Phase II BMP & Measurable Goal Examples
ILLICIT DISCHARGE DETECTION AND ELIMINATION MINIMUM MEASURE
Illicit discharges to MS4s are wastes and wastewaters that are not from storm water runoff and are not otherwise authorized by a NPDES permit. These discharges enter the system either through direct connections (wastewater piping connected to storm drains, for example) or through indirect connections (infiltration from leaky wastewater systems, spills, dumping into the storm drain, etc.).
Hypothetical Case Study: Smalltown, USA, has yet to survey the MS4 to identify problems and illicit connections. To initiate this process, they intend to map the entire system to systematically address potential problem areas, first with a general survey and then with a more detailed inspection. They also plan to enlist the support of the public in identifying illicit discharges or illegal dumping.
Minimum Measure Objectives: Develop a comprehensive map of the storm drain system, establish and carry out procedures to identify and remove illicit discharges, establish legal authority for enforcement actions, and encourage public education and involvement in eliminating illicit discharges.
BMP: Storm drain system map
Measurable Goal: A storm drain system map will be developed in the first year.
Justification: A comprehensive infrastructure map of the MS4 has not yet been created. Once completed, this map will aid the municipality in targeting outfalls with dry weather flows and other suspicious discharges for more in-depth inspection and monitoring and will help coordinate management activities to remove illicit connections and track storm drain system maintenance.
BMP: Identify illicit connections through dry weather screening and targeted video inspection
Measurable Goal: A survey during dry weather of 20% of the storm drain system outfalls per year will be conducted to identify non-storm water flows. Once each year's survey is complete, areas with suspicious discharges will be inspected with video cameras to detect suspected direct connections to the wastewater system and identify areas where wastewater might be leaking into adjacent storm drain pipes.
Justification: The municipality contains many older neighborhoods that will be the initial focus of the illicit discharge identification effort. Deteriorating infrastructure and questionable building codes at the time might have resulted in directly connected and/or leaking wastewater pipes. Targeted video inspection in areas with high nutrient levels, appearance of suds or oily discharges, or dry weather flows will efficiently identify these connections.
BMP: Illicit discharge/illegal dumping hotline
Measurable Goal: A hotline for citizens to report illegal dumping and suspicious discharges will be established in the first year. The hotline will be advertised by placement of one ad in the local newspaper every 6 months and an insert in each homeowner’s and business’s water utility bills every year.
Justification: This hotline will supplement the municipality’s effort to target outfalls for video inspection and will facilitate the cleanup and remediation of dumping sites. Also, advertising the hotline will improve public involvement and will serve as an educational tool to inform the public about the hazards of illicit discharges and illegal dumping.
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