introduction
Equipment/Machinery
• “Overview of sweeping machines
and sweeping methods/efficiencies
(such as sweeping on a damp day is
more effective to capture materials)”
• “Would like to get better
understanding about allowing water
to run off of sweeper in our heavy
rain season that happens to fall in
our heaviest leaf season. We are told
we can't but not one sweeper
company has a filter system built to
allow this.”
• Planned to include Chapter 4
Establishing New Street Sweeping
Programs.
• Could be addressed in Chapter 4
Establishing New Street Sweeping
Programs.
Sweeping Methods,
Planning, and
Improving Efficiency
• “Route development and sweeping
schedule optimization”
Planned to include Chapter 5
Optimizing Existing Street Sweeping
Programs.
Water Quality
Benefits/Impacts
• “Adaptive management: We need
more 6PPD fate & transport research
to know if street sweeping is
effective. Allowing the particles to sit
in the sun during dry periods may
ozonate the 6PPD out, sweeping may
consolidate 6PPD, fine vs. course
sweepers.”
• Addressed in Chapter 2 Water
Quality Benefits literature search
(status of current research), Could
also be included in Research Gaps
and Recommendations document.
• Could be included in Chapter 2
Water Quality Benefits.
1; 2.2%
21; 45.7%
24; 52.2%
Street Sweeping Program Cost
Considerations
1 – Low Importance
2 – Medum Importance
3 – High Importance
Street Sweeping Research & Practices Synthesis: Guiding Program Development & Implementation |
Statewide Survey Questions & Results
Theme
Survey Response
Post Survey Notes
Addressed in Current Manual
Concept?
• “The pollution generated by
increased street sweeping offsets is
at odds with the water quality
benefits of increased street
sweeping”
Testing
• “List what contaminants in sweep
waste should be tested.”
Could be included in Chapter 7 Street
Sweeping Waste Disposal.
Funding
• “Funding for additional equipment
and labor/disposal due to the
increased sweeping requirements.”
Addressed in Chapter 8 Street
Sweeping Program Cost
Considerations.
Additional Cost
Considerations
• “Cost of permit compliance for
temporary disposal of sweepings as
a sub-category of Program cost
considerations.”
Could be included in Chapter 8 Street
Sweeping Program Cost
Considerations.
Additional Comments
• “For the two areas I didn't score
high, I believe we'll get this
information in a separate report (but
maybe not other than 6PPD-q) and
Ecology is identifying the high
priority areas for us in the permit so I
scored that lower.”
Street Sweeping Research & Practices Synthesis: Guiding Program Development & Implementation | Statewide Survey Questions & Results
5. During the regional stormwater work group meetings, Permittees identified the following additional topics they would like included
in the street sweeping program manual. Please select the top 10 topics you feel are most important to include in the manual.
Topic
Selections
Percentage
Using street sweeper tracking data to improve program efficiency
8.2%
Methods to assess and prioritize roads (beyond what is required in the Permit) based on variables (weight,
bus/truck route, velocity, traffic density, start/stops)
6.4%
Methods for identifying when decant materials need to be sampled
6.2%
Addressing challenges such as protruding tree limbs, non-standard curbs, and street sweeping during leaf season
5.9%
Sweeping different types of surfaces, including permeable pavements
5.7%
Addressing labor and equipment issues, such as hiring enough staff and purchasing street sweepers
5.7%
Methods to minimize trips to the dewater/decant facility
5.5%
Effectiveness of sweeping curb vs non-curb roads
5.5%
Information or data a jurisdiction might collect to refine a program
5.5%
Program funding options
5.3%
Street sweeping program staff training
5.3%
Cost considerations for testing street waste to determine if it is hazardous waste
4.8%
Cost summary of implementing street sweeping requirements in the
Draft 2024-2029 Phase II Permits
4.8%
Parking policies and enforcement options
4.8%
Comparison of cost between street sweeping and vactoring catch basins
4.6%
Methods to effectively sweep areas that are too narrow for a full-size sweeper (e.g., protected bike lanes)
3.7%
Street sweeper size/type vs cost tradeoff (i.e., a larger sweeper will make less dewatering/decant trips but will
