ILLICIT DISCHARGE DETECTION AND

ELIMINATIONIDENTIFYING, TREATING AND PREVENTING IT UNDER THE BOROUGH’S STORMWATER MANAGEMENT PROGRAM.

BACKGROUND

• STORMWATER : RAINFALL, SNOW/ICE MELT

• STORMWATER FLOWS DIRECTLY INTO STREAMS AND RIVERS AND CARRIES POLLUTANTS AND CONTAMINANTS WITH IT

• ONE SPECIFIC CAUSE OF STORM WATER POLLUTION IS ILLICIT DISCHARGES. OUR FOCUS TODAY IS HOW TO IDENTIFY, CORRECT AND PREVENT THEM.

BACKGROUND: STORMWATER AND REGULATIONS

• THE FEDERAL CLEAN WATER ACT ADDRESSES WATER POLLUTION (AND THEREFORE STORMWATER)

• THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) REGULATES “POINT SOURCE DISCHARGES” OF STORMWATER TO WATERS OF THE U.S.

• IN 1999, FEDERAL REGULATIONS EXTENDED COVERAGE OF THE NPDES PROGRAM TO MUNICIPAL SEPARATE STORM SEWER SYSTEMS (MS4’S)

• UNDER THESE REGULATIONS, MILLERSVILLE BOROUGH IS AN MS4 COMMUNITY, AND IS REQUIRED TO OBTAIN AN NPDES PERMIT FOR THEIR STORMWATER DISCHARGES

• AS PART OF THIS NPDES STORMWATER PROGRAM, THE BOROUGH IS REQUIRED TO DEVELOP A STORMWATER MANAGEMENT PROGRAM

BACKGROUND: WHAT IS AN MS4?

THE EPA DEFINES AN MS4 AS A CONVEYANCE OR SYSTEM OF CONVEYANCES THAT IS:

• OWNED BY A STATE, CITY, TOWN, VILLAGE, OR OTHER PUBLIC ENTITY THAT DISCHARGES TO WATERS OF THE U.S.;

• DESIGNED OR USED TO COLLECT OR CONVEY STORMWATER (INCLUDING STORM DRAINS, PIPES, DITCHES, ETC.);

• NOT A COMBINED SEWER; AND

• NOT PART OF A PUBLICLY OWNED TREATMENT WORKS (SEWAGE TREATMENT PLANT).

STORMWATER MANAGEMENT PLAN

THE SIX MINIMUM CONTROL MEASURES (MCMS) REQUIRED UNDER THE STATE’S GENERAL NPDES PERMIT FOR MS4 COMMUNITIES INCLUDE:

• MCM#1: PUBLIC EDUCATION AND OUTREACH

• MCM#2: PUBLIC INVOLVEMENT/PARTICIPATION

• MCM#3: ILLICIT DISCHARGE DETECTION AND ELIMINATION

• MCM#4: CONSTRUCTION SITE STORMWATER RUNOFF CONTROL

• MCM#5: POST-CONSTRUCTION STORMWATER MANAGEMENT IN NEW AND RE-DEVELOPMENT ACTIVITIES

• MCM#6: POLLUTION PREVENTION/GOOD HOUSEKEEPING

EACH MCM HAS A NUMBER OF REQUIRED BEST MANAGEMENT PRACTICES (BMPS)

WHAT IS AN ILLICIT DISCHARGE?

AN ILLICIT DISCHARGE IS DEFINED AS:

“…ANY DISCHARGE TO THE MUNICIPAL SEPARATE STORM SEWER SYSTEM THAT IS NOT COMPOSED ENTIRELY OF STORM WATER.” (WITH SOME EXCEPTIONS)

THESE DISCHARGES ARE CONSIDERED “ILLICIT” BECAUSE THE MS4 IS NOT DESIGNED TO ACCEPT, PROCESS OR DISCHARGE NON-STORMWATER FLOWS

COMMON ILLICIT DISCHARGES: OILS/VEHICLE FLUIDS

COLOR: RAINBOW SHEEN THAT TENDS TO SWIRL WHEN DISTURBED.

