SWM-PS 991026Illicit Discharge Detection
and Elimination
A Forum of the North Central Texas
Regional Storm Water Management
Program `
October 26, 1999
Potential Phase II
Implementation Schedule
Phase II Rule Published (scheduled)
State to Modify Storm Water Regulatory
Program to Implement Phase II
EPA Develops Model Permit
EPA to Issue BMP Menu for MS4 Permit
Requirements
EPA Develops Guidance on Measurable Goals
State to Issue General Permit for Small MS4s
and Construction < 5 acres
MS4 Application for General Permit Coverage
- if Designated by 1990 Census
- if Designated by 2000 Census
MS4 Full Implementation of BMP Program
November 1999
November 2000 -01
October 2000
October 2000
October 2001
November 2002
February, 2003
60 days from notification
5 years from Permit
Issuance (June, 2008)
What Is An Illicit Discharge?
♦ "...any discharge to an MS4 that is not
composed entirely of storm water..." With
some exceptions.
♦ Discharges from direct connection (e.g.
sanitary sewer wastewater), intentional or
not.
♦ Discharges from indirect connections (e.g.
infiltration from sanitary sewers)
L3
Proposed Phase II
6 Minimum Measures
♦ Public education and outreach on storm water impacts
♦ Public
♦ Construction site storm water runoff control
♦ Post - construction storm water management in
development/redevelopment
♦ Pollution prevention/good housekeeping of municipal
operations
Why Are Illicit Detection and
Elimination Efforts Necessary?
♦ Both direct and indirect sources lead to
untreated discharges that contribute high
levels of pollutants to natural waterways.
♦ "MS4s are not designed to accept, process,
or discharge such non -storm water wastes."
♦ Contribute to water quality impairments and
non - attainment.
What Are The Key Components of An
Illicit Discharge Detection and
Elimination Program?
♦ A Plan
♦ Legal Authority
♦ Public OutreachUnvolvement
♦ A Map
Legal Authority
"`you must effectively prohibit illicit discharges
into your MS4 system"
♦ Use ordinances, orders, etc.
♦ Implement enforcement procedures /actions
♦ If you don't, the permitting authority will assume
responsibility for implementing, but you will remain
responsible for the quality of the MS4 discharge.
♦ Model ordinances and examples will be included in the
"tool box"
C%4 A Plan
"You must implement a plan to detect illicit
discharges and illegal dumping"
♦ Locate problem areas - public complaints, visual
screening, water quality sampling
♦ Find the source - smoke & dye testing, tracing,
inspection, video
i Remove /correct the problem - educate and enforce
♦ Document actions taken - track progress
Public OutreachUnvolvement
"You must inform public employees, businesses and
citizens of hazards arising from illegal discharges
You should coordinate this measure with the public
information measure"
♦ Training programs
♦ Informational brochures
♦ Facilitated public reporting - Hotlines
♦ Coordination of volunteer efforts
♦ Recycling programs for hazardous waste
WN
Ll
a
A Map
E3
"You must develop storm water system maps"
♦ Show location of major pipelines, outfalls and
topography
• Show areas of concentrated activities likely to be a
source of storm water pollutants
♦ Demonstrate an awareness of the intake and discharge
areas of the system
♦ Identify the extent and sources of dry weather flows
"It may take more than one trip to locate all outfalls"
Illicit Discharge Detection
and Elimination
E3
The objective of this minimum control measure is to have
MS4 owners and operators gain a thorough awareness of
their storm water systems.
U
The task is to determine the types and sources of illicit
discharges entering their systems, and then to establish
the legal, technical, and educational means to try and
eliminate these discharges.
What type of mapping
system is appropriate for
your community?
-Paper records
-CAD drawings
•GIS system
How do you decide which system
to use?
— How much does it cost (set -up
and maintenance)?
— Which departments will share it?
— Can you share the cost with
other jurisdictions?
E3
U