City of Grand Junction Illicit Discharge Detection and Elimination Manual
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1 City of Grand Junction Illicit Discharge Detection and Elimination Manual A. IDDE Program Goals The goal of the Illicit Discharge Detection and Elimination (IDDE) Program is, to the maximum extent practicable, to reduce the frequency and environmental impact of illicit discharges in which pollutants are intentionally or accidentally discharged into the storm sewer system as required by the Colorado Department of Health and Environment (CDPHE). B. Permit Requirements The City of Grand Junction must develop, implement and enforce a program to detect and eliminate illicit discharges into the City s storm sewer and waters of the state. Illicit discharges do not include discharges or flows from emergency fire fighting activities, or other activities specifically authorized by a separate Colorado Discharge Permit System (CDPS) permit. The permittee must: 1) Develop and maintain a current storm sewer system map, showing the location of all municipal storm sewer outfalls and the names and locations of all state waters that receive discharges from those outfalls. 2) To the extent allowable under State or local law, effectively prohibit, through ordinance or other regulatory mechanism, illicit discharges (except those identified in subparagraph 5 and 6 of this section) into the storm sewer system, and implement appropriate enforcement procedures and actions. 3) Develop, implement, and document a plan to detect and address non-storm water discharges, including illicit discharges and illegal dumping, to the system. The plan must include the following three components: procedures for locating priority areas likely to have illicit discharges, including areas with higher likelihood of illicit connections; procedures for tracing the source of an illicit discharge; and procedures for removing the source of the discharge. 4) Develop and implement a program to train municipal staff to recognize and appropriately respond to illicit discharges observed during typical duties. The program must address who will be likely to make such observations and therefore receive training, and how staff will report observed suspected illicit discharges. 5) Address the following categories of non-storm water discharges or flows (i.e., illicit discharges) only if the permittee identifies them as significant contributors of pollutants to the permittee s MS4: landscape irrigation, lawn watering, diverted stream flows, irrigation return flow, rising ground waters, uncontaminated ground water infiltration (as defined at 40 CFR (20)), uncontaminated pumped ground water, springs, flows from riparian habitats and wetlands, water line flushing, discharges from potable water sources, foundation drains, air conditioning condensation, water from crawl space pumps, footing drains, individual residential car washing, dechlorinated swimming pool discharges, and water incidental to street 1
2 sweeping (including associated sidewalks and medians) and that is not associated with construction. The permittee may also develop a list of occasional incidental non-storm water discharges similar to those in the above paragraph, (e.g., non-storm water commercial or charity car washes, etc.) that will not be addressed as illicit discharges. These nonstorm water discharges must not be reasonably expected (based on information available to the permittee) to be significant sources of pollutants to the MS4, because of either the nature of the discharges or conditions the permittee has established for allowing these discharges to the MS4 (e.g., a charity car wash with appropriate controls on frequency, proximity to sensitive water bodies, BMPs, etc.). The permittee must document in their program any local controls or conditions placed on the discharges. The permittee must include a provision prohibiting any individual nonstorm water discharge that is determined to be contributing significant amounts of pollutants to the MS4. 6) The following sources are excluded from the prohibition against non-storm water discharges and the requirements of subsections (2) and (3) above: i) Discharges resulting from emergency fire fighting activities. Such discharges are specifically authorized under this permit (see Part I.A.2). ii) Discharges specifically authorized by a separate CDPS permit. C. Illicit Discharges Definition: An illicit discharge is defined as any discharge to a storm drain system that is not composed entirely of uncontaminated storm water, except discharges pursuant to a CDPS/NPDES permit, discharges resulting from emergency fire fighting activities, and discharges further exempted by the City s storm water ordinance. (See Exemptions below) No person shall release or cause to be released into the storm drainage system any discharge that is not composed entirely of uncontaminated storm water, except as allowed in the Exemptions section of this document. Common storm water contaminants which cannot be released into the storm drainage system include herbicides and lawn chemicals, construction debris and wastes, wastewater, oil, petroleum products, cleaning products, paint products, hazardous waste, sediment, dirt and other toxic substances, including substances defined as pollutants. Exemptions: The following non-storm water discharges are not a violation of the storm water ordinance. 1. Intermittent uncontaminated discharge from landscape irrigation, lawn watering, or irrigation return flows. 2. Uncontaminated discharge from foundation, footing or crawl space drains and sump pumps. (Commercial air conditioning condensation and commercial cooler drains shall be discharged to the sanitary sewer system only.) 2
