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[[File:IDDE Sample.jpg|500 px|right|thumb|alt=This image shows a person collecting a water sample from an outfall |<font size=2>Image of a person collecting a water sample from an outfall </font size>]]
 
[[File:IDDE Sample.jpg|500 px|right|thumb|alt=This image shows a person collecting a water sample from an outfall |<font size=2>Image of a person collecting a water sample from an outfall </font size>]]
==Introduction==
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In Minnesota, our storm sewer systems carry water directly to our lakes, rivers, and wetlands. This water does not go to a treatment plant before entering our surface water. To maintain fishable, swimmable, and drinkable water and prevent pollution from entering our waterbodies, only stormwater should enter a storm sewer system. If anything else, such as oil, chemicals,  or sediment, enters the system it is usually an illicit discharge. Minimum Control Measure (MCM) 3 of the [https://stormwater.pca.state.mn.us/index.php?title=MS4_PART_III.STORMWATER_POLLUTION_PREVENTION_PROGRAM_(SWPPP) MS4 General Permit] requires permittees to develop and implement a program to detect and eliminate illicit discharges within their storm sewer system.
+
In Minnesota, our storm sewer systems carry water directly to our lakes, rivers, and wetlands. This water does not go to a treatment plant before entering our surface water. To maintain fishable, swimmable, and drinkable water and prevent pollution from entering our waterbodies, only stormwater should enter a storm sewer system. If anything else, such as oil, chemicals,  or sediment, enters the system it is usually an illicit discharge. Minimum Control Measure (MCM) 3 of the [https://stormwater.pca.state.mn.us/index.php?title=2020_MS4_General_Permit_Section_18_MCM_3:_Illicit_Discharge_Detection_and_Elimination MS4 General Permit] requires permittees to develop and implement a program to detect and eliminate illicit discharges within their storm sewer system.
  
 
==MS4 General Permit requirements for MCM 3==
 
==MS4 General Permit requirements for MCM 3==
 
The illicit discharge detection and elimination (IDDE) program must include:
 
The illicit discharge detection and elimination (IDDE) program must include:
 
:*A map of the MS4 that includes all pipes 12 inches or greater and their flow direction; outfalls, including the unique identifier and geographic coordinates; municipally owned or operated structural stormwater best management practices (BMPs); and all receiving waters.
 
:*A map of the MS4 that includes all pipes 12 inches or greater and their flow direction; outfalls, including the unique identifier and geographic coordinates; municipally owned or operated structural stormwater best management practices (BMPs); and all receiving waters.
:*A [[#Model regulatory mechanisms|regulatory mechanism]] to prohibit illicit discharges.  
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:*A [[#Model language|regulatory mechanism]] to prohibit illicit discharges.
 +
:*Cities, townships, and counties must implement a pet waste [[#Model language|regulatory mechanism]].
 +
:*Cities and townships must implement a salt storage [https://www.pca.state.mn.us/sites/default/files/p-tr1-54.pdf regulatory mechanism] at commercial, institutional, and non-NPDES permitted industrial facilities.
 
:*The incorporation of illicit discharge detection into all [[Municipal operation inspections|municipal operation inspection]] and maintenance activities, such as those conducted on ponds, outfalls, and other structural stormwater BMPs. These inspections should be conducted during dry weather, when possible.
 
:*The incorporation of illicit discharge detection into all [[Municipal operation inspections|municipal operation inspection]] and maintenance activities, such as those conducted on ponds, outfalls, and other structural stormwater BMPs. These inspections should be conducted during dry weather, when possible.
 
:*Detecting and tracking the source of illicit discharges using visual inspections.
 
:*Detecting and tracking the source of illicit discharges using visual inspections.
:*[[Employee training|Training]] of all field staff on illicit discharge recognition.
+
:*[[Employee training|Training]] of all field staff on illicit discharge recognition. Field staff includes, but is not limited to, police, fire department, public works, and parks staff.
:*Identifying priority areas likely to have illicit discharges by evaluating land uses associated with business and industrial activities, areas where illicit discharges have been observed in the past, areas with storage of large quantities of materials that could result in an illicit discharge. These locations should have additional illicit discharge inspections.
+
:*Identifying priority areas likely to have illicit discharges by evaluating land uses associated with business and industrial activities, areas where illicit discharges have been observed in the past, areas with storage of large quantities of materials that could result in an illicit discharge. These locations should have additional illicit discharge inspections. In addition, these areas need to be kept in a written or mapped inventory.
 
:*[[#Example procedures|Procedures]] for investigating, locating, and eliminating the source of illicit discharges.
 
