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