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 1 st 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

Inspection of Catch Basins Requirement:  Inspect all at least once by 4 th 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 4 th 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 Illicit Discharge Detection Elimination System

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 2 nd year  BMP guidance not finalized yet Response:  Developing strategies and procedures in 1st year changed to 2nd year  Fully implemented by end of 2 nd year  Goal to finalize Manual in advance

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 Pollution Prevention and Good Housekeeping in Municipal Operations

Cooperation with Interconnected MS4’s Identifying Physical Interconnections with Other MS4’s Requirement:  ID within 1 st 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 3 rd year

Ordinances Requirement: Developed and introduced within 1 st year and adopted by 2 nd 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