IDDE From the Regulatory Perspective. Chris Kallis IEPA

Transcription

1 IDDE From the Regulatory Perspective Chris Kallis IEPA

2 What is an Illicit discharge? A discharge to an MS4 that is not composed entirely of storm water Exceptions: NPDES Permitted discharges Discharges from fire fighting activities Listed discharges provided that they have been determined not to be a substantial contributor of pollutants

3 IDDE Characteristics Unique frequency, composition & mode of entry Can be an interaction of the sewage disposal system and the storm drain system Produced from generating sites

4 Discharge Frequency Continuous Discharges Always occurring Intermittent Discharges Occurring occasionally Transitory Discharges Singular events such as industrial spills, ruptured tanks, sewer breaks, transport accidents, illegal dumping, etc.

5 Illicit Discharge Examples Industrial wastewater Liquid wastes such as wash water Sewage Septage Contaminated groundwater

6 Modes of Entry Direct entry Sewage, industrial and commercial cross connections Straight Pipe Indirect entry Groundwater seepage Spills and overflows Dumping

7 Potential Generating Sites Residential Commercial Industrial Institutional Municipal

8 Possible Water Quality Violations Dissolved Oxegon ph Fecal Coliform Heavy Metals Offensive Conditions and Unnatural Sludge Substances that can cause acute and/or chronic toxicity

9 NPDES Permit Requirements Legal Authority Mapping Field Screening Investigation Spill Response and Prevention Proper Management of Used Oils and Toxics Prevention of Sanitary Discharges Education and Training

10 Authority An ordinance must be in place to prohibit illicit discharges and dumping to the MS4 Exclusions must not conflict with permit requirements Enforcement mechanisms should be authorized An Enforcement Escalation Plan should be developed

11 Mapping Must have a map of the storm drain system showing locations of drains pipes, inlets, outfall and structural storm water controls. Map should be readily available to personal who would respond to an illicit storm discharge incident

12 Field Screening Field screening areas must be identified, prioritized and evaluated Outfalls must be inspected during dry weather to identify any non storm water discharge Monitoring of dry weather discharges should include more than just visual observation A database should be established to track locations of illegal discharges, spills and dumping

13 Investigation Written procedures should be in place for tracing active illicit discharges Proper equipment such as videotape should be available Investigations should be tracked An Enforcement Response Plan should be adopted Abatement and clean up costs should be part of ordinance.

14 Spill Response and Detection The Village should have a clear set of procedures detailing responsibility in responding to spills Spills should be tracked and added to a database Inspections of industries should include evaluations of Spill Prevention and Control Plans

15 Public Awareness and Reporting Outreach material should be available to public to encourage reporting of illicit discharges and dumping. A hotline number is helpful Complaints and calls should be tracked Prioritization of educational efforts should be based on frequency and types of complaints in areas within the MS4

16 Proper Management of Used Oil and Toxics Educational materials should facilitate proper management of automotive waste and toxic materials such as household hazardous wastes. A recycling and collection facility is helpful Evaluation of the permittee s own housekeeping procedures should be part of the public works pollution prevention program

17 Sanitary Discharges Evaluation should be made to determine whether sanitary sewers are contributing to contaminants in the storm sewer Both sanitary sewer overflows and cross connections should be evaluated The extent of inflow and infiltration as a major impact should be studied Evaluate the possibility of septic tank seepage field impacts

18 Education and Training Insure that all applicable staff be trained on spill response and IDDE Insure that the NPDES Permit 24 hour reporting requirements are complied with on any discharge which may endanger the health of the environment

19 The Big Picture

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31 Questions?