TOWN OF PHILIPSTOWN

HANDOUT DISTRIBUTED AT WORKSHOP #2 ON

 

 

 

MINIMUM MEASURE #3

 

 

 

 

 

ILLICIT DISCHARGE DETECTION AND ELIMINATION

 

 

DECEMBER 14, 2005

 

 

 

 

 

 

 

 

 

 

 

 

 

 

PREPARED BY:

CFE CONSULTING SERVICES, LLC

178 BENNETTS FARM ROAD

RIDGEFIELD, CT 06877

203-431-2683

MINIMUM MEASURE #3

ILLICIT DISCHARGE DETECTION AND ELIMINATION

 

1. MINIMUM MEASURE #3 REQUIREMENTS

 

Under Minimum Measure #3, the Town of Philipstown must develop and implement measures for controlling the illicit discharges from their storm sewer system, as summarized below:

 

1. Develop, implement and enforce a program to detect and eliminate illicit discharges into the MS4

2. Develop and maintain a map showing the location of all outfalls and the names and location of the waters of the United States that receive discharges from these outfalls.

3. Prohibit, through an ordinance or other regulatory mechanism, illicit discharges into the storm sewer system

4. Develop and implement a plan to detect and address non-stormwater discharges, including illegal dumping into the system

5. Inform public employees, businesses and the general public of hazards associated with illicit discharges and improper disposal of waste

6. Address the non-stormwater discharges listed in MS4 Permit Gp-02-02

7. Develop measurable goals and select appropriate management practices to ensure the reduction of pollutants of concern from illicit discharges to stormwater system to the maximum extent practicable

 

2. TERMINOLOGY

 

Illicit Discharges : include non-stormwater discharges, such as sewage and septage wastes, oils, paints and process waters, wash water from a laundry, commercial carwash wastewater, fleet washing, shop drains, etc.

 

Storm Sewer System: may include a piped storm sewer as well as non-piped drainage systems (open channels), such as ditches gully and swales that are man-made or natural, that collects and transports and discharges stormwater from its origination point to another point downstream from its point of origination

 

Outfalls: point of stormwater disposal from a piped or open channel to a body of water or where one body of water drops away into another body of water

 

Waters of the United States: all waters whose surface is exposed to the atmosphere, including rivers, streams, lakes, wetlands, coastal and navigable waters of the United States

 

Best Management Practices (BMPs): are practices or stormwater controls instituted to reduce the impact of pollutants to stormwater discharges, examples of which include conducting shoreline surveys to locate non-storm sewer discharges, conducting dye testing, inspecting storm sewers, establishing citizen watch groups, developing public education materials on the hazards of pollutants discharged from illicit connections

 

Maxim Extent Practicable (MEP): According to Phase II, MS4s must reduce pollutants in stormwater to the MEP to protect water quality. The regulations also specify that compliance with MEP requirement can be attained by developing a SWMP that addresses six (6) minimum measures.

 

Measurable Goals: are stormwater controls known as BMPs that effectively reduce pollution and under Phase II include the following six (6) Minimum Measures:

 

        Public Education

        Public Involvement/Participation

        Illicit Discharge Detection and Elimination

        Construction Site Runoff Control

        Post-Construction Runoff Control

        Pollution Prevention/Good Housekeeping

 

Above measurable goals should include one or more of the following components:

 

        Tracking implementation over time

        Measuring the progress in implementing the BMP

        Tracking total numbers of BMPs implemented

        Tracking program/BMP effectiveness

        Tracking environmental improvement

 

 

3. COMPONENTS OF AN EFFECTIVE IDDE PROGRAM

Components of an effective IDDE program should include:

 

        Audit of Existing Resources and Programs

        Establishment of Responsibility, Authority and Tracking

        Assessment of Illicit Discharge Potential

        Development of Program Goals & Implementation Strategies

        Conducting of Outfall Surveys within Priority Waterbodies

        Isolation of Sources of Illicit Discharges and Instituting Enforcement Actions

        Education and Enforcement to prevent Illicit Discharges

        Ongoing Management of IDDE Program