Response to Comments Workshop

1
Response to Comments Workshop
Presented by Eric Beck, P.E. RIDEM July 24, 2003
Developed by Laura Stephenson, Greg Goblick,
Margarita Chatterton
2
Public Education/Involvement
Development of Strategies Requirement Within 6
months ? Inform community on involvement ? ID
pollutants ? Involve community in development
and implementation Comment ? 6 months is
inadequate Response ? Extended to 1st year
3
Illicit Discharge Detection Elimination System
Tagging Outfall Pipes Requirement ? ID and
number outfall pipes ? Legible, durable,
maintained ? Municipality and serial
s Comments ? No benefit ? Some
inaccessible ? What size outfall
pipes? Response ? Easy ID, awareness,
accuracy ? Inaccessible pipes not required w/
proper documentation ? GIS maps sufficient
depending on accuracy ? ALL outfall pipes
4
Illicit Discharge Detection Elimination System
Inspection of Catch Basins Requirement ?
Inspect all at least once by 4th year for illicit
discharges Comments ? Financial burden ?
May not accomplish more than existing outfall
inspection program ? Remove requirement Response
? Coordinate activity with sediment
inspections ? Cost effective over other
techniques ? RIDEM experiences shows effective
5
Illicit Discharge Detection Elimination System
Mapping of Additional Elements Requirement ?
Location of catch basins, manholes,
pipes Comments ? Should not be mandated ?
Should be given flexibility ? Financial
burden Response ? Support completion of other
necessary activities ? Plat/lot maps
sufficient ? No deadline ? No minimum level of
effort established
6
Illicit Discharge Detection Elimination System
Dry Weather Survey Requirement ? 2 surveys
conducted by 4th year Comments ? Burdensome ?
1 survey sufficient Response ? Groundwater
table differences ? Different dischargers/users

7
Illicit Discharge Detection Elimination System
Outfall Sampling Requirement ? Temperature,
conductivity, pH, bacteria Comments ?
Costly ? Visual inspections ? Narrow
scope Response ? Visual inspections alone not
sufficient ? Temperature, conductivity, pH
quickly and easily measured in field ? Only
bacteria requires laboratory costs ? Operators
may choose additional parameters
8
Construction/Post Construction Programs
Development of Strategies and Procedures Requirem
ent ? Development of strategies and
procedures within the first year of the
program Comments (No specific comments received
on construction) ? Move to 2nd year ? BMP
guidance not finalized yet Response ?
Developing strategies and procedures in 1st year
changed to 2nd year ? Fully implemented by
end of 2nd year ? Goal to finalize Manual in
advance
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Pollution Prevention and Good Housekeeping in
Municipal Operations
Inspection and Cleaning of Catch
Basins Requirement ? Annual inspection unless
2 consecutive years of inspection data proves
otherwise Comments ? Cost prohibitive ? Need
more cleaning flexibility Response ?
Frequency of cleaning not mandated in permit ?
Inspections annually unless proven otherwise ?
Clean as necessary
10
Pollution Prevention and Good Housekeeping in
Municipal Operations
Street Sweeping Requirement ? Twice
annually Comments ? Financial burden ?
Differences in need ? Should be done in spring
only ? Exemption should be granted w/
documentation ? Not all areas require sweeping
every year Response ? Recommend twice per
year in urbanized (regulated) areas ? Mandated
now only once unless 2 consecutive years of
data justify less ? Increase as necessary
11
Pollution Prevention and Good Housekeeping in
Municipal Operations
Controlling Floatables Requirement ?
Maintenance activities, schedules, inspections ?
Floatable control option (sewer grate retrofits,
litter receptors, netting) Comments ? Be
more specific about intent ? May impact
operation/efficiency ? Not feasible Response ?
Reduce litter to prevent clogging, flooding and
erosion ? Flexibility offered (no particular BMP
is mandated) ? ID priority areas
12
Pollution Prevention and Good Housekeeping in
Municipal Operations
Discharges Causing Scouring/Sedimentation Require
ment ? Remediate known discharges causing
scouring Comments ? Will require Wetlands
permit ? Sediment loading ? Request waiver for
wetlands permit ? Not all outfalls should be
subject to requirement Response ? ID report
annually outfalls causing scouring and remedial
steps ? Added ID report annually outfalls
with sedimentation and remedial steps ?
Dept. will help in determination of
significance ? Maintenance, cleaning,
replacement, or repairs are exempt
activities complete w/o Wetlands permit
13
Pollution Prevention and Good Housekeeping in
Municipal Operations
Municipal Operations that Do Not Meet the
Definition of Industrial Facilities Requirement
? List operations, activities and facilities,
that introduce pollutants into storm water
runoff Comments ? Not legally feasible ? Need
to issue separate permit ? Not covered by Phase
II Response ? Did not expand NPDES Phase II ?
Only operations and facilities specifically
under the operators legal control
14
Pollution Prevention and Good Housekeeping in
Municipal Operations
Municipal Operations that Meet the Definition of
Industrial Facilities Requirement ? SWMPP must
contain SWPPP with description of
BMPs Comments ? Request for additional time
to develop SWPPP ? Does not allow No Exposure
Waiver ? Clarification needed of storm water
discharge associated with industrial
activity Response ? Extension beyond March
10, 2003 ? Facilities with no exposure- no
exposure certification ? Regulations contain a
list of regulated industrial facilities. ?
Facilities not eligible for this permit are
listed in Part I.B.4.d
15
Cooperation with Interconnected MS4s
Identifying Physical Interconnections with Other
MS4s Requirement ? ID within 1st year work
cooperatively Comment ? Not possible until
mapping process is complete Response ? Not all
have to be mapped ? Beneficial to owner to know
where discharges are coming from (ID
significant contributors) ? Changed deadline to
within 3rd year
16
Ordinances
Requirement Developed and introduced within 1st
year and adopted by 2nd year ? IDDE ? SE and
control of other construction wastes ?
Post-construction run-off Comment ? Passage
not guaranteed Response ? Reasonable
deadline ? Dept. will evaluate level of effort