cost more to purchase and operate)
3.7%
Ongoing maintenance and staffing requirements required to operate a decant facility
3.4%
Sweeping non-street locations (e.g., parking lots, pathways)
3.0%
Interlocal agreements and community-based public/private partnerships
2.3%
Street Sweeping Research & Practices Synthesis: Guiding Program Development & Implementation |
Statewide Survey Questions & Results 10
6. Does your jurisdiction have access to a decant facility? (Select one)
7. If yes, does the decant facility reside within your jurisdiction? (Select one)
8. How far must the operators travel to access the decant facility? (Fill in the blank)
41; 89.1%
4; 8.7%
1; 2.2%
20%
40%
60%
80%
100%
a. Yes
b. No
c. Unsure
Decant Facility Access
38; 82.6%
2; 4.3%
6; 13.0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
a. Yes
b. No
c. N/A
Decant Facility Within Jurisdiction
17; 37.0%
4; 8.7%
8; 17.4%
5; 10.9%
12; 26.1%
10%
15%
20%
25%
30%
35%
40%
5-10
10-20
20+
N/A or No Information
Distance in Miles to Decant Facility
Appendix Y
Appendix Name
Street Sweeping Research & Practices Synthesis: Guiding Program Development & Implementation |
Statewide Survey Questions & Results
9. If decant facility access requires traveling to another jurisdiction, does the travel distance pose an
acceptable burden, or does it greatly hinder your sweeping program's efficiency? (Select one)
10. For jurisdictions with access to a decant facility, is the decant facility at or near capacity? (Select one)
11. How prepared is your jurisdiction to implement a street sweeping program for water quality
purposes? (Select one)
1; 2.2%
12; 26.1%
33; 71.7%
10%
20%
30%
40%
50%
60%
70%
80%
a. Acceptable
b. Impacts sweeping efficiency
c. N/A
Decant Facility Travel Distance Impact
15; 32.6%
13; 28.3%
14; 30.4%
4; 8.7%
10%
15%
20%
25%
30%
35%
40%
a. Yes, near capacity
b. No, there is additional capacity available
c. Unsure
d. N/A
Decant Facility Capacity
11; 23.9%
9; 19.6%
17; 37.0%
9; 19.6%
10%
15%
20%
25%
30%
35%
40%
a. Our program requires a lot of work
b. Only minor improvements are needed
c. Our program is ready now
d. Not sure
Jurisdiction Preparedness
Appendix Y
Appendix Name
Street Sweeping Research & Practices Synthesis: Guiding Program Development & Implementation |
Statewide Survey Questions & Results
What do you need to be ready that could be included in the manual that has not already been
mentioned? (Fill in the blank)
Theme
Survey Response
Post Survey Notes
Addressed in Current
Manual Concept?
Equipment
• “Type of sweeper needed. We only have a
mechanical sweeper, and contract out
regenerative air vac sweepers.”
• “Addressing moving from an internal
combustion engine sweeper to an electric
or potentially a hydrogen sweeper. What
are the impacts(environmentally, cost,
availability etc.), what grant funding is
available, how to propose for a grant etc.”
• Addressed in Chapter 4
Establishing New Street
Sweeping Programs.
• Could be included in
Chapter 4 Establishing New
Street Sweeping Programs.
Measuring, Assessing,
and Tracking Program
Performance
• “How to practically or simply measure
sweeping effectiveness for program
modification”
• “Methods to develop a street sweeping
schedule, developing the schedule,
delineation of routes or areas (for tracking
purposes) called out in the schedule, and
anticipating budget and staffing to run the
street sweeping program.”
Addressed in Chapter 5
Optimizing Existing Street
Sweeping Practices
Staff and Training
• “Priority for an expanded sweepings
program is sufficient, Trained Staff
(significant issue due to large amount of
turnover since COVID), equipment & plans
for dealing with equipment maintenance.
These items are issues for existing
programs.”
• “I feel many municipalities will need
additional staffing as well as equipment. I
think we do a good job but when it is wet
or during leaf season we slow way down
when I think it is most important and the
only thing that would help is additional
staff”
Addressed in Chapter 4
Establishing New Street
Sweeping Programs.
Decant Facilities
• “Establishing a decant facility”
• “Additional sweeper, staff and an
additional decant facility/potentially a new
solid waste handling permit if waste is
deemed hazardous.”
