New Illicit Discharge Detection and Elimination (IDDE) and Monitoring Requirements COST Stormwater Management Conference October 19, 2016
Topics to Cover What is IDDE? What s new in the 2016 MS4 Permit? Written IDDE Program Outfall catchment assessments Outfall screening Catchment investigations Removing illicit discharges Impaired waters outfall monitoring Program milestones IDDE Resources
What is an Illicit Discharge? Any discharge to a MS4 that is not composed entirely of stormwater Illegal floor drain connections Broken sanitary sewer line Cross-connections Sanitary sewer overflows Piped sewer discharge Failing septic system Grass clippings, leaf litter, pet, waste or other material dumped into catch basin
Direct, continuous discharge: broken sanitary line CWP, 2004
Indirect, transient discharge: concrete slurry discharges from storm drain outfall CWP, 2004
Common Sources of Illicit Discharges Illegal dumping (95%) Broken sanitary sewer line (81%) Cross-connections (71%) Illegal floor drain connections (62%) Sanitary sewer overflows (52%) Piped sewer discharge (38%) Failing septic system (33%) Improper RV/boat waste disposal (33%) Pump station failure (14%) CWP 2003 IDDE Survey Responses
Allowable Non-Stormwater Discharges Section 3(a)(2) Uncontaminated pumped ground water Foundation and footing drains Water from crawl space pumps Landscape irrigation and lawn watering runoff Residual street wash water associated with sweeping Discharges/flows from firefighting activities (except training) Rising groundwater Naturally occurring springs Uncontaminated ground water infiltration Diverted stream flows Flows from riparian habitats and wetlands
Your IDDE Program Should Already Include Regulatory authority to prohibit discharges and implement enforcement actions (regulation or ordinance) MS4 outfall map 12 diameter or greater within UA 15 diameter or greater outside UA IDDE program with procedures to locate and eliminate illicit discharges Education of town employees and the public
New IDDE Requirements 2016 MS4 Permit Only required in Priority Areas Detailed written IDDE program Updates to and more detailed storm system mapping SSO inventory More detailed protocol for field work to detect and eliminate illicit discharges Citizen reporting Targeted efforts to address water quality impairments Specific timeframes for program completion
Written IDDE Program Within 1 year (existing) or 2 years (new permittees) Must Include (Appendix B of MS4 Permit): Legal authority (regulation or ordinance) Program responsibilities Procedures for assessing and priority ranking of catchments for illicit discharge potential Systematic procedures for locating, confirming, and removing illicit discharges Illicit discharge prevention procedures Tracking and reporting IDDE program progress Annual employee training
Written IDDE Program
Sanitary Sewer Overflow (SSO) Inventory Develop inventory of all known SSO discharge locations in previous 5 years Location, date, time Entered surface water or MS4? Estimated volume Description/causes Mitigation and corrective measures Update SSO inventory in annual report Eliminate any SSOs detected Inadequate Capacity Flow Interconnectivity
Citizen Reporting Must develop citizen reporting program Website, Email list, hotline, etc. Provide email address, phone number, or other means Municipality must investigate and eliminate the discharge Need to include time and location of observed discharge
IDDE Program Protocol MS4 Permit Appendix B 1. Inventory and Map Outfalls 3. Assess and Rank Catchments 5. Investigate Catchments 7. Removal and Confirmation 2. Delineate Catchments 4. Screen and Sample Outfalls 6. Isolate Sources 8. Followup Screening
Mapping Initial Mapping Outfall and Interconnection Map Type, material, size, and location Name and classification of water body being discharged to Watershed name Completed within 2 years Additional Mapping Entirety of system Outfalls, pipes, manholes, catch basins, interconnections, municipally owned treatment structures Where available: sanitary system, combined system Completed within 3 years
