Illicit Discharge Detection and Elimination
Finding everything that’s not stormwater
Tuesday, May 31, 2011
By Steve Goldberg
“Illicit discharges,” according to the EPA, “are generally any discharge into a storm drain system that is not composed entirely of stormwater. The exceptions include water from fire fighting activities and discharges from facilities already under NPDES permit.” EPA further explains, “Illicit discharges are a problem because, unlike wastewater which flows to a wastewater treatment plant, stormwater generally flows to waterways without any additional treatment.
“Illicit discharges enter the system through either direct connections (e.g., wastewater piping either mistakenly or deliberately connected to the storm drains) or indirect connections (e.g., infiltration into the MS4 from cracked sanitary systems, spills collected by drain outlets, or paint or used oil dumped directly into a drain). The result is untreated discharges that contribute high levels of pollutants,
including heavy metals, toxics, oil and grease, solvents, nutrients, viruses, and bacteria to receiving waterbodies. Pollutant levels from these illicit discharges have been shown in EPA studies to be high enough to significantly degrade receiving water quality and threaten aquatic, wildlife and human health.”
To illustrate the possible scope of the problem, a Sacramento, CA, study from the late 1980s demonstrated that nearly half of the water discharged from a local MS4 did not originate from precipitation runoff. The study concluded that “A significant portion of these dry weather flows were from illicit and/or inappropriate discharges and connections to the MS4.”
Illicit discharge detection and elimination (IDDE) is one of the six minimum control measures central to the NPDES Phase II regulations. Every permittee must develop, implement, and enforce an IDDE program, which is to include the following elements:
- A storm sewer system map, showing the location of all outfalls and the names and location of all waters of the United States that receive discharges from these outfalls;
- Through an ordinance, or other regulatory mechanism, a prohibition (to the extent allowable under state, tribal, or local law) on non-stormwater discharges into the MS4, and appropriate enforcement procedures and actions;
- A plan to detect and address non-stormwater discharges, including illegal dumping, into the MS4;
- The education of public employees, businesses, and the general public about the hazards associated with illegal discharges and improper disposal of waste;
- The determination of appropriate best management practices (BMPs) and measurable goals for this minimum control measure.
A wide variety of activities can produce illicit discharges, including:
- washdown of greasy equipment and grease traps
- power washing of buildings and parking lots
- dumping and spills
- outdoor material and fluid storage
- road maintenance
- driveway cleaning
- septic system maintenance
- swimming pool discharges
However, not all illicit discharges need to be addressed, as long as they are not identified as significant sources of pollutants. For example, these might include:
- water line flushing
- landscape irrigation
- discharges from potable water sources
- foundation drains
- air-conditioning condensation
- uncontaminated groundwater infiltration
- street wash water
A model program instituted by Wayne County, MI, prioritized various business sectors, in order of the likelihood of producing illicit discharges. Businesses categorized as Priority 1 include automobile-related businesses and heavy manufacturing. Priority 2 businesses include printers, dry cleaners and laundries, photo processors, utilities, paint stores, water conditioners, chemical laboratories, construction companies, and medium-light manufacturing facilities. Priority 3 businesses include institutional facilities, private service agencies, retail establishments, and schools.
Mount Pleasant, SC
“Just a bridge away from Charleston,” Mount Pleasant, SC is a beautiful community that has been growing by leaps and bounds. The 2005 estimate from the US Census Bureau indicates a population of 59,000, an increase of 24% from just five years earlier. As a result, Mount Pleasant is now the fourth largest city in South Carolina.
Employed by the city of Mount Pleasant for 15 years, Hillary Repik is the town’s stormwater manager within the Public Services Department. “I’m in charge of everything with stormwater maintenance, capital projects, budgeting, and NPDES compliance,” she says.
Although the typical Phase II permit is issued for a five-year period, Repik notes that this was not the case for her community. “In South Carolina, we had an appeal of our permit, and a delay. When it was finally issued, it was issued to us with a shortened compliance schedule. It went through an administrative law process. Once that permit was finalized and everybody was finally issued their certificates of compliance to begin work, it was a shortened permit term.
“In our case, our first permit term was about three years long, so we had a three-year orientation and ramp-up. Now we’re seeing the next permit with far more technical requirements and inspections, and doing a lot of other work. I sense that the EPA has learned from other communities that have been under the permit a little bit longer, and I gather also that there were communities that didn’t understand what to do before, so it’s being spelled out a little more explicitly, with some additional requirements.”