3 3. Uncontaminated groundwater, including rising groundwater, groundwater infiltration into storm drains, pumped groundwater and springs. 4. Diverted stream flows and natural riparian habitat or wetland flows. 5. Uncontaminated discharges from the occasional charity washing of vehicles or occasional not-for-profit car washing events. 6. Dechlorinated and uncontaminated swimming pools and hot tubs may be drained to the storm drain system. Swimming pool and hot tub drainages may be drained to the sanitary sewer without dechlorination. 7. Discharges approved by the City Manager as being necessary to protect public property and/or public health and safety, such as flows from emergency fire fighting. 8. Waterline flushing and other infrequent discharges from potable water sources and waterline repair work as necessary to protect public health and safety. 9. Water incidental to street sweeping that is not associated with construction. 10. City activities as determined necessary by the City Manager, such as spring cleanup and fall leaf pickup programs. The intent of these activities is to reduce pollution in the storm drainage system. For this exemption to apply, participants must comply with the directions and specified time frame determined by the City Manager. 11. A discharge authorized by and in compliance with a CDPS or National Pollutant Discharge Elimination System (NPDES) permit, other than CDPS permit from the municipal separate storm sewer system. This type of discharge must receive advance approval by the City before the CDPS permit can be issued. Low Risk Discharges: Discharges of Potable Water Discharges of potable water are a type of industrial activity with short term infrequent discharges that with proper management are not expected to contain pollutants in concentrations that are toxic or in concentrations that would cause or contribute to a violation of a water quality standard. The typical pollutant of concern is total residual chlorine, however, depending on how the discharge occurs, total suspended solids and oil and grease may become pollutants of concern. These pollutants can be handled using dechlorination techniques, filters, oil booms, and other best management practices (BMPs). The following conditions must be strictly followed by anyone discharging potable water: The discharge of cleaning materials or chemicals, including dyes, is strictly prohibited, and should be sent to the sanitary sewer, with permission of the local wastewater treatment facility, or otherwise collected and disposed of. The potable water shall not be used in any additional process. Processes include, but are not limited to, any type of washing, heat exchange, manufacturing, and hydrostatic testing of pipelines not associated with treated water distribution systems. The discharge shall be from a potable water distribution system, tank or storage that has been maintained for potable water distribution use. Discharges from a 3
4 distribution system, tank or storage that is used for conveyance or storage of materials other than potable water is not authorized under this policy. The discharge shall not cause erosion of a land surface. The discharge shall not contain solid materials in concentrations that can settle to form bottom deposits detrimental to the beneficial uses of the state waters or form floating debris, scum, or other surface materials sufficient to harm existing beneficial uses. All discharges must comply with the lawful requirements of federal agencies, municipalities, counties, drainage districts, ditch owners, and other local agencies regarding any discharges to storm drain systems, conveyances, ditches or other water courses under their jurisdiction. o The guidance included in this document in no way reduces the existing authority of the owner of a storm sewer, ditch owner, or other local agency, from prohibiting or placing additional conditions on the discharge. If the discharge is directly to a State surface water (any stream, creek, gully, whether dry or flowing), it must not contain any residual chlorine. The operator is responsible for determining what is necessary for removing chlorine from the discharge. If the discharge is to a ditch, chlorine content may be limited by the owner of the ditch. However, if the ditch returns flow to classified state waters, it must not contain any residual chlorine at the point where it discharges to the classified state water. BMPs should be implemented as necessary to meet the conditions