Illicit Discharge Detection and Elimination or IDDE IDDE is MCM #3 of your NPDES Permit MCM = Minimum Control Measure (you have 6 measures in your permit) NPDES = National Pollutant Discharge Elimination System (i.e. your stormwater permit)
Illicit = Illegal What is Illicit Discharge? Any discharge that is not composed entirely of stormwater that is going into your stormwater system is illicit discharge.
Examples Painting Contractor discharging waste water into street, or direct dumping into a storm drain (Courtesy, Janet Wood, Myrtle Beach)
Examples Pool plaster company discharging waste water into storm drains (Courtesy, Janet Wood, Myrtle Beach)
Examples Restaurant fryer oil/grease discharged into a failing storm drain and pumped into a nearby landscaped bed. (Courtesy, Janet Wood, Myrtle Beach)
catch basin Examples Sediment leaving a construction site during a rain event. (Courtesy, Janet Wood, Myrtle Beach)
Examples Tenant discharging washing machine water into side lot ditch (Courtesy, Janet Wood, Myrtle Beach)
Examples Homeowner storing chemicals in an improperly labeled container within close proximity to a back lot ditch (Courtesy, Janet Wood, Myrtle Beach)
Misc.
Exceptions Any discharge that is not composed entirely of stormwater that is going into your stormwater system is illicit discharge. Discharges from fire fighting and emergency management activities Irrigation Water Foundation Drains (sump pump) Discharges from potable water sources (home water hose) Water line flushing Inert or neutralized swimming pool discharges Air conditioning condensate Individual residential car washing
Exceptions still need to be spelled out in your ordinance (Courtesy, Janet Wood, Myrtle Beach)
Exceptions still need to be spelled out in your ordinance NO NO MAYBE!
Detection finding a discharge, and then finding the source of the discharge Involves tracing up and tracing down. What is Detection????
What is Elimination? Elimination getting rid of the discharge Notification Remediation by offender Remediation by Town Other action
In Myrtle Beach Provide adequate access to permit the city to inspect and, if necessary, to take corrective action. Discovery of improper maintenance or structural issues shall lead to the issuance of a written letter of correction via certified mail. Commence taking corrective action within 30 calendar days of receipt of written notification. Complete all corrective action to the satisfaction of the city within 60 calendar days. Failure to comply with the corrective action may result in the city entering upon the property, taking corrective action, and placing a lien upon the property for the associated costs.
Permit Requirements Develop, implement and enforce a program to detect and eliminate illicit discharge Water Quality Monitoring IDDE Component of your Stormwater Ordinance Storm Drain Marking
Permit Requirements Develop, implement and enforce a program to detect and eliminate illicit discharge Develop a storm sewer system map, showing the location of all outfalls and the names and location of all waters of the State that receive discharges from those outfalls Steve Strickland should have this done for you
Roadways
Drainage Structures
Ditches/Ponds/Outfalls
Individual Parcels Private Drainage Systems
Permit Requirements Develop, implement and enforce a program to detect and eliminate illicit discharge Develop a storm sewer system map, showing the location of all outfalls and the names and location of all waters of the State that receive discharges from those outfalls Prohibit, through ordinance or other regulatory mechanism, nonstormwater discharges into your storm sewer system and implement appropriate enforcement procedures and actions This is what gives you the legal authority to address ID (i.e. this is corrective action if offender did not correct the offense themselves)
Permit Requirements Develop, implement and enforce a program to detect and eliminate illicit discharge Develop a storm sewer system map, showing the location of all outfalls and the names and location of all waters of the State that receive discharges from those outfalls Prohibit, through ordinance or other regulatory mechanism, non-stormwater discharges into your storm sewer system and implement appropriate enforcement procedures and actions Develop and implement a plan to detect and address non-stormwater discharges, including illegal dumping, into your system Not entirely sure how this differs from the first bullet vs Inform public employees, businesses, and the general public of hazards associated with illegal discharges and improper disposal of waste This could also be achieved through water monitoring, and other education activities already underway.
List your exceptions but clarify how you are going to address them (e.g. water line flushing, irrigation, water line flushing), particularly verifying that you have identified them not to be significant contributors of pollutants to your waterways.
The Surfside Situation Currently, there is no language in your stormwater ordinance that addresses illicit discharge. This is a solution to help Surfside address some of its chronic stormwater issues The good news is: You are on your way to implementing a water quality monitoring program that will help you satisfy this minimum control measure You have CTP and the CWSEC to assist with other education/outreach associated with IDDE (which has already been underway for some time) You have CTP, if needed, to provide technical assistance with incorporating this into the existing ordinance (or creating a separate manual/plan for IDDE).
Resources Look at your neighbors (e.g. Myrtle Beach and Horry County) they have some great models Manual