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 Transportâ€
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.