Addressed in Chapter 7
Disposing of Street Sweeping
Waste.
Sweeping Schedule and
Establishing Routes
• “Adding new routes to meet the permit
requirements; how to optimize the…

Draft Outline Comment Log/Responses- Street Sweeping Program Guidance Manual

Summary: Street sweeping manual, comments street sweeping manual, street sweeping manual outline

Commenter, Jurisdiction
Chapter
Section
Comment and Suggested Revision
Comment Response
Jackie Caldwell, City of Vancouver
Overall
N/A
The draft outline looks good, inclusive of all of the topic
information. I don’t have any comments at this time. Great
work!
Thank you!
Abbey Stockwell, Ecology
Purpose
This outline looks good and covers a lot! Couple thoughts:
-Could climate considerations be included for scheduling
and routing
-Add EJ considerations re: scheduling/routing/parking
enforcement
– wet weather practices
Climate considerations will be described in
Section 4.3.3 Scheduling and Section 5.1.1
Considerations When Designing Street Sweeping
Routes. No change proposed to the Final Manual
Outline.
EJ considerations will be described in Sections
4.3.3 Scheduling, 4.8.3 Parking Restrictions and
Enforcement, and 5.1.1 Considerations When
Designing Street Sweeping Routes. No change
proposed to the Final Manual Outline.
A new subsection was added to Section 4.8 Other
Program Considerations to describe best
practices during wet weather.
Foroozan Labib, Ecology
Purpose
Sweeping effectiveness in removing smaller particles
would likely be impacted by wet weather. Rain/runoff can
wash a lot of smaller particles off the street, and these
smaller particles could be temporarily attached to larger
wet particles accumulating in catch basins downstream.
This in turn could influence the decanting operations and
their pollutant removal efficacy.
Noted. This will be considered when describing
impacts of wet weather in Section 4.8.2.
Larry Schaffner, Thurston County
1.3
Be sure to also include a description of Appendix 6 –
Street Waste Disposal
Added, “….including Appendix 6 – Street Waste
Disposal,” to the Section 1.3 description.
Abbey Stockwell, Ecology
1.3
This might be just be MS4 Permit requirements
Revised to MS4 Permit Requirements.
Commenter, Jurisdiction
Chapter
Section
Comment and Suggested Revision
Comment Response
Larry Schaffner, Thurston County
1.4
Include a list and brief description of any appendices’
content.
Added, “….including appendices,” to the Section 1.4
description.
Larry Schaffner, Thurston County
2.2.2
To the extent possible, it would also be informative to
describe how the characteristics differ based on factors
such as roads serving different land use types, AADT levels
and/or road classifications (e.g., local, collector, arterial,
etc.), areas with significant tire wear, and geographical
and seasonal differences.
Added, “This section also describes how street
waste characteristics differ based on factors such
as road classifications, AADT levels, land use
types, areas with significant tire wear,
geographical area, and season,” to section
description.
Larry Schaffner, Thurston County
2.2.3
Should also include the removal efficiency differences of
the various street sweeping technologies.
This topic will be described either in Section 2.2.3
Removal Efficiency or Section 4.6.1 Equipment
Selection. No proposed change to Final Manual
Outline.
Douglas Howie, Ecology
2.2.3
Cite existing studies
A list of existing studies that will be used to
develop Chapter 2 content was added to the Final
Manual Outline.
Sue Barclift, City of Olympia
2.2.4
Title is not clear – Perhaps “Street Pollutant Transport”
Revised title to “Street Pollutant Transport.”
Larry Schaffner, Thurston County
Tables
To the extent that data exists, include table(s)
summarizing the characterizations should also depict
comparative differences on factors such as roads serving
different land use types, AADT levels and/or road
classifications (e.g., local, collector, arterial, etc.), areas
with significant tire wear, and geographical and seasonal
Added, “Tables summarizing differences of street
waste characteristics based on factors such as
road classifications, AADT levels, land use types,
areas with significant tire wear, geographical
area, and season.”
Larry Schaffner, Thurston County
3.3
Suggest folding this in as a subsection to 3.4 since it will be
one of the considerations for identifying and selecting
high-priority street sweeping areas.
Folding Section 3.3 into a subsection of Section 3.4
will be considered when developing Chapter 3.
