08/11/2010 Council Packet - Laserfiche WebLink

Home Search

• • Fact Sheet 2.5— Illicit Discharge Detection and Elimination Minimum Control Measure O Locate Problem Areas EPA recommends that priority areas be identified for detailed screening of the system based on the likelihood of illicit connections (e.g.. areas with older sanitary sewer lines). Methods that can locate problem areas include: visual screening; water sampling from manholes and outfalls during dry weather; the use of infrared and thermal photography. cross - training field staff to detect illicit discharges. and public complaints. O Find the Source Once a problem area or discharge is found. additional efforts usually are necessary to determine the source of the problem. Methods that can find the source of the illicit discharge include: dye- testing buildings in problem areas; dye- or smoke - testing buildings at the time of sale; tracing the discharge upstream in the storm sewer: employing a certification program that shows that buildings have been checked for illicit connections; implementing an inspection program of existing septic systems; and using video to inspect the storm sewers. O Remove /Correct Illicit Connections Once the source is identified. the offending discharger should be notified and directed to correct the problem. Education efforts and working with the discharger can be effective in resolving the problem before taking legal action. O Document Actions Taken As a final step, all actions taken under the plan should be documented. This illustrates that progress is being made to eliminate illicit connections and discharges. Documented actions should be included in annual reports and include information such as: the number of outfalls screened; any complaints received and corrected; the number of discharges and quantities of flow eliminated; and the number of dye or smoke tests conducted. Educational Outreach The Center for Watershed Protection and Robert Pitt (2004) researched the most cost - effective and efficient techniques that can be employed to identify and correct inappropriate discharges. Data from Montgomery County, Maryland, was analyzed and it was determined that staff identify and correct about six inappropriate discharges per year as a result of regular screening. By contrast. over 185 inappropriate discharges are corrected each year in Montgomery County as a direct result of citizen complaints and calls to a storm water compliant hotline. Public education and labeling of outfalls and other storm drain infrastructure is an important element of establishing a successful citizen hotline. Outreach to public employees, businesses. property owners. the general public, and elected officials regarding ways to detect and eliminate illicit discharges is an integral part of this minimum measure. Suggested educational outreach efforts include: Page 3 • Developing informative brochures, and guidances for specific audiences (e.g.. carpet cleaning businesses) and school curricula; • Designing a program to publicize and facilitate public reporting of illicit discharges; • Coordinating volunteers for locating. and visually inspecting, outfalls or to stencil storm drains; and • Initiating recycling programs for commonly dumped wastes, such as motor oil, antifreeze. and pesticides. What Are Appropriate Measurable Goals? Measurable goals. which are required for each minimum control measure, are intended to gauge permit compliance and program effectiveness. The measurable goals, as well as the BMPs. should reflect the needs and characteristics of the operator and the area served by its small MS4. Furthermore. they should be chosen using an integrated approach that fully addresses the requirements and intent of the minimum control measure. EPA has developed a Measurable Goals Guidance for Phase II MS4s that is designed to help program managers comply with the requirement to develop measurable goals. The guidance presents an approach for MS4 operators to develop measurable goals as part of their stormwater management plan. For example, an MS4 could establish a measurable goal of responding to all complaints received by the citizen complaint hotline within 24 hours to minimize water quality impacts or recurrent dumping. A complaint tracking system could be used to log response and enforcement activity. The educational outreach measurable goals for this minimum control measure could be combined with the measurable goals for the Public Education and Outreach minimum control measure (see Fact Sheet 2.3). Sources Center for Watershed Protection and R. Pitt. 2004. Illicit Discharge Detection and Elimination: A Guidance Manual for Program Development and Technical Assessments. Center for Watershed Protection. Ellicott City. MD. and University of Alabama. Birmingham. AL.