:*[[#Example procedures|Procedures]] for investigating, locating, and eliminating the source of illicit discharges.
 
:*[[#Example procedures|Spill response procedures]]. These procedures must include the requirement to notify the Minnesota Duty Officer.
 
:*[[#Example procedures|Spill response procedures]]. These procedures must include the requirement to notify the Minnesota Duty Officer.
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===Fact sheets and guidance===
 
===Fact sheets and guidance===
 +
Fact sheets and guidance documents should provide background information and tips to inform your approach to implementing MCM 3 - Illicit Discharge Detection and Elimination.
 
*[https://www.epa.gov/npdes/national-menu-best-management-practices-bmps-stormwater#ill EPA MCM 3 guidance] - EPA guidance and suggested BMPs for an effective illicit discharge detection and elimination program
 
*[https://www.epa.gov/npdes/national-menu-best-management-practices-bmps-stormwater#ill EPA MCM 3 guidance] - EPA guidance and suggested BMPs for an effective illicit discharge detection and elimination program
 
*[https://www3.epa.gov/npdes/pubs/fact2-5.pdf EPA Illicit Discharge Fact sheet] - EPA fact sheet on MCM 3
 
*[https://www3.epa.gov/npdes/pubs/fact2-5.pdf EPA Illicit Discharge Fact sheet] - EPA fact sheet on MCM 3
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===Model language===
 
===Model language===
 +
Fill in the blanks and adopt ordinance language that meets the regulatory mechanism requirements for [https://stormwater.pca.state.mn.us/index.php?title=2020_MS4_General_Permit_Section_18_MCM_3:_Illicit_Discharge_Detection_and_Elimination MCM 3 - Illicit Discharge Detection and Elimination].
 +
 +
* [https://stormwater.pca.state.mn.us/index.php?title=File:Model_Pet_Waste_Ordinance.docx Pet Waste Ordinance Model Language] - Model ordinance language for municipalities to prohibit pet waste
 
*[https://www.epa.gov/sites/production/files/2015-12/documents/modelillicit.pdf Illicit Discharge Model Ordinance Language] - EPA's model ordinance language for municipalities to prohibit illicit discharges and connections
 
*[https://www.epa.gov/sites/production/files/2015-12/documents/modelillicit.pdf Illicit Discharge Model Ordinance Language] - EPA's model ordinance language for municipalities to prohibit illicit discharges and connections
  
 
===Documentation and tracking templates===
 
===Documentation and tracking templates===
*[[media:IDDE Documentation Tracking.xlsx|Illicit Discharge documentation template]] - MPCA template to track the required information related to illicit discharges discovered or observed by municipal staff and reports (e.g. complaints, referrals) of illicit discharges received by the municipality.
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Documentation and tracking templates are examples that local stormwater staff are currently using to meet the [https://stormwater.pca.state.mn.us/index.php?title=2020_MS4_General_Permit_Section_18_MCM_3:_Illicit_Discharge_Detection_and_Elimination MS4 General Permit requirements for MCM 3 - Illicit Discharge Detection and Elimination].
*[[MS4 Illicit discharge discoveries and reports tracking template]] - MPCA template to track the required information related to illicit discharges discovered or observed by municipal staff and reports (e.g. complaints, referrals) of illicit discharges received by the municipality.
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*[[media:IDDE Documentation Tracking.xlsx|Illicit Discharge documentation template]] - MPCA template to track the required information related to illicit discharges discovered or observed by municipal staff and reports (e.g. complaints, referrals) of illicit discharges received by the municipality
*[https://stormwater.pca.state.mn.us/index.php?title=Documentation_requirements_and_documents_to_retain_under_the_MS4_permit Documentation that MS4 staff should retain] - List of all the documentation requirements (what information to keep, how long to keep it, level of detail to keep, etc.) for compliance with the [https://stormwater.pca.state.mn.us/index.php?title=MS4_General_Permit MS4 permit]
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*[[media:IDDE report & response form.pdf|Illicit Discharge documentation template]] - Empire Township's template to track the required information related to illicit discharges discovered or observed by municipal staff and reports (e.g. complaints, referrals) of illicit discharges received by the municipality
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*[[media:Illicit Discharge Investigation Report - MN State.docx|Illicit Discharge documentation template]] - Minnesota State's (MnSCU) template to track the required information related to illicit discharges discovered or observed by staff
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*[[media:Illicit Discharge Reporting Form - MN State.docx|Illicit Discharge documentation template]] - Minnesota State's (MnSCU) template to track reports (e.g. complaints, referrals) of illicit discharges
 +
*[https://stormwater.pca.state.mn.us/index.php?title=Documentation_requirements_and_documents_to_retain_under_the_MS4_permit Documentation that MS4 staff should retain] - List of all the documentation requirements (what information to keep, how long to keep it, level of detail to keep, etc.) for compliance with the [https://stormwater.pca.state.mn.us/index.php?title=MS4_General_Permit MS4 General Permit]
 