IDDE Data Management Options Traditional Digitize paper maps Field investigations using paper forms Digital Tablet based field inventories Multi-functional interface Inventory Inspection Cleanings Screenings PeopleGIS
Catchment Delineation Catchment the area that drains to an outfall
Catchment Assessment and Ranking Problem Known or suspected contributions of illicit discharges based on existing information Do not need to be screened Identified during initial ranking, cannot add to Problem category after initial ranking High Priority Discharging to an area of concern to public health Any outfall /catchment where screening results indicate sewer input based on olfactory/visual evidence or sampling results
Catchment Assessment and Ranking (cont.) Low Priority Not identified as Problem or High Priority outfall/catchment Lack of screening or system vulnerability factors Excluded No potential for illicit discharges Limited to roadway drainage in undeveloped areas with no dwellings and no sanitary sewers, Drainage from athletic fields Parks or undeveloped green space and associated parking without services
Outfall/Catchment Screening Factors Past discharge complaints Poor dry weather receiving water quality Density of generating sites Age of surrounding development and infrastructure >40 years old = high potential for illicit discharges Sewer conversion Historic combined sewer systems Density of aging septic systems Culverted streams Greater than one road crossing
Dry Weather Outfall Screening & Sampling For each outfall/interconnection, conduct visual inspection during dry weather Basic Information Unique identifier Receiving water Date of most recent inspection Dimensions Shape Material (concrete, PVC) Spatial location (latitude and longitude with a minimum accuracy of +/-30 feet) Physical condition Evidence of Non-Stormwater Flows Odor: sewage, sulfur, sour, rancid, petroleum/gas smells Visual: color, turbidity (cloudy water), floatables (suds, toilet paper), or oil sheen
Dry Weather Outfall Screening & Sampling Collect sample where dry weather (<0.1 inch of rain in previous 24 hours) flow is found Ammonia Chlorine Conductivity Salinity E. coli (freshwater receiving water) or enterococcus (saline or brackish receiving water) - lab Surfactants (such as MBAS, detergents) Temperature Pollutants of Concern If no flow observed, but evidence of dry weather flow exists, revisit outfall within 1 week
Likely Sewer Input Indicators Visual or Olfactory evidence (floatables, sheen, etc.) or Ammonia 0.5 mg/l and Surfactants 0.25 mg/l and Bacteria levels greater than the water quality criteria applicable to the receiving water or detectable levels of chlorine
General Safety Considerations Weather Water Quality Insects: Ticks, Bees, Hornets & Wasps, Mosquitos Plants: Poison Ivy, Poison Sumac, Poison Oak Excessive Heat Slips/Trips/Falls Drowning Stuck in mud
Catchment Investigations Written Catchment Investigation Procedure Review of Historic Information System Vulnerability Factors Manhole Inspections Dry weather Wet weather Isolation Procedures
System Vulnerability Factors History of SSOs Inadequate sanitary sewer Level of Service Common or twin-invert manholes Common trench construction serving both sanitary and storm alignments Crossings of storm and sanitary sewer alignments Sanitary sewer alignments with known underdrains Areas formerly served by combined sewers Areas with infrastructure greater than 40 years old
Manhole Inspections Dry Weather Wet Weather For all outfalls that have one or more system vulnerability factors
Isolation and Source Verification What do you do when you find a suspected Illicit Connection? Refer to your established procedure for isolating identified illicit connections (written IDDE Plan) Further investigation of Storm Drain Network Sand bagging Dye and smoke testing CCTV Top Down vs. Bottom Up
Outfall Monitoring Requirements Current Permit Monitor 6 representative outfalls every year during a rain storm New Permit Outfall screening for discharges to impaired waters only Representative outfall sampling in last 2 years of permit Outfalls that exceed thresholds are targeted for further investigation or BMPs
