session 3 outline what is a illicit storm water discharge? - potential sources what is required by...
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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?
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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.
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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
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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.
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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
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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
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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
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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
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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
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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
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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
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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
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Wrap UpWrap Up
Questions and
Answers
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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