Session 3 Outline What is a Illicit Storm Water Discharge? - Potential Sources What is required by the permit? What should I have in place prior to getting started? What information do I need to collect? What are my enforcement options? What should I do today? What is a Illicit Storm Water Discharge? - Potential Sources What is required by the permit? What should I have in place prior to getting started? What information do I need to collect? What are my enforcement options? What should I do today?
What is a Illicit Storm Water Discharge? Permit Definition: …any discharge to an MS4 that is not composed entirely of storm water… Exceptions would include NPDES - Permitted industrial sources and discharges from fire-fighting activities.
What is a Illicit Storm Water Discharge? Home Sewer Treatment System Discharge Home Sewer Treatment System Discharge Bypass leach fields Non-maintained aeration systems Redirect outflow
Potential Sources of Illicit Discharges Sanitary wastewater Effluent from septic tanks Car wash wastewaters Improper oil disposal Radiator flushing disposal Laundry wastewaters Agricultural run-off Un-Controlled storm water -quantity Spills from roadway accidents Improper disposal of auto and household toxics. Sanitary wastewater Effluent from septic tanks Car wash wastewaters Improper oil disposal Radiator flushing disposal Laundry wastewaters Agricultural run-off Un-Controlled storm water -quantity Spills from roadway accidents Improper disposal of auto and household toxics.
What is required by the permit? Permit Requirement: Develop, implement and enforce a program to detect and eliminate illicit discharges. Permit Requirement: Develop, implement and enforce a program to detect and eliminate illicit discharges. Contrary to popular belief this is not a BMP Flooding and Uncontrolled Storm Water Run-off
What should I have in place prior to getting started? 1. Goals and objectives to be able to manage, better control and identify storm water run-off issues. 2. Enforcement mechanisms to assist with compliance with these goals. 3. Documents to assist private and public projects with implementing proper controls. $1,000,000 in 2001 $3,100,000 in 2004
What should I have in place prior to getting started? Plan and schedule for performing system inventory. Decision on how to address potential illicit discharges encountered. during system inventory. Draft of illicit discharge detection and elimination protocols. Dry weather screening plan- including what pollutants you are screening for. Data collection and reporting protocols. Budget/funding options Plan and schedule for performing system inventory. Decision on how to address potential illicit discharges encountered. during system inventory. Draft of illicit discharge detection and elimination protocols. Dry weather screening plan- including what pollutants you are screening for. Data collection and reporting protocols. Budget/funding options
What are my enforcement options? Permit Requirement: Through and ordinance, or other regulatory mechanism, a prohibition on non-storm water discharges into the MS4, and appropriate enforcement procedures and actions. Ordinances Rules Civil penalties Pending legislation- HB 411 OEPA- NPDES Phase II rule still pending Permit Requirement: Through and ordinance, or other regulatory mechanism, a prohibition on non-storm water discharges into the MS4, and appropriate enforcement procedures and actions. Ordinances Rules Civil penalties Pending legislation- HB 411 OEPA- NPDES Phase II rule still pending
What information do I need to collect? Determine type of system inventory attributes to collect. Level of detail needed from inventory Type of location information Determination of illicit discharge information to collect Review what was committed to in Storm water Management plan Permit requires map of outfall locations and a removal program Determine type of system inventory attributes to collect. Level of detail needed from inventory Type of location information Determination of illicit discharge information to collect Review what was committed to in Storm water Management plan Permit requires map of outfall locations and a removal program
What should I do today? Suggested Next Steps Determine frame work of Illicit Discharge elimination program Set program objectives Determine scope and budget issues Begin inventory and locate potential illicit discharge points Suggested Next Steps Determine frame work of Illicit Discharge elimination program Set program objectives Determine scope and budget issues Begin inventory and locate potential illicit discharge points Program Objectives and Budget issues Outfall & HSTS Inventory Data collection and Tracking and Reporting
Inventory and Illicit Discharge Identification
Session 3 Review Illicit Storm Water Discharge Required permit activities Getting started Information to collect Enforcement options Getting started activities Illicit Storm Water Discharge Required permit activities Getting started Information to collect Enforcement options Getting started activities Outfall and HSTS Inventory Program Decision points IDEP Program
Wrap Up Questions and Answers
End of Session 3 Session 4 – Implementing Construction/Post- Construction Dos and Donts