above, by anyone discharging potable water. These BMPs have been developed by CDPHE to help ensure that the discharge will not negatively affect water quality. For discharge to the ground, the water should not cause any toxicity to vegetation. When discharging, allow the water to drain slowly so that it soaks into the ground as much as possible. If discharge is to the sanitary sewer, contact the local wastewater treatment facility prior to discharge. System owners may grant blanket authorization to discharge to their systems. This must be done to ensure that the facility is able to accept the discharge. Not all facilities are able to accept such discharges. Note that additional restrictions or local guidelines may apply. Removal of any residual chlorine must be done for any direct discharge to state surface waters, or for any discharge to a storm sewer or conveyance where the chlorine will not dissipate prior to reaching a state surface water. Dechlorination, if necessary, may be achieved by allowing water to stand uncovered until no chlorine is detected, or by dechlorination using a portable dechlorinator. Pay particular attention when handling super-chlorinated waters. A longer time is needed to dissipate chlorine from super-chlorinated waters. The discharge should be conducted to minimize the potential to pick up additional suspended solids. When possible, a best management practice, or combination of practices, for filtering or settling suspended solids and other debris, or a combination of practices, should be used to remove suspended solids or other debris. Examples of suspended solid removal practices include, but are not limited 4
5 to check dams, filter bags, and inlet protection. These devices should be used and maintained in accordance with the manufacturers specifications. The discharge should be conducted to minimize the potential that it will not pick up any oil and grease. When possible, an absorbent oil pad, boom or similar device should be used to eliminate oil from the discharge. Discharges from Surface Cosmetic Power Washing Operations to Land (See City of Grand Junction, Pressure Washing Guidelines) D. IDDE Program Measures Outfall Map: The first major component of the City s illicit discharge program is the GIS mapping of the municipal storm water drainage system. Maintaining an accurate map of the storm water drainage system will make it easier for the City to track and locate the source of suspected illicit discharges. Included in this map are the delineation of drainage basins located within the City, locations of the storm system outfalls, receiving waters, storm system infrastructure (which provides direction of flow), structural BMP s and natural drainage channels and their tributaries. The City of Grand Junction began work on the GIS project in The project s coverage area was established at the city limits as of July 1990 with an area of 14.9 square miles. The project s coverage area is currently defined as the 201 sewer service boundary with a 65.4 square mile area. GIS data is accessible by City staff through the GIS web site, which consists of five custom maps with three hundred and eighty two unique layers. The GIS allows us to view, understand, question, interpret, and visualize data in many ways that reveal relationships, patterns, and trends in the form of maps, reports, and charts. Multiple map layers have basic database information attached to them and can be viewed queried by themselves or in conjunction with other layers. Grand Junction is in a continual process of updating its GIS storm drainage infrastructure map through as-built drawings and field surveys in order to trace illicit discharges. Regulatory Mechanism: The Grand Junction Storm Water Pollution Prevention Ordinance, Municipal Code , was adopted in January The ordinance prohibits illicit discharges to the storm drain system and grants inspection and enforcement authority to Grand Junction staff. The ordinance provides the flexibility for retrospective enforcement of violations to the initial date of discharge or discovery. The ordinance provides for issuance of compliance advisories, notices of violation, cease and desist orders, stop work orders, administrative fine orders and administrative citations. The Streets Systems Division addresses all illicit discharge complaints, initiates enforcement measures, and documents complaints, response and problem resolution in our database. The Code Enforcement Division is responsible for issuing administrative fine orders and citations as necessary. 5
