Training Program Background

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2 Training Program Background The purpose of this presentation is to provide guidance for identifying and tracing illicit non-stormwater discharges into the City of St. Petersburg s separate stormwater sewer system (MS4).

3 Goals of Training Manual Provide field inspectors with : basic knowledge of stormwater management considerations the nature and characteristics of illicit discharges the procedures for tracing and documenting the sources of illicit discharges

4 Investigation Programs To satisfy permit requirements, the City has provided for four separate programs to detect and eliminate illicit discharges: Citizen Complaint Hotline Incident Reporting and Field Screening Field Screening Program Industrial Screening Program

5 Legal Authority The Final Rule requires permittees of municipal storm sewer systems (MS4) to prove that they have the authority to prohibit illicit discharges. St. Petersburg has such authority under the Environmental Protection Health and Sanitation Chapters of the City s Code (see Appendix B of your Training Manual).

6 The City s Storm Sewer System Defined as a medium MS4, serving a population of 100, ,000 people Contains 26 major drainage basins Primary land use within city limits is residential, with 5 drainage basins identified as industrial and/or commercial use Ultimate fate of stormwater is discharge into Tampa and Boca Ciega Bays

7 Allowable Discharges Water line flushing landscape irrigation diverted stream flows rising ground waters uncontaminated groundwater infiltration to separate storm sewers uncontaminated pumped groundwater

8 Allowable Discharges Discharges from potable water sources foundation drains air conditioning condensate irrigation water springs water from crawl space pumps footing drains

9 Allowable Discharges Lawn watering individual residential car washing flows from riparian habitats and wetlands dechlorinated swimming pool discharges street wash waters discharges from fire fighting activities

10 Illicit Discharges Defined as any flow to the storm sewer system that is not directly attributable to precipitation runoff draining from city surfaces Exceptions are the allowable discharges covered in the 3 proceeding slides Also known as dry-weather flow

11 Dry-Weather Discharge Sources Leaking or directly connected sanitary sewage Poorly operating septic tanks Wash waters from commercial and residential laundries Irrigation sources Automotive maintenance and operation sources

12 Dry-Weather Discharge Sources Construction dewatering Industrial process waters Spills Groundwater infiltration

13 Dry-Weather Discharge Sources Automotive and industrial process waters are the most significant sources of toxicants. Sanitary waste waters are most significant source of pathogens and nuisance contaminants Spills and disposal of household chemicals are generally low in volume

14 Residential Sources Nearly all of St. Pete s residences are connected to the sanitary sewer system, virtually eliminating septic tank effluent as a non-stormwater source to MS4 Some other sources may include improperly disposed household chemicals, sanitary wastewater, pool draining, and excess landscape watering

15 Industrial Sources Significant sources of industrial dry-weather discharge include: Cooling water Rinse water Process water Sanitary wastewater

16 Commercial Sources Businesses tend to be the most prevalent sources of dry-weather flows for the following reasons: Not traditionally seen as major polluters and are therefore not closely monitored Move frequently and are difficult to track Flows tend to be sporadic

17 Automotive Maintenance Largest single commercial source includes: Degreasing Car washing Radiator flushing Improper used oil disposal

18 Source Pathways Generally speaking, non-stormwater enters the MS4 through two pathways: direct connections and infiltration Often, direct connections are not authorized Infiltration is the most significant and least harmful source of dry-weather flows

19 Contaminant Categories Three general pollutant sources: Pathogenic or toxic Nuisance and aquatic life threatening Unpolluted water sources

20 Pathogenic or Toxic Pollutant Sources Most severe-can cause illness upon consumption, and can cause water treatment problems for the users downstream May originate from sanitary, commercial or industrial wastewater non-stormwater entrieresidential contributions from car degreasing, excessive fertilizer use, and inappropriate household chemical disposal

21 Nuisance and Aquatic Life Threatening Pollutant Sources Originate from residential lawn irrigation runoff, raw sanitary waste waters, laundry waste waters, construction site dewatering, washing of concrete trucks, and automobile wash waters. Causes dissolved oxygen depletion, algae blooms, coarse solids and floatables, and offensive colored, turbid, odorous waters

22 Field Investigations Initiated in two ways, hotline calls and informal field reports Proper field techniques in gathering data is critical!!!

23 Tracer Parameters Have the following desirable characteristics: Large difference in concentrations between possible pollutant sources Small variation in concentration within each likely pollutant source category Conservative constituents Ease of measure with proper detection limits, good sensitivity, and repeatability

24 IDSP Field Datasheets Utilize most common tracer parameters Outfall flow rates and noting presence of oil sheens, color, odors, floatables, etc are the most useful indicators of outfall problems

25 Physical Parameters Odor Color Turbidity (Clarity) Temperature Floatable matter Deposits and stains Vegetation Damage to structures

26 Chemical Parameters Specific Conductivity Fluoride Hardness Ammonia/Ammonium Potassium Surfactants and Fluorescence

27 Chemical Parameters ph Total available chlorine Toxicity screening tests Table 3-1 for typical tracer concentrations

28 Field Survey Preparation Main Elements: Hotline or field datasheets Maps

29 Field Sampling and Analysis Equipment Waterproof marker Camera & flashlight Spray paint Tape measure Watch (second hand) Sample Containers Ice box Two way radio Backpack Dipper on pole Hand pump Waders Walking stick First aid kit and knife Pepper spray Flat bottom boat

30 Safety Don t conduct surveys alone Wear waders in streams Wear life preservers in boats Beware of wildlife (alligators, water moccasins, rattlesnakes NEVER ENTER A CONFINED SPACE without following OSHA guidelines

31 Field Screening Investigation Approach Identify areas of illicit connections through field screening and Hotline calls Begin investigation where dry-weather flow indicates potential illicit connection Work in upstream direction to the source Once area is identified, land use and length of system must be determined

32 Field Screening Investigation Approach Collect water quality samples at evenly spaced intervals, moving upstream City Codes Chapter 14-5(d)(4) define proper sampling techniques for waste water and sedimentation collection Tracer parameters listed in Section 3.3 of training manual are recommended for laboratory analysis during initial screening phase

33 Tracer Parameters / EPA Recommended Methodologies Ammonia-Direct Nesselerization Color-HACH color kit Fluoride-HACH DR/2000 spectrophotometer with AccuVacs Hardness- HACH field titration Surfactants-HACH detergent field kit Fluorescence-Turner fluorometer

34 Tracer Parameters / EPA Recommended Methodologies Potassium- HACH DR/2000 spectrophotometer Turbidity-HACH nephelometer Chlorine-HACH DR/2000 spectrophotometer with AccuVacs Toxicity-Microtex 100% sample screen

35 Additional Parameters May be added depending on land use and drainage basin of area in question Flow characteristics need to be estimated If flow source cannot be accounted for through known connections, further testing may be required, such as smoke and dye tests. Video sewer cams can be used as a last resort, due to the high cost involved

36 Reporting and Corrective Action Once flow source is determined: City will issue all necessary cease and desist orders Other regulatory agencies may need to be notified City s SOP must be followed carefully so that all information is admissible if any court court proceedings are filed