ODOR: MAY HAVE PETROLEUM OR GASOLINE SMELL

COMMON ILLICIT DISCHARGES: GREASE

COLOR: YELLOW, BROWN

ODOR: STALE GREASY SMELL, PETROLEUM,

APPEARANCE: MATERIAL TYPICALLY CLUMPS/STRINGS TOGETHER

COMMON ILLICIT DISCHARGES: SEDIMENT

COLOR: ORANGE, YELLOW, RED, “CHOCOLATE MILK”ODOR: NONEAPPEARANCE: WATER CAN BE VERY TURBID, MAY NOT BE ABLE TO SEE BOTTOM OF STREAM

COMMON ILLICIT DISCHARGES: SEWAGE

COLOR: GREY

ODOR: STRONG SEWAGE SMELL, SULFUR, FECAL MATTER

APPEARANCE: FOAM, BUBBLES, FOOD WASTES, TOILET PAPER, ETC.

COMMON ILLICIT DISCHARGES: SOAPS/DETERGENTS

COLOR: MILKY WHITE, GREY, CLOUDY

ODOR: FRAGRANCE LIKE LAUNDRY DETERGENT/SOAPS, OR NONE AT ALL

APPEARANCE: BUBBLES, FOAM, HIGHLY TURBID

COMMON ILLICIT DISCHARGES: LAWN CLIPPINGS/LEAF DEBRIS

ADDITIONAL COMMON ILLICIT DISCHARGES

• PAINT

• PET WASTE

• PESTICIDES, HERBICIDES, FERTILIZERS

• CHLORINATED SWIMMING POOL WATER

ALLOWABLE DISCHARGES• SOME NON-STORMWATER DISCHARGES ARE ALLOWED UNDER THE BOROUGH’S STORMWATER

MANAGEMENT ORDINANCE (SWMO) § 315-81D) AND ARE THEREFORE NOT ILLICIT DISCHARGES:

• DISCHARGES FROM FIREFIGHTING ACTIVITIES

• AIR-CONDITIONING CONDENSATE.

• SPRINGS.

• LAWN WATERING.

• DECHLORINATED SWIMMING POOL DISCHARGES.

• WATER FROM INDIVIDUAL RESIDENTIAL CAR WASHING.

• ROUTINE EXTERNAL BUILDING WASH DOWN (WHICH DOES NOT USE DETERGENTS OR OTHER COMPOUNDS).

• OTHER DISCHARGES APPROVED BY THE BOROUGH

HOW DO ILLICIT DISCHARGES OCCUR?

•PROHIBITED CONNECTIONS

• FAILING TREATMENT SYSTEMS (EX. SEPTIC SYSTEMS)

• ILLEGAL DUMPING

• LEAKING FACILITIES (DUMPSTERS, TANKS)

• SPILLS

MORE INDIRECT CAUSES OF ILLICIT DISCHARGE:

• LANDSCAPING/GROUNDS CARE

• SEDIMENT RUNOFF

• AGRICULTURAL RUNOFF (PESTICIDES AND FERTILIZERS)

PROHIBITED CONNECTIONS: SWMO

• THE BOROUGH’S SWMO DEFINES PROHIBITED CONNECTIONS (§315.81):

• (1) ANY DRAIN OR CONVEYANCE, WHETHER ON THE SURFACE OR SUBSURFACE, THAT ALLOWS ANY NON-STORMWATER DISCHARGE INCLUDING SEWAGE, PROCESS WASTEWATER, AND WASH WATER TO ENTER A MUNICIPAL SEPARATE STORM SEWER (IF APPLICABLE), OR WATERS OF THIS COMMONWEALTH, AND ANY CONNECTIONS TO THE STORM SEWER FROM INDOOR DRAINS AND SINKS; AND

• (2) ANY DRAIN OR CONVEYANCE CONNECTED FROM A COMMERCIAL OR INDUSTRIAL LAND USE TO THE MUNICIPAL SEPARATE STORM SEWER (IF APPLICABLE) WHICH HAS NOT BEEN DOCUMENTED IN PLANS, MAPS, OR EQUIVALENT RECORDS, AND APPROVED BY THE BOROUGH.