Abbey Stockwell, Ecology
3.3
The permit refers to priority areas
Revised all instances of “high-priority” to “priority.”
Commenter, Jurisdiction
Chapter
Section
Comment and Suggested Revision
Comment Response
Larry Schaffner, Thurston County
3.5
Suggest folding this in as a subsection to 3.4.
Folding Section 3.5 into a subsection of Section 3.4
will be considered with developing Chapter 3.
Douglas Howie, Ecology
3.5
Industrial areas, areas with significant construction
activity.
Added, “…roads that serve commercial or
industrial land use, areas with significant
construction activity,…” to the Section 3.5
description.
Larry Schaffner, Thurston County
Tables
Table should focus on summarizing applicable MS4 Permit
requirements related to identify high-priority street
sweeping areas.
Revised table description to, “Table summarizing
applicable MS4 Permit requirements related to
identifying priority street sweeping areas. ”
Larry Schaffner, Thurston County
4.2
Also suggest including street sweeping waste disposal.
Added, “…and street waste disposal,” to the Section
4.2 description.
Douglas Howie, Ecology
4.2
Including publicly owned parking areas
Added publicly owned parking areas to the
Section 3.5 description.
Larry Schaffner, Thurston County
4.3
Suggest including a subsection on street sweeping waste
disposal.
Added new Section 4.3.4 Street Waste Disposal.
This section will provide a high-level overview of
street waste disposal and reference Chapter 7.
Sue Barclift, City of Olympia
4.3.2
Consider differences in program size for staffing needs
Differences in program size for staffing needs will
be described in Section 4.3.2. No change proposed
to the Final Manual Outline.
Douglas Howie, Ecology
4.3.2
Include both operation and maintenance staffing, include
need for parts storage
Added a new subsection to Section 4.3 Program
Elements, titled “Operations and Maintenance,”
which describes operations and maintenance
practices for street sweeping programs, including
sufficient storage for street sweepers and
associated equipment. Operations and
maintenance staffing will be described in Section
4.3.2 Staffing.
Commenter, Jurisdiction
Chapter
Section
Comment and Suggested Revision
Comment Response
Sue Barclift, City of Olympia
4.3.5
Suggest training opportunities. I don’t know of any training
courses except by the dealer or manufacturer. Some of
them aren’t feasible to attend. I’ve been considering
developing operator training aimed at water quality
sweeping. Current training focuses on how to operate the
sweeper.
Training opportunities will be suggested based on
findings from literature in Section 4.3.7. No change
proposed to the Final Manual Outline.
Douglas Howie, Ecology
4.6
There is a correlation between sweeping and vactoring
catch basins that should be discussed in this document. I
don’t know if this is the best place to insert the vactor
issue, but it needs to be included here somewhere.
Section 2.2 will include a brief paragraph
describing the correlation between street
sweeping and vactoring catch basins. Analysis
and discussion beyond this it outside of our scope
of work.
Sue Barclift, City of Olympia
4.6.2
Be sure to include cold weather sweeper storage to keep
the water in the water tank and hoses from freezing.
Cold weather sweeper storage will be included in
Section 4.6.2. No change proposed to Final Manual
Outline.
Larry Schaffner, Thurston County
4.7
Recognize that this doesn’t’ necessarily need to be a
binary choice. Rather it could be a hybrid where
contracting supplements the in-house program. Hence,
discussing supplemental contracting would be useful
here.
Revised the first sentence of the section
description to, “Compares the jurisdictional
workload between performing in-house street
sweeping and contracting out a portion of or all
street sweeping services.”
Sue Barclift, City of Olympia
5.5
I started with our policies – we sweep our bike paths every
2 weeks which is most of our arterials.
Considering policies when designing street
sweeping routes was added to Section 5.5.1.
Larry Schaffner, Thurston County
5.5.3
In what context in “basin” used in this subsection (or
perhaps it would be best not to refer to “basin” and gust
leave it as “area”)?
Revised subsection title to, “Areas.”
Commenter, Jurisdiction
Chapter
Section
Comment and Suggested Revision
Comment Response
Douglas Howie, Ecology
5.5
This may be a good place to describe the issues with
decant water collecting in the sweeper and how to
dispose of it as efficiently as possible while still meeting
the permit discharge requirements.