Although it was somewhat rudimentary, Mount Pleasant has had a stormwater program since well before the Phase II regulations existed. “We actually implemented our stormwater utility in 1996,” says Repik. “Our focus at the time was almost solely on flood control, so our utility was developed to get us some funding to take care of some repetitive flooding issues, to have a dedicated maintenance crew to go out and take care of repairs to the system, and do our ditch cleaning for our community rating system program.
“We did handle a few calls about people dumping in the ditches and handling water quality on a smaller, low-key level. At least when Phase II came about, we had a funding mechanism in place, and we had some staff available to begin to tackle some of the permit requirements and the different issues we faced. We already had that in place, so we weren’t going to fight the battle. What we were now going to figure out was how much more funding we need to run a water-quality program in addition to our flood control and general maintenance program.”
The town’s stormwater guidelines specifically address some of the concerns unique to Mount Pleasant:
“As a coastal community, the Town of Mount Pleasant recognizes that water quality is important to the quality of life of our residents. Residents enjoy the recreational aspects, aesthetic beauty, and seafood that our coastal area provides. Some illicit discharges from indirect connections or infiltration flows, such as infiltration of groundwater due to our high ground water table and our elevations running close to sea level, must be addressed and evaluated, as they can be difficult to prevent or control. Other illicit discharges such as direct connections will be found and removed as the program is developed and the detection activities are undertaken. The reduction of illicit discharges will help to improve not only the water quality but also the quality of life.”
To accomplish these goals, the guidelines specify actions to be developed and implemented over the permit term:
- Illicit discharge detection and elimination program
- Storm sewer map preparation and updating
- Ordinance review and updating for illicit and non-stormwater discharge activities
- Ordinance review of non-stormwater discharge and illegal dumping
- Detection and elimination prioritization plan
- Outfall inspections
- Public education on illicit discharges through the public education/outreach schedule
- Residential used oil recycling program
Funding comes in a variety of ways, Repik explains. “We have our dedicated stormwater utility, which usually is never enough, and we do get some additional assistance from the town’s general fund revenues. In some cases, they pay for other staff who work on NPDES-related activities but that may not be their specific job. I have a stormwater inspector who is not paid for by the utility, he’s paid for by the general fund.
“We can’t afford all the staff we are using as resources, and we can’t always do everything we’d like to do right away, so sometimes our general fund assists us with that. We talk to the county, and if the county can assist us, they come in and help us where they can. We have a pretty good setup going on locally.”
When it came time to prepare for Phase II regulations, Repik says, “The entire basis of Mount Pleasant’s program was to go in and look at what operations we currently did that we could turn around and ramp up for Phase II. So for illicit discharge detection, we already responded to citizen calls for issues and problems with the operation of the system.
“We have a video camera system that we use for doing internal video inspections of storm drainage pipes, and when we go in, we’re no longer just looking for faults in the pipe,” she continues. “If we see some type of a connection, whether a yard drain or something coming into the system, it draws a flag and then we follow up with the illicit discharge part of that process. It gets reported, and somebody goes back to check if it was a yard drain, or if there was encroachment, is it gray water, and then follows it to wherever it needs to be.
“If it’s enforcement that is necessary, then we enforce it. Usually, we can get people to remove the connections if we don’t want them.”
She says that overall, the program has been very successful, both at spotting illicit connections and at dealing with older parts of the system. “We are trying to also get some better equipment so we can see things more clearly and get into different sizes of pipes and look at other issues. But I think we’re on the track toward ramping up our program and being able to say, ‘This area of town is good,’ and unless somebody does something when we’re not looking, we’re okay. In some parts of town, we have older areas where the systems need to be cleaned out before we can know what’s going on.
The city is looking ahead at what the state permitting agency is proposing for the new NPDES permit. “What we’re really trying to evaluate is, are there areas where we have sort of tweaked our program and we’ve used our existing resources where that’s no longer going to be feasible? Will we have to say, ‘We can no longer have the crew that is one day fixing sinkholes, and the next day using the inspection camera, and the next day cleaning pipes.’ Is there going to have to be dedicated crew doing one task? And how much is that going to cost us? And what is our efficiency rate going to be? That’s our main concern right now. We’re looking at the ramp-up, how much time we are going to have to come into compliance with the new requirements.”
Repik mentions that in the IDDE effort, the “detection” part has not proven to be a major problem because the community already had some video inspections in place. However, she says, “The mapping part was definitely a major part of our stormwater effort. We didn’t have to increase our resources, but in the mapping side, we did have to go and get some outside assistance. We’re doing QAQC [quality assurance/quality control] of our map and getting those field inspections in, finding the outfall points and checking their status.”