HOW ARE POTENTIAL ILLICIT DISCHARGES DISCOVERED?

• CITIZEN REPORTING *

•OUTFALL INSPECTIONS *

•OTHER AGENCY REPORTING

CITIZEN REPORTING

CITIZENS ARE OFTEN THE FIRST TO OBSERVE AN EVENT THAT MAY LEAD TO AN ILLICIT DISCHARGE. IT IS IMPORTANT THAT THEY CAN EASILY REPORT THESE CONCERNS DIRECTLY TO THE BOROUGH.

• CALLING THE BOROUGH’S MAIN OFFICE NUMBER AND EITHER SPEAKING TO SOMEONE OR LEAVING A MESSAGE

• HAVING A WAY TO REPORT A CONCERN ONLINE (EMAIL ADDRESS, LINK)

HOW TO HANDLE A CITIZEN COMPLAINT

WHEN A CALL IS RECEIVED TRY TO GET AS MUCH INFORMATION AS POSSIBLE:

SOME KEY QUESTIONS TO ASK:

WHERE DID IT OCCUR?WHEN DID IT OCCUR?

IS THERE A NOTICEABLE ODOR?IS THERE A NOTICEABLE COLOR/SHEEN?

REFER INQUIRIES TO THE PUBLIC WORKS DIRECTOR FOR INVESTIGATION

OUTFALL INSPECTIONS

• ROUTINE OUTFALL INSPECTIONS CAN OFTEN REVEAL ILLICIT DISCHARGES

• THE INSPECTIONS CHECK FOR THE FOLLOWING GENERAL PARAMETERS:• DRY WEATHER FLOWS• HIGH TURBIDITY• STRONG ODORS• UNUSUAL COLORS• FLOATING OR SUBMERGED SOLIDS• DEPOSITS/STAINS• ABNORMAL VEGETATION

IF INSPECTION STAFF ENCOUNTER A DISCHARGE THAT POSES AN IMMEDIATE HEALTH AND SAFETY THREAT TO THE PUBLIC DURING INSPECTION ACTIVITIES, THE PROBLEM WILL BE IMMEDIATELY REFERRED TO DEP EMERGENCY RESPONSE.

OUTFALL INSPECTIONS: PRIORITY AREAS

• THE BOROUGH MUST MAINTAIN AND UPDATE A LIST OF “PRIORITY AREAS”: AREAS WITH A HIGHER LIKELIHOOD OF ILLICIT DISCHARGES, ILLEGAL CONNECTIONS, AND/OR ILLEGAL DUMPING. THESE CAN INCLUDE:

• AREAS WITH OLDER INFRASTRUCTURE

• A CONCENTRATION OF HIGH RISK ACTIVITIES

• PAST HISTORY OF WATER POLLUTION

THESE AREAS SHOULD INSPECTED ANNUALLY.

INVESTIGATION PROCEDURES

• AFTER A COMPLAINT IS RECEIVED OR AN INSPECTION REVEALS A POTENTIAL ILLICIT DISCHARGE, AN INVESTIGATION WILL BE INITIATED

• AN INVESTIGATION CAN INCLUDE ANY OR ALL OF THE FOLLOWING:• REVIEW OF CURRENT OUTFALL AND STORM SEWER MAPS

• REVIEW OF PAST INVESTIGATIONS/INSPECTION REPORTS (IF ANY)

• SITE VISIT:

• SAMPLING OF ANY FLOWS

• “TRACING THE SOURCE”

• STORM DRAIN NETWORK INVESTIGATIONS

• DRAINAGE AREA INVESTIGATIONS

INVESTIGATION PROCEDURES

• RECORD KEEPING IS EXTREMELY IMPORTANT!! BE SURE TO DOCUMENT AND SAVE EVERYTHING INCLUDING:

• CITIZEN COMPLAINT ILLICIT DISCHARGE FORM

• RESPONSE FORM (IN IDDE PROGRAM)

• FIELD/INSPECTION NOTES

• LAB RESULTS

• CORRESPONDENCE (MAIL, EMAIL, PHONE LOGS)

• PROOF OF CORRECTED PROBLEM

• ANY ADDITIONAL INFO

FOLLOW UP ACTIONS

WHEN THE CAUSE OF THE ILLICIT DISCHARGE IS DISCOVERED, CORRECTIVE ACTIONS SHOULD TAKE PLACE INCLUDING:

• NOTIFYING THE PROPERTY OWNER OR OPERATOR OF THE PROBLEM, AND PROVIDING THE APPROPRIATE EDUCATIONAL MATERIALS AND/OR A COPY OF THE IDDE ORDINANCE

• FOCUS FIRST ON EDUCATION TO PROMOTE VOLUNTARY COMPLIANCE AND ESCALATE TO INCREASINGLY SEVERE ENFORCEMENT ACTIONS IF VOLUNTARY COMPLIANCE IS NOT OBTAINED.

WHAT WOULD YOU DO?

A CALL IS RECEIVED CLAIMING THAT A STREAM IN THE BOROUGH HAS A STRONG SULFUR SMELL AND A BUBBLY/FOAMY APPEARANCE. THE AREA IS IN THE VICINITY OF SEVERAL BOROUGH STORMWATER OUTFALLS.

WHAT WOULD YOU DO NEXT?

WHAT WOULD YOU DO?

1. THE PERSON RECEIVING THE CALL SHOULD GATHER AS MUCH INFORMATION AS POSSIBLE AND FORWARD TO THE PUBLIC WORKS DIRECTOR.

2. THE INVESTIGATION SHOULD INCLUDE A SITE VISIT, SAMPLING AND A STORM DRAIN NETWORK INVESTIGATION (TO SEARCH FOR ILLICIT CONNECTIONS).

3. ENFORCEMENT ACTIONS SHOULD TAKE PLACE TO CORRECT THE PROBLEM.

4. BASED ON FINDINGS, A CALL TO DEP MAY BE NECESSARY.

WHAT WOULD YOU DO?

THE SITUATION ON THE LEFT WAS SPOTTED ON BOROUGH PROPERTY. A STORM SEWER INLET IS LOCATED NEARBY IN THE PATH OF THE FLOW FROM THE DUMPSTER.

• WHAT ARE THE NEXT STEPS?

WHAT WOULD YOU DO?

• CONTACT THE PUBLIC WORKS DEPARTMENT IMMEDIATELY TO INITIATE THEIR CLEAN UP PROCEDURES

• THIS SHOULD INCLUDE CLEAN UP AND PROPER DISPOSAL OF THE FLUIDS AND AN INSPECTION OF THE DUMPSTER TO DETERMINE THE CAUSE OF THE LEAK

• THE FACILITY SHOULD BE REPAIRED OR REPLACED BEFORE IT IS USED AGAIN.

WHAT WOULD YOU DO?

• AN OUTFALL INSPECTION REVEALED AN OUTFALL WITH “CHOCOLATE MILK” COLORED FLOW.

WHAT WOULD YOU DO?

1. THE INSPECTOR SHOULD PHOTOGRAPH THE PROBLEM AREA AND CONDUCT A QUICK VISUAL INSPECTION OF THE SURROUNDING AREA TO IDENTIFY ANY OBVIOUS POLLUTION SOURCES.

3. A DRAINAGE AREA INVESTIGATION SHOULD BE CONDUCTED TO “TRACE THE SOURCE”

4. ENFORCEMENT ACTIONS SHOULD TAKE PLACE TO CORRECT THE PROBLEM.

5. BASED ON FINDINGS, A CALL TO DEP MAY BE NECESSARY.

THE END

QUESTIONS?