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Response to Comments Workshop. Presented by: Eric Beck, P.E. RIDEM July 24, 2003. Developed by: Laura Stephenson, Greg Goblick, Margarita Chatterton. Public Education/Involvement. Development of Strategies Requirement: Within 6 months: Inform community on involvement
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Response to Comments Workshop Presented by: Eric Beck, P.E. RIDEM July 24, 2003 Developed by: Laura Stephenson, Greg Goblick, Margarita Chatterton
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
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
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
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
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
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
Construction/Post Construction Programs • Development of Strategies and Procedures • Requirement: • 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
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
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
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
Pollution Prevention and Good Housekeeping in Municipal Operations • Discharges Causing Scouring/Sedimentation • Requirement: • 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
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 operator’s legal control”
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 BMP’s • 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
Cooperation with Interconnected MS4’s • Identifying Physical Interconnections with Other MS4’s • 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
Ordinances Requirement: Developed and introduced within 1st year and adopted by 2nd year: IDDE S&E and control of other construction wastes Post-construction run-off Comment: Passage not guaranteed Response: Reasonable deadline Dept. will evaluate level of effort