EPA audited the city’s program within the past year, and Repik terms the audit both successful and helpful. “They thought we were doing a good job,” she says, “with only having a couple of people working on it full time. They encouraged us to get into the evaluation of the process a little bit more. We use their BMP toolbox, and look at their resources they have on the Web. We do participate in the NPDES listserv, to see what other folks around the country are doing. It’s a good resource for us.
“For all intents and purposes, we are acting by ourselves in the implementation of our program. Mount Pleasant is sort of a peninsula, almost an island. But we stay in very close communication with the surrounding jurisdictions. In fact, we have what we call our little MS4 group, and we will meet from time to time to talk about how we all are handling different program elements that come up. If somebody runs into an issue with one of the elements, we’ll sit around a round table and discuss it.”
After 15 years on the job, Repik has some advice for other communities that may be struggling with Phase II regulations. “I talk to a lot of the smaller communities who seem to struggle with understanding the permits and the requirements. Get the resources you need to understand, and take simple measures. You don’t always have to have the most expensive equipment, and you don’t always have to have the best consultants around. But if you can look internally at your processes, you may find that you’re actually doing a lot of things toward water quality already.
“To help keep costs low, our goal is to put the money back into actual operations out in the field, and not to spend it on lots of paperwork and lots of plans, but to actually turn it around and make those day-to-day differences out in the field.”
O’Fallon, MO
Located among the western suburbs of St. Louis, the town of O’Fallon, MO, is one of the fastest-growing communities in the state. The 2006 US Census estimate pegs the population of O’Fallon at 72,000, an increase of 48% from 2000.
According to Michele Gremminger, stormwater management coordinator for the community, the city’s initial Phase II permit was issued in 2002, and it are well into the second permit period now. She says that before the Phase II regulations, the O’Fallon stormwater program primarily consisted of “reactive responses to concerns brought to our attention. Maintenance of infrastructure and industrial waste permits were all handled by Alliance Water Resources, which was contracted to manage water, sewer, and storm issues for us.”
Currently, the O’Fallon stormwater program is funded via a half-cent parks and stormwater sales tax. It was passed by local voters in April of 2008 and is a shared tax with the Parks Department.
In October 2006, the city passed its Stormwater Quality Management and Illicit Discharge Control ordinance, a comprehensive set of regulations with three objectives:
- To regulate the contribution of pollutants to the MS4
- To prohibit illicit connections and illicit discharges to the MS4
- To establish legal authority to carry out all inspection, surveillance, and monitoring procedures necessary to ensure compliance
The ordinance allows the city to suspend MS4 discharge access to violators. It also provides for the installation of sampling and monitoring equipment by the city, as it deems necessary, although consent of property owners is required. However, if consent is not granted, the city maintains the right to seek an administrative search warrant in order to install equipment where there is reasonable concern about potential illicit discharges.
Asked how effective the ordinance has been, Gremminger says, “The illicit discharge ordinance has helped with illegal dumping and washing at commercial parking lots, as well as improved erosion and sediment control and vegetation practices on construction sites.”
O’Fallon administers its own stormwater program, but Gremminger notes, “We do collaborate with several neighboring communities on a regular basis to discuss what each of us is doing, bounce ideas off one another, share documents and information, and so on.”
As an example of this collaboration, she cites a recent Mission Clean Stream creek cleanup event. “In addition, we modeled the St. Charles County Land Disturbance Checklist. We share several public outreach brochures, and I have sent and received ordinance drafts or policy drafts for their review and comment as peers.”
She noted that to date, O’Fallon’s stormwater program has managed the minimum control measures without problems, with the exception of the IDDE measure. “We have approximately three-quarters of our system mapped and are beginning to prepare to map the rest,” she says. “We are also constantly evaluating our program to improve.”
She adds that implementation of Phase II requirements has not come without some difficulties with the local community. “As we are almost halfway into our second permit cycle and are more familiar with what is expected of us, I would say that there are things we could have done differently. The first five years of the program focused primarily on public education and outreach to bring attention to these new requirements, as well as getting our illicit discharge ordinance in place. It was new for us, and for developers, builders, contractors, the city council, and residents. It has been a learning curve for all with regards to compliance and what is expected.
“As a municipality, getting the minimum control measure [MCM] requirements of the permit in place has continued to be our main focus. Now that we are in this second permit cycle and most of our MCM requirements are in place, we can focus on our approach as well as continue to look for ways to improve permit compliance. We can also continue to grow our relationships and work closer with industry professionals and the general public by continuing to educate them when changes or additions to our program occur.”
Author's Bio:
Steve Goldberg writes on issues related to erosion control and the environment.
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