session 3 outline

Session 3 OutlineSession 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?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?

What is a Illicit “Storm Water” Discharge?

Home Sewer Treatment

System Discharge

Home Sewer Treatment

System Discharge

Home Sewer Treatment

System Discharge

• Bypass leach fields

• Non-maintained aeration systems

• Redirect outflow

Potential Sources of Illicit DischargesPotential 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?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?

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?

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?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?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?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 IdentificationInventory and Illicit Discharge Identification

Program ObjectivesIdentify

PrioritizeDocumentRemove

Follow up

Reporting/TrackingData collection protocol

Where and how will data be stored?What are others doing with data?

Program DecisionsBudget

ScheduleStaffing

Data Mgt.Tracking/Reporting

Session 3 ReviewSession 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

Outfall and HSTS Inventory

Program Decision points

Program Decision points

IDEP Program

Wrap UpWrap Up

Questions and

Answers

End of Session 3End of Session 3

Session 4 – Implementing

Construction/Post-

Construction Do’s and Don’ts

Session 4 – Implementing

Construction/Post-

Construction Do’s and Don’ts