Challenges with decant water collecting in the
sweeper and how to efficiently dispose of it while
still meeting the MS4 Permit discharge
requirements will be described in Sections 5.5.1,
5.6, and 7.3.1.
Sue Barclift, City of Olympia
5.6
Mention the issue of sweeping during rain events & wet
roads in general. Water fills the hopper quickly & it’s not
feasible to decant often (can fill after sweeping 10 blocks).
Also, the hose attached to the hopper releases water and
releases fines that were collected.
Challenges of sweeping during rain events will be
included in Section 5.6. The section description
includes, “…sweeping during leaf season,
inclement weather, and minimizing trips to the
dewater/decant facility.”
Sue Barclift, City of Olympia
5.6
Need to consider scheduling conflicts such as
garbage/recycle pickup days and special events – school
schedules, construction, paving, street painting. Work with
other depts for seasonal scheduling.
Scheduling conflicts will be described in Section
4.3.3. No change proposed to the Final Manual
Outline.
Larry Schaffner, Thurston County
5.6
Another challenges involve minimizing traffic disruptions
and strategies for dealing with alternative parking options
during sweeping operations.
The section description was revised to include
minimizing traffic disruptions. Strategies for
dealing with alternative parking options will be
described in Section 4.8.3.
Douglas Howie, Ecology
5.6
Include parked vehicles along curb line
The section description was revised to include
parked vehicles along the curb line.
Mark Melton, Ecology
5.6
Consider including snow and inclement weather
The section description was revised to include
inclement weather.
Don McQuilliams, Bellevue WA
5.6
Add pavement deficiencies to the problems list (i.e. roots
lifting pavement or settling uneven pavement).
The section description was revised to include
pavement deficiencies.
Commenter, Jurisdiction
Chapter
Section
Comment and Suggested Revision
Comment Response
Larry Schaffner, Thurston County
6.2
Please elaborate on the relevance/purpose regarding
“who may potentially collect data.”
Who may potentially collect data and its
importance will be described in Section 6.2. No
change proposed to the Final Manual Outline.
Larry Schaffner, Thurston County
6.3
Beyond MS4 Permit-driven documentation and reporting,
suggest including considerations related to business-
related drivers (e.g., improving program efficiency and
efficacy).
Beyond MS4 Permit-driven documentation and
reporting, such as metrics related to business-
related drivers will be included in Section 6.4.2. No
change proposed to Final Manual Outline.
Douglas Howie, Ecology
6.4
Note that documentation for meeting permit requirements
for sweeping and obtaining SMED points are related but
different.
Noted. Additional documentation will be
described in Section 6.4.2. No change proposed to
Final Manual Outline.
Jim Crawford/King County Roads
6.4.1
Include Health Dept Tracking and Reporting Requirements
under Solid Waste Handling Standards. (Storage &
inspection requirements & annual tracking of amounts
generated and disposed). Source: WAC Title 173 Chapter
173-350
The section description was revised to include
WAC Title 173 Chapter 173-350 Solid Waste
Handling Standards.
Jim Crawford/King County Roads
7.2
Appendix 6 AND WAC Title 173 Chapter 173-350-320
The section description was revised to include
WAC Title 173 Chapter 173-350-320.
Don McQuilliams, Bellevue WA
7.2
Add permitting requirements around operation of a
decant facility beyond the NPDES requirements (i.e.
wastewater discharge permit, industrial landfill permit).
Added, “This section also describes potentially
applicable wastewater discharge and industrial
landfill permits,” to the Section 7.2 description.
Larry Schaffner, Thurston County
7.3
Information could also be useful in calculating street
waste disposal costs.
Using information in Section 7.3 to calculate street
waste disposal cost will be described and
reference Chapter 8. No change proposed to Final
Manual Outline.
Commenter, Jurisdiction
Chapter
Section
Comment and Suggested Revision
Comment Response
Sue Barclift, City of Olympia
7.3.1
Be sure to add a disclaimer for your spreadsheet. This is so
hard to predict due to weather (snow/no snow, rain/storm
frequency and operator availability (vacations, sick leave,
operator retention).
A disclaimer will be added to all
tools/spreadsheets developed as part of this
manual.
