Stoimwater and Sediment 



in introductory sections of this chapter. For this reason, EPA has required that the NPDES 

 permit system must be applied to urban runoff in the late 1980s. Rhode Island's RIPDES 

 program, and the point source discharge programs of Massachusetts, will be required to 

 follow suit 



Both state regulators and municipal public works agencies are much concerned by the 

 advent of this new responsibility, and many questions regarding implementation remain. 

 Because treatment technology for stormwater per se is still experimental, it is unclear 

 whether treatment of the runoff effluent will by required by EPA. Municipalities are 

 concerned that the expenses of stormwater treatment requirements would rival those of 

 secondary sewage treatment In Rhode Island, given the spotty enforcement history of the 

 RIPDES program (U.S.EPA, 1987) stormwater discharge permitting is likely to raise very 

 difficult issues. 



Recommendations 



In issuing development permits throughout DEM and CRMC, and in 

 coordinating implementation efforts with other state agencies, place strong 

 emphasis on preventing stormwater discharge rather than curing its effects. 



In that regard, increase emphasis on source control, on management of household 

 hazardous waste and on soict adherence to required stormwater management practice. 



Consider issuing general permits to urbanized or urbanizing watershed 

 areas "rather than to specific cities or towns. Towns could then establish 

 stormwater utilities singly or joindy and could set rates for stormwater services, and 

 organize management, on a watershed basis. The Ten Mile, Pawtuxet, and Pawcatuck 

 Rivers could be used as prototypes to evaluate the feasibility of issuing general permits 

 where toxics-based NPDES and RIPDES permits have been issued. 



DEM MANAGEMENT OF WASTE OIL THROUGH THE OCEAN STATE CLEANUP 

 AND RECYCLING PROGRAM 



Waste lubricating oil is disposed of in various ways by the 35 percent of Providence 

 residents who change their own automobile lubricating oil (Hoffman, et al., 1980). 

 Methods included garbage can disposal (41 percent), backyard dumping (30 percent), 

 disposal down sewers or storm drains (8 percent), return to a service station (7 percent), 

 pouring the oil on the road (5 percent), and disposal at the town dump (3 percent). 



On a weight basis, road or sewer disposal can account for 44 metric tons of 

 hydrocarbons discharged into the city's combined storm and sanitary sewage tteatment 

 system, or 19 percent to the total hydrocarbons discharged by the city plant. Disposal on 

 land, or in dumps (direcdy or via solid waste collection) also contributes to deterioration of 

 Bay water quality, due to contamination of land runoff, urban mnoff, and groundwater, 

 although inputs due to these sources are difficult to measure (Hoffman et al., 1980). 



Throughout the state, 1980 estimates indicate that roughly 700,000 gallons of used 

 industrial oil and over 2 million gallons of used automotive oil are produced annually. 

 Because waste oil is classified as a hazardous waste according to the Hazardous Waste 

 Management Act of 1978, state regulations specify that it must be manifested on disposal. 

 371,703 gallons were manifested in 1985, a figure which DEM's Ocean State Cleanup and 



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