- Comment: If all discharge is sheet flow, it would not be a regulated discharge correct? (My understanding is that it would need to form a channel at the point it left the property or entered waters of the state to be regulated).
- ResponseAs long as the Permittee has chosen their Benchmark Monitoring Location in accordance with the definition of the Industrial Stormwater Permit, how they collect the sample doesn't change that it's a regulated industrial stormwater discharge.
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- Comment: How about replacing these TP 40 maps with Atlas 14 which was has now been adopted by NOAA.
- Response We have added a link to Atlas 14. The Stormwater Manual will be updated in the future.
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- Comment: The heading notes that there are two different rates for group B soils, but only one is displayed. The old manual used to have a 0.6 inches per hour rate for group B soils.
- Response: As part of the MIDS project, a technical team evaluated the infiltration table and determined there should be one value for B soils (0.3 in/hr). The heading is corrected. This is an important change and we are discussing how to inform Manual users about these types of changes.
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- Comment: This (Stormwater pond/wetland O & M checklist) is a very comprehensive list; most of the criteria would be helpful. It should be reformatted so that it prints more clearly and in a smaller number of pages. A 4 page check list when you are inspecting a pond is too much.
- Response: In the header for select checklists we have added an option to access an Excel version of the checklist
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- Comment:The requirement for two year monitoring seems extremely hard on these systems. Monitoring requirements are not stipulated, pre-installation monitoring is required to characterize the runoff etc. No one in their right mind will do this on every site installation. Take into account that field monitoring devices themselves have been shown to be extremely inaccurate. With the move to MID design standards all tools are valid and for urban redevelopment underground systems may be the best option for the site. I strongly recommend replacing the monitoring requirement with a more stringent design process, say sizing on 50 um lab test using a treatment flow rate developed from the design storm event. Then require washout verification to say below 50 mg/l so that retention of sediment is also considered. A lot of work has been done at SAFL on this.
- Response:This will not be required under the new CSW permit and it has therefore been removed.
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- Comment: How about replacing these TP 40 maps with Atlas 14 which was has now been adopted by NOAA.
- Response We have added a link to Atlas 14. The Stormwater Manual will be updated in the future.
—————————————————————————————————————————————————————————————————————
- Comment: The heading notes that there are two different rates for group B soils, but only one is displayed. The old manual used to have a 0.6 inches per hour rate for group B soils.
- Response: As part of the MIDS project, a technical team evaluated the infiltration table and determined there should be one value for B soils (0.3 in/hr). The heading is corrected. This is an important change and we are discussing how to inform Manual users about these types of changes.
—————————————————————————————————————————————————————————————————————
- Comment: This (Stormwater pond/wetland O & M checklist) is a very comprehensive list; most of the criteria would be helpful. It should be reformatted so that it prints more clearly and in a smaller number of pages. A 4 page check list when you are inspecting a pond is too much.
- Response: In the header for select checklists we have added an option to access an Excel version of the checklist
—————————————————————————————————————————————————————————————————————
- Comment:The requirement for two year monitoring seems extremely hard on these systems. Monitoring requirements are not stipulated, pre-installation monitoring is required to characterize the runoff etc. No one in their right mind will do this on every site installation. Take into account that field monitoring devices themselves have been shown to be extremely inaccurate. With the move to MID design standards all tools are valid and for urban redevelopment underground systems may be the best option for the site. I strongly recommend replacing the monitoring requirement with a more stringent design process, say sizing on 50 um lab test using a treatment flow rate developed from the design storm event. Then require washout verification to say below 50 mg/l so that retention of sediment is also considered. A lot of work has been done at SAFL on this.
- Response:This will not be required under the new CSW permit and it has therefore been removed.