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?
Permit Definition: “…any discharge to an MS4 that is not composed entirely of storm water…” What is a Illicit “Storm Water” Discharge? • 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.
What is required by the permit? Permit Requirement: Develop, implement and enforce a program to detect and eliminate illicit discharges. Flooding and Uncontrolled Storm Water Run-off Contrary to popular belief this is not a BMP
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
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
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
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 Data collection and Tracking and Reporting Program Objectives and Budget issues Outfall & HSTS Inventory
Session 3 Review • 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 Do’s and Don’ts