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CONSTROVERSIAL ISSUES ON ADM. DRAFT MRP EXEMPT NON-STORMWATER DISCHARGES

This document discusses three controversial issues regarding non-stormwater discharges and their impact on water utilities and the Water Board. Issues include sampling requirements, reporting efforts, discharges from potable water sources, installation of flushing diffusers, and discharges from swimming pools.

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CONSTROVERSIAL ISSUES ON ADM. DRAFT MRP EXEMPT NON-STORMWATER DISCHARGES

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  1. CONSTROVERSIAL ISSUES ONADM. DRAFT MRPEXEMPT NON-STORMWATER DISCHARGES November 15, 2006 Habte Kifle

  2. 14 – Conditionally Exempt Non-Stormwater DischargesControversial Issue 1 1. Task “a” – Pumped Groundwater, Foundations drains, Water from Crawl Space Pumps and Footing Drains Issue: • Too many sampling requirements • No consideration of cost and extensive reporting only further stretches Water Board staff’s time

  3. Controversial Issue 2 Task “d” – Planned and Unplanned Discharges from Potable water Sources including, but not limited to, Water Conveyance Systems and Hydrant Flushing Issues: • New reporting requirement will demand significant level of efforts from water utilities, Water Board, and municipalities • Impossible to assess and report within 24 hours after unplanned discharger incident • Discharges to sanitary sewer is infeasible due to cost, sanitary sewer capacity, and access problem areas

  4. Continued… Controversial Issue 2 Task “d” – Planned and Unplanned Discharges from Potable Water • Issues: • Installation of flushing diffusers with dechlorinated tablets to meet water quality standards is too prescriptive • Cleanup of storm drains prior to discharge will be problematic

  5. Controversial Issue 3 Task “g” – Swimming Pool, Hot Tub, Spa, and Fountain Water Discharges. Issues: • Discharges to sanitary sewer needs authorities approval and Water Board staff should obtain it • Older sewer plants may not have enough capacity to take extra discharges from swimming pools

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