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Response to Comments Workshop

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

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  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 • 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

  9. 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 • 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

  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 operator’s 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 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

  15. 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

  16. 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

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