Logansport Municipal Utilities

Chapter 5 - Illicit Discharge Detection and Elimination MCM

5.0 Introduction

This chapter describes the Illicit Discharge Detection and Elimination minimum control measure, the third of six measures the operator of a Phase II regulated small municipal separate storm sewer system (MS4) is required to include in its stormwater management program to meet the conditions of its National Pollutant Discharge Elimination System (NPDES) permit.

Federal regulations define an illicit discharge as any discharge that is not composed entirely of stormwater. Illicit discharges can enter the system through either direct connections or indirect connections. The result is untreated discharges that contribute high levels of pollutants to receiving water bodies. Recognizing the adverse effects illicit discharges can have on receiving waters, this chapter allows the MS4 operator to detect and eliminate illicit discharges by gaining a thorough awareness of the entire stormwater sewer system.

Each section of this plan describes a Best Management Practice (BMP). Each BMP is accompanied by its own implementation schedule. The implementation schedule informs the MS4 Operator and their designated personnel of the tasks to complete each year. The MS4 Operator will require that the parties responsible for each detection and elimination activity record and report annually on the items to be tracked so that the MS4 Operator may include them in the annual report to IDEM.

Measurable Goal: The illicit discharge detection and elimination program aims to reduce the amount of stormwater pollution caused by illicit discharges within the corporate limits of Logansport by 10%. The goal is to achieve the 10% reduction by the end of the 5-year permit term.

The following is the illicit discharge detection and elimination program.

5.1 Development of a MS4 Conveyance Map

The purpose of the MS4 conveyance map is to provide accurate location information for all components of the conveyance system. This includes identifying the location of all outfalls in the City and identifying the names and locations of water bodies that receive discharges from those outfalls. All known conveyance systems with a pipe diameter of twelve inches or larger and open ditches with a two-foot or larger bottom width will be mapped within the first five years of permit coverage.

The completed map will aid in the efforts of:

Identifying the possible sources of dry weather flows
Identifying the water bodies that dry weather flows may be affecting

5.1.1 Implementation Schedule

The implementation of the development of storm sewer mapping shall be the responsibility of the MS4 Operator who will pursue the following schedule:

Year 1 (ending Nov 2004): Collect available storm sewer map information on the MS4 area. Incorporate existing information into one map.

Year 2 (ending Nov 2005): Collect field data for and map at least twenty-five percent (25%) of the MS4 conveyances within the MS4 area.

Year 3 (ending Nov 2006): Collect field data for and map an additional twenty-five percent (50% total) of the MS4 conveyances within the MS4 area.

Year 4 (ending Nov 2007): Collect field data for and map an additional twenty-five percent (75% total) of the MS4 conveyances within the MS4 area.

Year 5 (ending Nov 2008): Collect field data for and map the remaining twenty-five percent (100% total) of the MS4 conveyances within the MS4 area. Review compiled mapping to ensure completeness.

5.1.2 Items to be Tracked

The following items will be recorded on the corresponding reporting form located at the end of this chapter.

Linear footage of MS4 mapped; and
Number and location of MS4 area outfalls mapped.

5.2 Development of a Regulatory Mechanism

The purpose of the development of a regulatory mechanism such as an ordinance is to provide for the health, safety, and general welfare of all citizens within the MS4 area. This is accomplished through the regulation of non-stormwater discharges to the storm drainage system.

The objectives of an illicit discharge detection and elimination ordinance are:

To regulate contribution of pollutants to the MS4 by stormwater discharges by any user
To prohibit illicit connections and discharges to the MS4
To establish legal authority to carry out all inspection, surveillance, monitoring, and to implement corrective actions necessary to ensure compliance with the ordinance

5.2.1 Implementation Schedule

The implementation of the development of an Illicit Discharge Detection and Elimination ordinance shall be the responsibility of the MS4 operator who will pursue the following schedule:

Year 1 (ending Nov 2004): Develop a draft ordinance for illicit discharge detection and elimination. City will adopt the ordinance.

Year 2 (ending Nov 2005): Review illicit discharge ordinance and note any suggested improvements. Update ordinance if necessary.

Year 3 (ending Nov 2006): Review illicit discharge ordinance and note any suggested improvements. Update ordinance if necessary.

Year 4 (ending Nov 2007): Review illicit discharge ordinance and note any suggested improvements. Update ordinance if necessary.

Year 5 (ending Nov 2008): Review illicit discharge ordinance and note any suggested improvements. Update ordinance if necessary.

5.2.2 Items to be Tracked

The following items will be recorded on the corresponding reporting form located at the end of this chapter.

Number and type of suggested improvements for the ordinance; and
Number and description of changes made to ordinance.

5.3 Development of an Illicit Discharge Detection and Elimination Plan

The plan to detect and address illicit discharges is the central component of this minimum control measure. It allows the MS4 operator to systematically find and remove illicit discharges from the entire MS4 area. All illicit discharge detection and elimination activities shall be documented on the reporting forms located at the end of this chapter.

