1. Illicit Discharge Detection and Elimination 6/4/20161 Illicit Discharge Detection and Elimination

2. 6/4/20162 Minimum Control Measure: Illicit Discharge Detection and Elimination (IDDE) MUST: Develop a sewer system map of all outfalls and the names of all receiving waters Prohibit non-storm water discharges, through an ordinance or other means, and implement appropriate enforcement procedures Implement a plan to detect and address non-storm water discharges Inform public of hazards associated with illegal discharges and improper disposal of waste

3. Illicit Discharge Detection and Elimination 6/4/20163 What is an Illicit Discharge? A discharge to an MS4 that is not composed entirely of stormwater except permitted discharges and fire fighting related discharges 40 CFR 122.26(b)(2) - Unique frequency, composition & mode of entry -Interaction of the sewage disposal system & the storm drain system -Produced from “generating sites”

4. Illicit Discharge Detection and Elimination Example Illicit Discharges Examples of illicit discharges include:  Sanitary wastewater from improper connections or failing septic tanks  Irrigation runoff  Laundry washwater  Improper oil disposal  Construction site dewatering  Spills from roadway and other accidents

5. Illicit Discharge Detection and Elimination 6/4/20165 IDDE Guidance Manual Joint EPA-funded project between Center for Watershed Protection (CWP) and University of Alabama (Bob Pitt) 8 Program Elements Desktop Methods Field and Lab Protocols Model Ordinance Technical Appendices www.cwp.org OR www.epa.gov/npdes

6. Illicit Discharge Detection and Elimination 6/4/20166 Auditing an Illicit Discharge Program Primarily focus on two main areas: Records  Review illicit discharge/spill response records Procedures  Discuss illicit discharge and spill response procedures It is more difficult to assess in-field activities  Could view outfall screening or follow along on an illicit discharge investigation

7. Illicit Discharge Detection and Elimination 6/4/20167 Inspecting an Illicit Discharge Program Base your inspection primarily on enforceable conditions in the permit Focus on illicit discharge recordkeeping For each illicit discharge report:  Is the problem clearly described in the records?  How long until the MS4 conducts an investigation?  Does the MS4 follow-up to verify that the problem was corrected?  What enforcement actions are taken?

8. Illicit Discharge Detection and Elimination 6/4/20168 Mapping/Database of outfalls Illicit discharge records Dry weather monitoring Training III.8 Illicit Discharge Detection and Elimination Records to review during the audit

9. Illicit Discharge Detection and Elimination 6/4/20169 Common Program Components Legal Authority and Mapping Dry Weather Field Screening Investigation of Suspected Illicit Discharges and/or Improper Disposal Spill Prevention and Response Public Reporting Oils, Toxics, and Household Hazardous Waste Control Preventing Sanitary Sewer Seepage Municipal Staff Education and Training

10. Illicit Discharge Detection and Elimination 6/4/201610 Legal Authority and Mapping Legal Authority Legal authority to specifically prohibit illicit discharges and dumping to the MS4? Exclusions? Enforcement mechanisms? Mapping What mapping exists? (storm drain pipes, outfalls, inlets, municipal facilities, structural controls, etc) Are maps readily available to municipal staff?

11. Illicit Discharge Detection and Elimination Example: Mapping can include TV’ing of storm drain pipes

12. Illicit Discharge Detection and Elimination 6/4/201612 Dry Weather Field Screening Does the MS4 screen outfalls during dry weather for illicit discharges?  How are screening areas identified?  Are areas prioritized based on incidents of illicit discharges, land use, dumping reports, etc.?  How often is screening conducted? If dry-weather flows are present, are they being sampled to determine potential sources of pollutants? For what parameters? Does the permittee have a database to track locations of illicit discharges, spills, and illegal dumping? Does the database track dry-weather monitoring or screening data?