*[[media:Enforcement Action Documentation Tracking.xlsx|Enforcement action documentation template]] - MPCA's template for documenting all enforcement actions used to compel compliance with your regulatory mechanisms
 
*[[media:Enforcement Action Documentation Tracking.xlsx|Enforcement action documentation template]] - MPCA's template for documenting all enforcement actions used to compel compliance with your regulatory mechanisms
 
*[[media:Employee Training Tracking.xlsx|Employee training tracking template]] - MPCA template to document all required information related to employee training events
 
*[[media:Employee Training Tracking.xlsx|Employee training tracking template]] - MPCA template to document all required information related to employee training events
  
 
===Example procedures===
 
===Example procedures===
 +
Example procedures are those that local stormwater staff are currently using to meet the [https://stormwater.pca.state.mn.us/index.php?title=2020_MS4_General_Permit_Section_18_MCM_3:_Illicit_Discharge_Detection_and_Elimination MS4 General Permit requirements for MCM 3 - Illicit Discharge Detection and Elimination].
 
*[[media:IDDE procedure - Arden Hills.docx|Procedure for Illicit discharge detection and elimination]] - City of Arden Hills' procedure for investigating, locating, and eliminating the source of illicit discharges
 
*[[media:IDDE procedure - Arden Hills.docx|Procedure for Illicit discharge detection and elimination]] - City of Arden Hills' procedure for investigating, locating, and eliminating the source of illicit discharges
 
*[[media:Illicit Discharge Procedure -Cloquet.pdf|Procedure for Illicit discharge detection and elimination]] City of Cloquet's procedure for investigating, locating, and eliminating the source of illicit discharges
 
*[[media:Illicit Discharge Procedure -Cloquet.pdf|Procedure for Illicit discharge detection and elimination]] City of Cloquet's procedure for investigating, locating, and eliminating the source of illicit discharges
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===Training tools===
 
===Training tools===
 +
Below are examples, tools, or other resources to jump-start your illicit discharge detection and elimination training program.
 
*[[media:Employee Training - Columbia Heights.pdf|Good Housekeeping employee training example]] - The City of Columbia Heights' employee training presentation
 
*[[media:Employee Training - Columbia Heights.pdf|Good Housekeeping employee training example]] - The City of Columbia Heights' employee training presentation
 
*[https://prezi.com/-e3kqcpedn07/city-of-owatonna-ms4-employee-training-idde/ Annual MS4 employee training example] - City of Owatonna's employee training presentation
 
*[https://prezi.com/-e3kqcpedn07/city-of-owatonna-ms4-employee-training-idde/ Annual MS4 employee training example] - City of Owatonna's employee training presentation
 +
*[[media:MS4 Field Staff Training 180130.pptx| Illicit Discharge Staff Training]] - City of Big Lake's illicit discharge detection and elimination training presentation
 +
*[https://www.youtube.com/watch?v=hnXMaImmcKo Illicit Discharge Identification Training video] -  North Central Texas Council of Governments' (NCTCOG) illicit discharge detection and elimination video - what to look for and where illicit discharges may be observed
 +
*[https://youtu.be/Y6uWvOlaP44 Illicit Discharge Detection and Elimination Training video] - Minnesota Pollution Control (MPCA) illicit discharge detection and elimination training video
  
 
===Checklists===
 
===Checklists===
 +
These checklists can be used to meet the [https://stormwater.pca.state.mn.us/index.php?title=2020_MS4_General_Permit_Section_18_MCM_3:_Illicit_Discharge_Detection_and_Elimination MS4 General Permit requirement]  for incorporating illicit discharge inspections into municipal inspections.
 