6 A. Enforcement Investigation The City has the authority to conduct storm water inspections at commercial and industrial facilities and residential facilities (property owners association detention ponds) and to require implementation of best management practices (BMP s) where appropriate. Any violation of the storm water ordinance reported to or discovered by City staff shall be investigated. Throughout the course of the investigation, City storm water staff is granted the authority to sample, photograph, perform interviews and access any facility or area within the premises that may have any effect on the alleged violation. In the event that the owner or occupant refuses entry after a request has been made, contact the City Attorney s office for assistance. B. Enforcement Process 1. When it is determined that a violation of the storm water ordinance has occurred, an enforcement order shall be issued to the responsible party. 2. Within the specified time frame after the date of issuing the compliance advisory or notice of violation, the responsible party must provide evidence of the satisfactory correction of the violation. 3. If satisfactory correction of the violation is not achieved, the responsible party may be served with a stop work or cease and desist order, and/or an administrative citation, and/or an administrative fine order. Administrative citations and administrative fine orders are issued by the Code Enforcement Division. 4. If the property owner is not available or willing to correct the violation, the City may be required to take any and all measures necessary to abate the violation. When this occurs, it is necessary to accurately document all expenses related to the abatement for reimbursement by the property owner. C. Appeals 1. The person or business responsible for an alleged violation may appeal any decision, action, enforcement document or determination made by City staff. 2. The conditions of the decision, action, enforcement document or determination will remain in effect and are enforceable during the appeal process. Illicit Discharge Detection and Elimination Plan: A. Locating areas likely to have illicit discharges: Grand Junction has identified the following priority areas: a) old commercial and industrial, b) old residential, c) new commercial and industrial, and d) new residential (listed in decreasing priority). Grand Junction relies on customer complaints, trail hosts and field staff to identify areas likely to have illicit discharges. The Grand Junction Streets Systems Division, 911 or 521 Drainage Authority Hotline is informed when an illicit discharge is identified. Grand Junction staff addresses and resolves illicit discharges in the Grand Junction city limits. B. Tracing the source of illicit discharges: 6
7 Sources of illicit discharges are traced using Grand Junction s GIS storm drainage infrastructure map and visual observations. Using the storm water GIS map layer which indicates direction of flow, City staff is able to trace illicit discharge pathways in the entire storm drain system. This will be utilized to enhance the efficiency of finding pollution sources and minimizing downstream impacts. Beginning at the discharge point of observation, staff will work upstream to isolate the location of the discharge. If unable to determine the point of discharge using visual observations, other methods including the use of dye and/or smoke, a sewer TV-truck or sampling may be necessary to determine the origin of the discharge. C. Removing the source of illicit discharges: The timeline of corrective action procedures is highly dependent on the nature of the violation and the responsiveness and cooperation from the person(s) responsible. The urgency of addressing identified problems will be based on the nature of the pollutant in question and potential impacts to downstream waters. Compliance dates should be included in all violation notices. Quick and efficient corrective action of illicit discharges is accomplished by a well defined regulatory mechanism coupled with effective enforcement and follow-up measures. Most illicit discharge events are transitory illegal dumping discharges. Corrective action for this type of discharge is spill containment and clean up procedures. (See the Storm Water Municipal Operations Manual, Spill Prevention and Response Plan, Section 3.9.3) Spill containment and clean up is followed by evaluating the actions that caused the spill and amending any processes necessary to prevent future spills. Other illicit discharge corrective actions involve some form of infrastructure modification or repair. These structural repairs are used to eliminate a wide variety of direct discharges such as private floor drains, sewage cross-connections, and industrial and commercial cross-connections. Fixes range from simple plumbing to excavation and replacement of sewer lines. Removal and correction of a discharge or connection should be confirmed both at the source, to ensure that the correction has been made, and downstream, to ensure that it was the only local discharge present. For discharges resulting from internal plumbing and lateral connections, dye testing can confirm the correction. The correction of discharges resulting from some sort of infrastructure failure in either the sanitary sewer or MS4 can be verified by dye testing or TV ing the line. Staff Education: All Grand Junction field staff (Public Works and Planning, Utilities and Street Systems Departments) are trained to identify and respond to illicit discharges through an internal training classroom program coordinated with the 521 Drainage Authority. 7
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