Introductions What s the worst illicit you ve ever seen?

Transcription

1 Hal Clarkson, PE, CFM rd Quarter Meeting Building a Comprehensive Illicit Discharge Detection and Elimination Program Hal Clarkson, PE Introductions What s the worst illicit you ve ever seen? Grey Water Discharge Household Wash Water Sanitary Sewer Overflow Marble Company Discharge Phase II MS4 Permit Illicit Discharge Requirements 1. Create legal authority (ordinance) 2. Develop system map (outfalls) 3. Identify priority areas 4. Dry weather screening SOP 5. the source 6. requirements 7. Determine the source 8. Corrective actions 9. Public reporting 10. training 1

2 Requirement: Permittees must procure all necessary legal authority to prohibit, inspect, and enforce the elimination of illicit discharges Purpose: Regulate, respond, and enforce illicit discharges in the MS4 Should have completed in 1 st permit cycle Should have completed in 1st permit cycle 1. Create Legal Ordinance should: Prohibit illicit discharges & illegal connections Provide for access & inspection Require & enforce elimination Address unique conditions or requirements 2. Develop Requirement: Location of outfalls, names of receiving waters (WOTUS) Purpose: Know where system is and find dry potential illicit discharges Outfall Inventory vs. Full Inventory Outfall inventory Full system inventory 2

3 2. Develop an Outfall Inventory Streamwalk Method Pros: Cons: All outfalls, including private and non-regulated outfalls, are more easily observed and mapped In areas containing a dense or convoluted street network or where there is limited access to streams, streamwalks may be more efficient than the MS4 method May be advisable in industrial or commercial areas, or other areas expected to contain a complex or extensive outfall population Streamwalks are generally more time consuming (and therefore more costly) than the MS4 method Private outfalls and other outfalls that may not be of interest to the community (such as small pipes and other non-regulated outfalls) are mapped, with no apparent means of identifying the outfalls of interest during the field effort 2. Develop an Outfall Inventory MS4 Method Pros: Cons: Generally substantially more cost effective and less time consuming than streamwalks Only outfalls of interest such as those owned or maintained by the community, or those meeting or exceeding a threshold to warrant consideration as regulated outfalls are tracked and collected Some private outfalls, or those of less significant size or catchment area, may not be mapped 3. Identify Requirement: identify priority areas for more detailed screening, create list NLT 12 months from effective date and update annually (should be done) Purpose: Focus screening efforts on worst areas Communities should consider a number of factors when prioritizing watersheds for inventory, dry weather screening, and illicit tracking: Past Discharge Complaints Former Combined Sewers Poor Dry Weather Water Quality Older Industrial Operations Density of Generating Sites Aging or Failing Sewers Density of Industrial NPDES Permits Density of Older Septic s Stormwater Outfall Density Past Sewer Conversions Age of Subwatershed Development Select the factors that apply most to your community 3

4 3. Identify Subwatershed Past discharge complaints Poor dry weather WQ Density of SW outfalls Average age of dev. Raw IDP score Subwatershed A 8 (2) 30% (2) 14 (2) 40 (2) 8 2 Subwatershed B 3 (1) 15% (1) 10 (2) 10 (1) rmalized IDP score Subwatershed C 13 (3) 60% (3) 16 (2) 75 (3) Subwatershed D 1 (1) 25% (1) 9 (1) 15 (2) Subwatershed E 5 (1) 15% (1) 21 (3) 20 (1) Basis for Assigning Scores Past discharge complaints/reports (total # logged) Dry weather water quality (# times bacteria stds exceeded) < > 10 > 50% < 25% 25-50% Storm water outfall density (# outfalls / stream mile) < Average age of development (years) < > Identify Update annually. Severe Illicit Discharge Problems Minimal Illicit Discharge Problems Key: Low IDP risk Clustered Illicit Discharge Problems Medium IDP risk High IDP risk 4. Screening Requirement: Implement a written dry weather screening process within 12 months of effective date, program may consist of 1) visual observations, 2) field screening monitoring, 3) analytical monitoring Visual Screening - initial screening technique to identify dry weather flows, quick, can use construction / maintenance staff screening of dry weather flows - some equipment and training required, can produce disposal issues, helps determine if true illicit discharge Analytical monitoring - comprehensive, tracks through the system, expensive, has other uses 4

5 4. Screening Use field crews of two people Crews should be trained : HAZWOPER - Handling, transporting, and disposing of hazardous waste Confined space entry CPR and First Aid NOT SAFE! Always use safety glasses and gloves when sampling Physical limitations of personnel Be aware of hunters and private property owners Dogs Fences 4. Screening Options for Collecting Inventory Points Logitech 420 digital camera Garmin GPS/76 4. Screening Fujitsu ST-4121 Tablet PC Dry Weather Screening Methodology Done while conducting outfall inventory 72 hours or greater with < 0.1 of precipitation Grab sample tested for chemical attributes Between 4 hours and 24 hours later run second grab for the same analytes Physical Attributes Color Odor Deposits and stains Floatable matter Temperature Turbidity Changes in flow Vegetation change Structural damage Grease / oil Chemical Attributes ph Chlorine Copper Phenols Surfactants 5