*[[media:Rain_Garden_&_Bioretention_Systems_Inspection_Checklist.pdf|Rain garden/bioretention basin inspection checklist]] - University of Minnesota's (U of M) checklist for inspecting bioretention systems, such as rain gardens
 
*[[media:Rain_Garden_&_Bioretention_Systems_Inspection_Checklist.pdf|Rain garden/bioretention basin inspection checklist]] - University of Minnesota's (U of M) checklist for inspecting bioretention systems, such as rain gardens
 
*[[media:Constructed Wetlands Inspection Checklist.pdf|Constructed wetland inspection checklist]] - U of M's checklist for inspecting constructed wetlands
 
*[[media:Constructed Wetlands Inspection Checklist.pdf|Constructed wetland inspection checklist]] - U of M's checklist for inspecting constructed wetlands
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*[[media:Outfall Inspection Form - Rochester.pdf|Outfall inspection checklist]] - City of Rochester's checklist for inspecting outfalls
 
*[[media:Outfall Inspection Form - Rochester.pdf|Outfall inspection checklist]] - City of Rochester's checklist for inspecting outfalls
 
*[[media:Outfall Inspection Form - Arden Hills.docx|Outfall inspection checklist]] - City of Arden Hills' checklist for inspecting outfalls
 
*[[media:Outfall Inspection Form - Arden Hills.docx|Outfall inspection checklist]] - City of Arden Hills' checklist for inspecting outfalls
 +
*[[media:General Inspection Checklist - MN State.docx|Stockpile and storage/material handling area inspection checklist]] - Minnesota State's (MnSCU) checklist for inspecting stockpiles and storage/material handling areas
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[[Category:Level 3 - Regulatory/Municipal (MS4)/Guidance, outreach materials, miscellaneous information]]

Revision as of 22:39, 1 December 2022

This image shows a person collecting a water sample from an outfall
Image of a person collecting a water sample from an outfall

In Minnesota, our storm sewer systems carry water directly to our lakes, rivers, and wetlands. This water does not go to a treatment plant before entering our surface water. To maintain fishable, swimmable, and drinkable water and prevent pollution from entering our waterbodies, only stormwater should enter a storm sewer system. If anything else, such as oil, chemicals, or sediment, enters the system it is usually an illicit discharge. Minimum Control Measure (MCM) 3 of the MS4 General Permit requires permittees to develop and implement a program to detect and eliminate illicit discharges within their storm sewer system.

MS4 General Permit requirements for MCM 3

The illicit discharge detection and elimination (IDDE) program must include:

  • A map of the MS4 that includes all pipes 12 inches or greater and their flow direction; outfalls, including the unique identifier and geographic coordinates; municipally owned or operated structural stormwater best management practices (BMPs); and all receiving waters.
  • A regulatory mechanism to prohibit illicit discharges.
  • Cities, townships, and counties must implement a pet waste regulatory mechanism.
  • Cities and townships must implement a salt storage regulatory mechanism at commercial, institutional, and non-NPDES permitted industrial facilities.
  • The incorporation of illicit discharge detection into all municipal operation inspection and maintenance activities, such as those conducted on ponds, outfalls, and other structural stormwater BMPs. These inspections should be conducted during dry weather, when possible.
  • Detecting and tracking the source of illicit discharges using visual inspections.
  • Training of all field staff on illicit discharge recognition. Field staff includes, but is not limited to, police, fire department, public works, and parks staff.
  • Identifying priority areas likely to have illicit discharges by evaluating land uses associated with business and industrial activities, areas where illicit discharges have been observed in the past, areas with storage of large quantities of materials that could result in an illicit discharge. These locations should have additional illicit discharge inspections. In addition, these areas need to be kept in a written or mapped inventory.
  • Procedures for investigating, locating, and eliminating the source of illicit discharges.
  • Spill response procedures. These procedures must include the requirement to notify the Minnesota Duty Officer.
  • Enforcement Response Procedures to compel compliance with the illicit discharge prohibition regulatory mechanism.
  • Documentation as required here.

Resources

Click on the blue links above in the "MS4 General Permit requirements" section to get more information and resources specific to those permit requirements. In addition, all resources related to MCM 3 are below.

Fact sheets and guidance

Fact sheets and guidance documents should provide background information and tips to inform your approach to implementing MCM 3 - Illicit Discharge Detection and Elimination.

Model language

Fill in the blanks and adopt ordinance language that meets the regulatory mechanism requirements for MCM 3 - Illicit Discharge Detection and Elimination.

Documentation and tracking templates

Documentation and tracking templates are examples that local stormwater staff are currently using to meet the MS4 General Permit requirements for MCM 3 - Illicit Discharge Detection and Elimination.

Example procedures

Example procedures are those that local stormwater staff are currently using to meet the MS4 General Permit requirements for MCM 3 - Illicit Discharge Detection and Elimination.

Training tools

Below are examples, tools, or other resources to jump-start your illicit discharge detection and elimination training program.

Checklists

These checklists can be used to meet the MS4 General Permit requirement for incorporating illicit discharge inspections into municipal inspections.