13. Illicit Discharge Detection and Elimination Example: Example of a truck used by an MS4 to conduct outfall screening

14. Illicit Discharge Detection and Elimination Example: Outfall Inventory Sheet Example: Outfall physical condition checklist

15. Illicit Discharge Detection and Elimination 6/4/201615 Investigation of Suspected Illicit Discharges Does the permittee have a written procedure for tracking the source of an active illicit discharge?  Who performs the investigations?  What equipment is available? How are investigations tracked? Has an enforcement response plan been adopted for use when an illicit discharge source has been located? Does the permittee have the ability to collect cleanup and abatement costs from the responsible party?

16. Illicit Discharge Detection and Elimination 6/4/201616 Investigation of Suspected Illicit Discharges Paperwork Review: Review 5-10 illicit discharge reports (including a spill and an unknown illicit discharge in the storm drain system)  Was the full investigation process documented?  Are follow-up activities documented? Did someone verify that the problem was corrected?  Are adequate enforcement actions taken when required?

17. Illicit Discharge Detection and Elimination 6/4/201617 Spill Prevention and Response Does the permittee have a clear set of procedures in place that details who is responsible for responding to spills and emergency situations? Do field staff have spill containment supplies in their vehicles, and are they trained to contain minor spills? Is a contractor or other entity available for larger spills? Does the permittee have the ability to collect cleanup and abatement costs from the responsible party? How are spills and spill response tracked to ensure adequate reporting?

18. Illicit Discharge Detection and Elimination 6/4/201618 Public Reporting Does the permittee prioritize subwatersheds or neighborhoods and assign resources for educational efforts based on frequency and types of illicit discharge incidents? Is there a general phone number or “hotline” in the phone book or Web site that people can call to report a spill or dumping? What types of public outreach materials are available to publicize public reporting? Does the permittee track the number of public calls or complaints reporting illicit discharges?

19. Illicit Discharge Detection and Elimination BACK Example: Investigate Dry Weather Discharges to MS4

20. Illicit Discharge Detection and Elimination 6/4/201620 Oils, Toxics, and Household Hazardous Waste Control Do educational activities and materials encourage the proper disposal of used oil and toxic materials such as household hazardous waste. Does the permittee have recycling or collection facilities to which the public can take used oil and other toxics?

21. Illicit Discharge Detection and Elimination 6/4/201621 Preventing Sanitary Sewer Seepage Has the permittee conducted any studies or evaluations to determine whether sanitary sewers are contributing pollutants to the MS4? What is the extent of infiltration and inflow into the sanitary sewer system? How is this impacting discharge from the MS4? If the permittee also operates a sanitary sewer system, do they have procedures to prevent sewage spills and SSOs to the MS4?

22. Illicit Discharge Detection and Elimination 6/4/201622 Municipal Staff Education and Training What type of training do field staff (e.g., storm sewer maintenance crews, street sweepers) receive on spill response and IDDE? Are staff generally educated about what illicit discharges are and how to report them?

23. Illicit Discharge Detection and Elimination 6/4/201623 Example Field Activity How does the MS4 respond when an illicit discharge is identified in the field? Are they actively looking for illicit discharges? The following photos illustrate how an MS4 investigated an illicit discharge that occurred during an industrial inspection.

24. Illicit Discharge Detection and Elimination

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29. Illicit Discharge Detection and Elimination 6/4/201629 Additional Field Activities Accompany an MS4 crew as they screen outfalls during dry weather View several outfalls  Condition of the outfall can be an indicator of the MS4’s level of maintenance  Is significant trash visible?  Is there flow during dry weather?  Can the MS4 staff easily find the outfalls?

30. Illicit Discharge Detection and Elimination 6/4/201630 IDDE programs are largely reactionary spill response programs. MS4s lack adequate documented procedures for how to conduct IDDE investigations. MS4s don’t conduct any dry weather sampling. MS4s often don’t have criteria to determine if a discharge is illegal or not. MS4 training on IDDE identification, reporting, and response is not adequate. MS4s don’t track IDDE events. Common Compliance Problems