This plan is divided into a three step process:

Locate Problems within Priority Areas
Find the Source
Remove or Correct Illicit Connections

All actions taken as required by this plan will be documented. The documentations will be retained to be incorporated into the annual report. This plan will also be reviewed and assessed at a minimum of every five years.

High priority areas are areas that are considered to be likely sources of illicit discharges, based on available information. These areas can include older sections of the City, commercial and industrial areas, high density areas, and unsewered areas.

Once the high priority areas have been located, a screening of these outfalls will be conducted via dry weather screening. Dry weather screening consists of visual investigation of stormwater outfalls at least seventy-two hours after a rainfall event. The presence of flow during dry weather can indicate an illicit discharge.

Problem areas and discharges identified through the dry weather screenings will be analyzed for pollutants of concern and other parameters. Field test kits will be used to test for pH, conductivity, and ammonia-nitrogen. Other parameters to be investigated during a visual screening include but are not limited to odor, color, temperature, deposits or stains, and damage to the outfall structure. Depending on visual inspection results, more analysis of dry weather discharges may follow.

After all high priority areas have been screened for illicit discharges, the remaining lower priority area screening will begin.

Once outfalls with evidence of illicit discharges have been located, various methods will be used to detect the source of the discharge.

Once an illegal discharge is located through field screening and confirmed through sampling, enforcement action may be required to have the source removed. There will be a graduated response to the discovery of an illegal connection beginning with voluntary compliance and escalating to enforcement actions if compliance is not obtained.

The procedures of enforcement will be outlined in the City of Logansport's Illicit Discharge Detection and Elimination ordinance.

A reference list of all known active industrial facilities, within the MS4 area, discharging to the MS4 conveyance system is provided in Appendix B. Updated information regarding these and newly active industrial facilities will be submitted in each annual report.

The implementation of the Detection and Elimination of Illicit Discharges Plan shall be the responsibility of the MS4 Operator who will pursue the following schedule:

Year 1 (ending Nov 2004): Identify high priority areas based on available mapping and public complaints. These areas will be screened first.

Year 2 (ending Nov 2005): Screen twenty-five percent (25%) of the outfalls and locate problems within the MS4 area. Follow through with removing or correcting illicit discharges and connections.

Year 3 (ending Nov 2006): Screen an additional twenty-five percent (50% total) of the outfalls and locate problems within the MS4 area. Follow through with removing or correcting illicit discharges and connections.

Year 4 (ending Nov 2007): Screen an additional twenty-five percent (75% total) of the outfalls and locate problems within the MS4 area. Follow through with removing or correcting illicit discharges and connections.

Year 5 (ending Nov 2008): Screen the remaining twenty-five percent (100% total) of the outfalls located in the MS4 area. Follow through with removing or correcting illicit discharges and corrections.

The following items will be recorded on the corresponding reporting form located at the end of this chapter.

It is acknowledged that outreach to public employees, businesses, property owners, and the general public will help gain support for and increase compliance with the stormwater program. Information and education regarding ways to detect and eliminate illicit discharges is an integral part of this minimum control measure.

An education program identifying the hazards of illicit discharges and improper waste disposal will be combined with the Public Outreach and Education minimum control measure (chapter 3). Information and guidance for specific audiences will be incorporated into the stormwater website, activity books, cable access television, and other programs.

Public participation programs pertaining to illicit discharge detection and elimination will be combined with the Public Participation and Involvement minimum control measure (chapter 4). These programs include the coordination of a household hazardous waste recycling program and the establishment of a telephone notification system for reporting illicit discharges.

Current Employees: Current employees involved in illicit discharge detection and elimination will be required to complete training. This training will involve education on testing equipment as well as policies and procedures to be used. This training will be documented. The documentation will be retained by the City.

During subsequent years, employees whose work involves illicit discharge detection and elimination will be required to complete an annual refresher training program. This training will be documented. The documentation will be retained by the City.

New Employees: New employees whose work involves illicit discharge detection and elimination will be required to complete training. This training will take place within the first two months of employment. This training will be documented. The documentation will be retained by the City.

The implementation of the training for MS4 personnel shall be the responsibility of the MS4 operator who will pursue the following schedule:

Year 1 (ending Nov 2004): Develop and implement training policy and procedures for public employee training on illicit discharge detection and elimination. Begin training employees.

Year 5 (ending Nov 2008): Continue training employees. Evaluate the policies, procedures, and training methods; and begin implementing any recommended changes.

The following item will be recorded on the corresponding reporting form located at the end of this chapter.

5.6 Consistency with the Long-Term Control Plan (LTCP) and Combined Sewer Overflow Operational Plan (CSOOP)

The City of Logansport's Long-Term Control Plan and Combined Sewer Overflow Operational Plan were reviewed for the illicit discharge detection and elimination component to ensure that the efforts of the Stormwater Management Plan were neither in conflict with, nor duplicating the efforts of the LTCP or the CSOOP.

Currently the City of Logansport monitors only the combined sewer overflows. There is no program in place to monitor stormwater outfalls. Therefore, the efforts of this SWQMP, which aim to detect and eliminate illicit discharges from stormwater outfalls, are not in conflict with or a duplication of the efforts of either the LTCP or the CSOOP.

STORM WATER