What are Impaired Waters? Surface waters that do not meet state water quality standards for certain uses like recreation or aquatic life 29% of river miles not supporting for recreation
Impaired Waters Monitoring Requirements #1, Get to Know Your Outfalls Inventory and map of outfalls discharging to impaired waters Outfall Screening Collect sample during a rain event Sample only for pollutants of concern If you have sampling results for outfall from 2004 MS4 permit sampling or other wet weather sampling program, do not need to screen again use data already in-hand
Phosphorus & Nitrogen Collect samples to deliver to lab or use portable N & P meter (requires digester) Nitrogen Require follow-up investigation Total Nitrogen > 2.5 mg/l Phosphorus Require follow-up investigation Total Phosphorus > 0.3 mg/l
Bacteria Collect samples to deliver to lab (watch hold times!) Receiving Water Freshwater E. Coli Indicator Bacteria Threshold for Follow-up Investigation (colonies per 100 ml) >235 for swimming areas >410 for all others Class AA, A and B surface waters Total Coliform >500 Marine Class SA and SB surface waters Fecal Coliform Enterococci >31 for Class SA >260 for Class SB >104 for swimming areas >500 for all others ** No follow-up investigation needed if can prove outfall exceeded levels solely due to natural sources (e.g., wildlife or runoff from undeveloped wooded area)
Other Pollutants of Concern Collect samples from outfall and in-stream immediately upstream of outfall 2 locations Collect readings for Turbidity using portable meter Require follow-up investigation Difference, > 5 NTU
Follow-up Investigations Investigate activities within the drainage area Land use or development patterns Business or commercial activities Industrial activities DCIA Natural contributors Potential MS4 maintenance issues Residential activities Implement a BMP program focusing on impaired waters provisions within the General Permit
Prioritized Outfall Monitoring Screen ½ impaired outfalls Select 6 outfalls with highest levels of pollutant of concern Sample annually
Wet Weather Monitoring Procedures Qualifying rain event, 48 hours after previous measureable rain storm (> 0.1 inch rainfall) Rain storm may include insignificant amounts of snow or ice melt Single grab sample Collect within 6 hours of discharge Record rain event information Date, temperature, time of the start of discharge, time of sampling, magnitude (inches) of the rain event sampled Duration between the rain event sampled and the end of the previous measurable rain event
IDDE Program Milestones Existing 2004 MS4 Permittees New MS4 Permittees IDDE Program Element SSO Inventory 120 Days Legal Authority X X Written IDDE Plan X X X X Years from Effective Date of Permit 1 2 3 4 5 10 Outfall Inventory and Mapping X X X X Initial Priority Ranking of Outfalls X X Dry Weather Outfall Screening X X Begin Catchment Investigations X X Complete Catchment Investigations: 80% Problem Catchments 100% Problem Catchments Indication of Sewer Inputs 40% of Area Served by All Catchments 100% of Area Served by All Catchments X X X X X X X X X X
Impaired Waters Monitoring Milestones Existing 2004 MS4 Permittees New MS4 Permittees Program Element Years from Effective Date of Permit 1 2 3 4 5 Inventory and map of outfalls discharging to impaired waters X X Outfall Screening: Start X X Outfall Screening: 50% X X Outfall Screening: 100% X X Follow-up Investigations X X Prioritized Outfall Monitoring X X
IDDE Resources Connecticut MS4 Permit http://www.ct.gov/deep/lib/deep/permits_and_licenses/water_discharge_ge neral_permits/ms4_gp.pdf IDDE Program Examples/Resources CWP 2004 IDDE Manual https://www3.epa.gov/npdes/pubs/idde_manualwithappendices.pdf CWP 2011 Illicit Discharge Detection and Tracking Guide http://owl.cwp.org/mdocs-posts/idde-and-tracking-guide/ NEIWPCC 2003 IDDE Manual http://www.neiwpcc.org/neiwpcc_docs/iddmanual.pdf Sampling Kits and Meters http://centralmastormwater.org/pages/crsc_toolbox/waterqualitytools
Questions? Contact Information Erik Mas, PE Vice President emas@fando.com 800.286.2469 x4433 William Guenther, MS Environmental Scientist wguenther@fando.com 800.286.2469 x4579 Jennifer Cavanaugh, CPESC, CPMSM Senior Project Engineer jcavanaugh@fando.com 800.286.2469 x4202