ILLICIT DISCHARGE DETECTION AND ELIMINATION

1 ILLICIT DISCHARGE DETECTION AND ELIMINATION A Programmatic Overview of Hopewell s IDDE Program and Process September 2015 (Revised October 2016) To report potential pollution draining to the City s storm drain or any surface waters contact City of Hopewell Public Works Department at 804-541-2295. ILLICIT DISCHARGE DETECTION and ELIMINATION Program Manual i September 2015 (Revised October 2016) This ILLICIT DISCHARGE DETECTION and ELIMINATION Program Manual was developed for the City of Hopewell by 3e Consulting, Inc. 8525 Bell Creek Road Mechanicsville, VA 23116 ILLICIT DISCHARGE DETECTION and ELIMINATION Program Manual ii September 2015 (Revised October 2016) Table of Contents INTRODUCTION AND PURPOSE .. 1 IDDE TRAINING PROGRAM .. 2 DOCUMENTATION .. 3 Annual Reporting to DEQ .. 3 IDENTIFICATION OF AN ILLICIT DISCHARGE .. 4 Defining an ILLICIT DISCHARGE .. 4 Stormwater Outfall Mapping/Inventory.

2 5 Awareness during Daily Activities and Operations .. 5 Special Local Water Quality Concerns .. 6 Reporting Procedures .. 6 OUTFALL SCREENING .. 7 Dry-Weather Outfall Screening .. 7 Wet-Weather Screening .. 10 INVESTIGATING ILLICIT DISCHARGE .. 11 Investigation Triggers and Prioritization .. 11 Investigation Protocol .. 11 Timeframes for Performing Investigations .. 13 ELIMINATING VERIFIED ILLICIT DISCHARGES .. 14 Source ELIMINATION .. 14 Follow-up on Source ELIMINATION .. 15 Administrative Action, Enforcement and Penalties .. 15 Reportable Spills .. 15 Appendices Appendix A Outfall Reconnaissance Inspection Form Appendix B IDDE Tracking Form Acronyms DEQ Virginia Department of Environmental Quality EPA Environmental Protection Agency IDDE ILLICIT DISCHARGE DETECTION and ELIMINATION MS4 Municipal Separate Storm Sewer System NPDES National Pollutant DISCHARGE ELIMINATION System ORI Outfall Reconnaissance Inventory TMDL Total Maximum Daily Load VPDES Virginia Pollutant DISCHARGE ELIMINATION System VSMP Virginia Stormwater Management Program City City of Hopewell ILLICIT DISCHARGE DETECTION and ELIMINATION Program Manual 1 September 2015 (Revised October 2016) INTRODUCTION AND PURPOSE This manual presents the standard protocols that the City of Hopewell (City) will utilize to implement its ILLICIT DISCHARGE DETECTION and ELIMINATION (IDDE) Program.

3 These protocols were developed in general accordance with the EPA s " ILLICIT DISCHARGE DETECTION and ELIMINATION : A Guidance Manual for Program Development and Technical Assessments" and consist of written procedures to detect, identify, and prevent unauthorized non stormwater discharges, including illegal dumping, to the City s small municipal separate storm sewer system (MS4). The City s effective implementation of this IDDE program is a condition of the City s MS4 General Permit (MS4 Permit). Figure 1. Generalized depiction of the regulatory framework for the MS4 permit. The City s IDDE Program includes five distinct components: IDDE Training Section outlines procedures to train applicable field ILLICIT DISCHARGE Tracking Section outlines procedures to track and document all efforts related to the IDDE process Identification of an ILLICIT DISCHARGE Sections and outlines procedures to screen, identify and report questionable ILLICIT discharges.

4 Investigating the source of an ILLICIT DISCHARGE Section outlines procedures to investigate reported questionable ILLICIT discharges. ELIMINATION of an ILLICIT DISCHARGE Section outlines procedures to eliminate ILLICIT discharges that have been confirmed through the investigation effort. Documentation of IDDE activities is required for the City to demonstrate compliance with the conditions of the MS4 Permit Section describes the appropriate documentation procedures for activities described in this Manual. ILLICIT DISCHARGE DETECTION and ELIMINATION Program Manual 2 September 2015 (Revised October 2016) IDDE TRAINING PROGRAM The City s MS4 Program Plan requires the City to provide annual training to applicable field personnel in recognition and reporting of ILLICIT discharges. As part of the City s Program, this manual serves as the annual training material to meet the permit requirement. Note that training is also required for Good Housekeeping Pollution Prevention practices to applicable employees and the City provides a separate manual as training material for those activities.

