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 1 st 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. 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

5. 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

6. 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

7. 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

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 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

9. 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

10. 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

11. 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

12. 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

13. 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

14. 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

15. 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

16. 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