Douglas Howie, Ecology
Purpose
Not just a decant facility. What happens when sweeping
during rain events and need to unload water from the
sweeper without going to the decant facility? This is a
serious issue that needs to be discussed.
The Purpose of the chapter was revised to include,
“Provide guidance for disposing of street sweeping
waste, both liquids and solids.” A new section titled
Street Sweeping Waste Treatment and Disposal
was added to Chapter 7 that describes the
treatment and disposal of street sweeping liquid
and solid waste.
Larry Schaffner, Thurston County
8.3
If not covered in Chapter 7, suggest touching upon costs
related to decant and street waste disposal.
Decant and street waste disposal costs will be
included in Chapter 7. No change proposed to
Final Manual Outline.
Sue Barclift, City of Olympia
8.4
Encourage funding for the planning stage – decant facility
design and enhanced street sweeping plan before
applying for a street sweeper grant.
Encouraging funding for the planning stage will be
included in Section 8.4. No change proposed to
Final Manual Outline.
Larry Schaffner, Thurston County
8.4
Will this cover funding associated with operations, capital,
both?
Funding described in Section 8.4 will include
funding associated with operations and capital.
This topic will be added to the list of potential case
studies. No change proposed to Final Manual
Outline.

Draft Street Sweeping Manual Concept Chapters Outline

Summary: Concept chapters street sweeping, road maintenance

Ecology | Synthesis of Street Sweeping Research & Practices
ATTACHMENT A-1
Table 4. Street Sweeping Guidance Manual Concept Outline
CHAPTER 1. MANUAL INTRODUCTION
Purpose: Describe the manual’s intended use and audience, relevant permit requirements,
background on why the manual was developed, and an overview of the manual
organization and content.
CHAPTER 2. STREET SWEEPING WATER QUALITY BENEFITS
Purpose: Summarize the impacts that street waste can have on water quality and the
benefits street sweeping can provide to reduce those impacts.
CHAPTER 3. IDENTIFYING HIGH PRIORITY AREAS
Purpose: Provide guidance to assist Permittees in identifying their specific high priority
areas for their street sweeping program using information from Chapter 2 and available
jurisdictional information.
CHAPTER 4. ESTABLISHING AND IMPROVING STREET SWEEPING PROGRAMS
Purpose: Introduce street sweeping program elements; guidance for defining program
goals, starting new programs, and right sizing street sweeping programs; selecting
equipment; and developing/selecting a defendable way to assess and measure program
benefits. Guidance for how to establish and organize multi-department collaborations
that support street sweeping programs.
CHAPTER 5. OPTIMIZING STREET SWEEPING PRACTICES
Purpose: Provide guidance for designing sweeping routes, improving efficiency/efficacy of
existing programs including instructions for collecting data, and variables that may
influence efficiency/efficacy. This chapter will also include guidance for developing
performance measures for street sweeping activities.
CHAPTER 6. DOCUMENTING AND TRACKING STREET SWEEPING ACTIVITIES
Purpose: Provide guidance for documenting and tracking sweeping activities to assist
Permittees with MS4 Permit compliance and tracking program costs.
CHAPTER 7. DISPOSING OF STREET SWEEPING WASTE
Purpose: Provide guidance for estimating the quantity of waste generated from street
sweeping based on specific jurisdictional conditions (i.e., road-miles, sweeping frequency,
land use, traffic volumes, climate, tree-cover, etc.). The guidance will be used to develop a
spreadsheet that Permittees can use to input jurisdictional conditions to estimate the
amount of waste generated and another that estimates the number and size of decant
facilities needed. Considerations will be provided for waste water treatment and disposal
locations and planning for designing/constructing/operating a decant facility.
CHAPTER 8. COST CONSIDERATIONS FOR ESTABLISHING AND MAINTAINING PROGRAMS
Purpose: Provide guidance for estimating street sweeping program costs using
information collected by the jurisdiction or information collected from literature/surveys
(for jurisdictions without data). This will include developing a spreadsheet for conducting a
lifecycle cost estimate and projecting costs based on growth. Information about potential
funding sources will also be provided.
CHAPTER 9. OTHER CONSIDERATIONS
Purpose: Discuss topics that do not fit in other chapters, but Permittees may need to know
when implementing a street sweeping program (e.g., emerging contaminants, when/why
to test waste, etc.)