5 The written procedures herein serve as the foundation of the IDDE Program and help to achieve MS4 Permit compliance. However, compliance is dependent on effective implementation and documentation of these procedures. The goal of effective implementation is to eliminate non stormwater discharges to the City s storm sewer system and downstream receiving waters. As referenced throughout this manual, the IDDE Program relies on supplemental materials to assist with implementation and documentation. Field personnel identified for IDDE training should be familiar with each Section of this Manual, the City s IDDE Field Guide, the City s MS4 Outfall Inventory and outfall mapping database, and supplemental materials provided in the Appendices of this Manual, which include: Outfall Reconnaissance Inspection Form This form is for outfall screening to assist in determining the potential of an ILLICIT DISCHARGE . The guide is located in Appendix A. IDDE Tracking Form This form is for the inclusion of documentation required by the MS4 Permit for each investigation of any suspected ILLICIT DISCHARGE .

6 The Stormwater Program Manager or designee will complete this form, but field staff assist with obtaining the required information. The form is located in Appendix B. ILLICIT DISCHARGE DETECTION and ELIMINATION Program Manual 3 September 2015 (Revised October 2016) DOCUMENTATION As highlighted throughout this Manual, documentation of reported ILLICIT DISCHARGE , investigations, and ELIMINATION actions is required for demonstrating compliance with the MS4 permit. In the case of an ILLICIT DISCHARGE , the City s MS4 Permit requires, at a minimum, the following information: The date or dates that the ILLICIT DISCHARGE was observed and reported; The results of the investigation; Any follow up of the investigation; Resolution of the investigation; and The date that the investigation was closed. The resolution of a DISCHARGE may be a referral to and acceptance by the VDEQ or local government for action; however, the action must be properly documented by the City.

7 If the DISCHARGE is determined to be a permitted or allowable DISCHARGE , then the final action is documented and the information is included on the corresponding IDDE Tracking Inventory Form. This will enable the City to access this information if future requests are received concerning the DISCHARGE in question. It will also be included in annual reporting. Annual Reporting to DEQ The City must annually report to the DEQ specific information pertaining to its IDDE efforts. The information is included in the MS4 Annual Report due October 1st of each year. Information required for reporting includes: 1) A list of any written notifications of physical interconnection given by the operator to other MS4s; 2) The total number of outfalls screened during the reporting period, the screening results, and details of any necessary follow up action; 3) A summary of each investigation conducted by the City regarding suspected ILLICIT DISCHARGE . The summary must include: a. The date the suspected DISCHARGE was observed, reported, or both; b.

8 How the investigation was resolved, including any follow up; and c. Resolution of the investigation and the date(s) the investigation was closed. ILLICIT DISCHARGE DETECTION and ELIMINATION Program Manual 4 September 2015 (Revised October 2016) IDENTIFICATION OF AN ILLICIT DISCHARGE The MS4 means a conveyance, or system of conveyances, that discharges into jurisdictional surface waters and wetlands of the United States as defined by the United States Army Corps of Engineers (USACE). That is, any system of drainages from roads, parking lots, catch basins, curbs, gutters, ditches, man made channels, or storm drains that direct stormwater into a stream, pond, wetland or other similar feature is part of the City s MS4. These conveyance systems are vulnerable to contamination, and can carry pollutants in stormwater runoff to the receiving waters or wetlands. Substances other than stormwater that enter receiving waters are considered an ILLICIT DISCHARGE and are the focus of this Manual.

9 An ILLICIT DISCHARGE can be: 1. a measurable flow from a storm drain during dry weather that contains pollutants or pathogens; 2. a unique frequency, composition, and mode of entry in the storm drain system; 3. caused when the sewage disposal system interacts with the storm drain system; or 4. DISCHARGE of pollutants from specific source areas and operations known as generating sites. Defining an ILLICIT DISCHARGE For the purposes of the IDDE Program, the VSMP regulation definition for an ILLICIT DISCHARGE is generalized as: ILLICIT DISCHARGE Any DISCHARGE to an MS4 that is not composed entirely of stormwater, except discharges specifically identified in the Virginia Administrative Code and determined not to be a significant contributor of pollutants to the MS4. ILLICIT discharges on City property are likely to originate from a generating site or activity, such as a washing area or vehicle maintenance area and be the result of daily practices or a specific spill incident.

10 Table 1 provides source pollutants generated from areas of the City. Table 1. Examples of source pollutants of an ILLICIT DISCHARGE . Automotive fluids (oil, fuel, antifreeze) Landscape waste (grass clippings, etc.) Cooking oil and grease Improperly applied fertilizer Solvents Sediment Paints Vehicle wash water Chemical cleansers (detergents, soaps) Sanitary sewer wastewaters Improperly applied pesticides/herbicides Dumpster leachate Improperly managed salts Trash The Virginia regulations include exemptions for some non stormwater discharges that are not considered an ILLICIT DISCHARGE if they are not a significant contributor of pollutants to the City s MS4. Table 2 includes discharges relevant to the City that are not significant contributors of pollutants and are not considered ILLICIT DISCHARGE DETECTION and ELIMINATION Program Manual 5 September 2015 (Revised October 2016) ILLICIT discharges. If there is uncertainty of the source or constituents within an observed DISCHARGE , the Stormwater Program Manager should be contacted immediately so a determination can be made.