6 4. Screening - Sampling Methods Spectrophotometer HACH Storm Water Test Kit Direct Read Meter Dip Strips 4. Screening Assess program by third annual report Include procedures in SWMP 5. the Requirement: Develop written procedures for conducting investigations including enforcement procedures Determine and document the source of illicit discharges Initiate investigation, report to DHEC immediately if threat to human health or environment, Document investigation and follow up 6

7 5. the Two Methodologies: 1. Screen and then track More time consuming Provides complete record of dry weather screening activities 2. Track and then screen (if necessary) More efficient way of tracking Usually takes less time to complete investigation Some illicit discharges do not require dry weather screening activities (i.e. sanitary sewer, car wash discharge, illegal dumping activities, etc.) 6. Chemical Parameter Sampling Data Interpreting Sampling Data Set ranges/limits Indicative of sanitary sewage Chlorine Copper Phenol Surfactant WATER QUALITY INFORMATION: SAMPLE 2 SAMPLE 1 SAMPLE DATE: Chemical Properties Allowable Range/Limit ph 7/14/2004 SAMPLE DATE: Chemical Properties 7/14/2004 ILLICIT INVESTIGATION SAMPLE SAMPLE DATE: Chemical Properties 7/16/2004 ph: 6.2 ph: 6.13 ph: 6.9 CHLORINE: 0.71 CHLORINE: 0.76 CHLORINE: 0.72 COPPER: 0.03 COPPER: 0.05 COPPER: 0.13 PHENOLS: 0.11 PHENOLS: 0.09 PHENOLS: 0.13 SURFACTANTS: 0.11 SURFACTANTS: 0.12 SURFACTANTS: 0.09 FLUORIDE: AMMONIA/POTASSIUM RATIO: FLUORIDE: AMMONIA/POTASSIUM RATIO: 0.14 FLUORIDE: AMMONIA/POTASSIUM RATIO: TEMPERATURE: 22.2 DEG. C TEMPERATURE: DEG. C TEMPERATURE: TURBIDITY: TURBIDITY: Physical Properties OIL SHEEN: Physical Properties OIL SHEEN: SCUM: SCUM: FLOW ODOR: FLOW ODOR: FLOW COLOR: FLOW RATE: Cloudy Stream FLOW COLOR: FLOW RATE: DEG. C Physical Properties TURBIDITY: OIL SHEEN: SCUM: FLOW ODOR: Cloudy Stream FLOW COLOR: FLOW RATE: Cloudy Stream 6. Outfall Inventory Results Approximately 10% of the outfalls that were checked had dry weather flows Approximately 6% of the total number of dry weather flows qualified as illicit discharges Averaged 5 crew hours per dry weather outfall Includes travel time, sampling, and field tracking 7

8 7. Determine Purpose: Determine and document the source of illicit discharges Requirement: Determine and document the source of illicit discharges If illicit discharge is found, but no source identified within 6 months maintain documentation / prudent to continue monitoring on regular basis If illicit discharge is intermittent, perform minimum of three investigations while discharging - maintain documentation / prudent to continue monitoring on regular basis 7. Determine : : NEIWPPC,2003 Smoke Testing Dye Testing : Robotic Crawler 7. Determine Pole Camera : 8

9 7. Determine Innovative Techniques to Locate the Discharge Sable the Sniffer - Detection Canine Rescued from an animal shelter Detects fecal contamination in storm drainage systems Reference: es/2010/06/15/werf-studyuses-dogs-to-find-fecalcontamination-in-stormdrains.aspx Reference: Reference: 7. Determine Innovative Techniques to Locate the Discharge Fiber-Optic Distributed Temperature Sensing (DTS) Used to find household sewage connections in the Netherlands Reliable, inexpensive and practically feasible method Reference: Locating illicit connections in storm water sewers using fiber-optic distributed temperature sensing. O.A.C. Hoes, R.P.S. Schilperoort, W.M.J. Lexemburg, F.H.L.R. Clemens, N.C. van de Giesen 8. Corrective Actions Requirement: tify responsible party, require corrective action within 30 days (or written explanation of why longer), conduct follow up investigation, document, follow the ERP 9

10 8. Corrective Actions 8. Corrective Actions Fixing Illicit Discharges Who is responsible? What methods will be used to repair? How long will the repair take? How will removal be confirmed? 9. Public Reporting Requirement: Promote, publicize, facilitate reporting mechanism, Develop written spill / dumping response, conduct reactive inspections to complaints Leads to early detection & correction Encourages active public stewardship Can piggyback on other call response needs Identifies suspected facilities for further investigation & education Good tool to pick up intermittent and transitory discharges 2005 Hotline Calls 10

11 10. Training 9. Public Reporting Requirement: Train all appropriate staff and track who is trained on what Decision Points 1. Financial resources 2. Education and training of employees and residents 3. Severity of illicit / spill problem 4. Complexity of MS4 system 5. Historical illicit problems 6. Calibrate your program resources to the magnitude of your problem I am 100% certain that I am 0% sure of what I am going to do. Hal Clarkson, PE hal.clarkson@woolpert.com Columbia, SC Questions? 11