Illicit Discharge Detection

& Elimination Programs

DuPage County Water Quality Stakeholders

June 14, 2006
 Presentation Overview

PART 1
Illicit Discharge Detection &
Elimination (IDDE) Program Development

PART 2
Example Programs
 Part 1 – Program Development
Phase II Minimum Controls
Construction Erosion Control IDDE Post Construction Controls

Housekeeping Practices Public Participation Public Education

Drain Goes to Stream

 IDDE Program Components
1. Develop Program Goals and Implementation Strategy
2. Research Existing Programs and Resources
3. Assign Responsibilities, Establish Authority, and Develop Tracking
Procedures
4. Develop Monitoring Approach
5. Perform Monitoring (Detect)
6. Locate and Eliminate Sources of Illicit Discharges (Eliminate)
Develop Detailed Procedures
 1. Program Goals and Implementation
Strategy
¼ Foundation: Notice of Intent / Permit
¼ Define Scope, Budget, Schedule
¼ Living document
 2. Research Existing Programs and
Resources

¼ Existing legal authority

¼ Existing ordinances (plumbing code, health dept. code, etc.)
¼ DRSCW
¼ TMDLs
¼ Departments and staff currently involved with IDDE (or can be)
¼ Existing outfall and storm sewer information
¼ Availability of lab resources
¼ Inventory available tools (boats, televising equipment, etc.)
¼ Existing funding sources
 3. Assign Responsibilities, Establish
Authority, and Develop Tracking Procedure

¼ Formalize community and department responsibilities

¼ Develop and adopt IDDE ordinance
¼ Develop tracking system
 4. Develop Monitoring Approach
¼ Develop program work maps
(outfalls, watersheds, land uses,
pipes, existing industrial permit
holders, historic violations, etc.)
¼ WHERE: Determine which MS4
outfalls are going to be monitored
¼ WHAT: Determine sampling
parameters
¼ LEVELS: Determine “allowable”
pollutant levels
¼ WHEN: Determine monitoring
frequency / follow-up triggers
¼ HOW: Detection and Elimination
procedures
 5. Perform Monitoring
(Detect)
COLLECT:
¼ Structural Condition
¼ Photographs
¼ Water Quality Samples
PERFORM:
¼ Testing (lab or kits)
¼ Evaluation of results
PREPARE:
¼ Work Orders
Violation Sources: Direct Connections
Violation Sources: Occasional Spills - Discharges
Violation Sources: Pipe Defects
 6. Locate and Eliminate
Sources of Illicit Discharges (Eliminate)

¼ Is a “hit” a Violation? (existing permit holders)

¼ Trace System to Source
¼ Take Corrective Action
System Sampling
Smoke Testing
Dye Water Testing – Televising
Sewer Inspections
 Contact Property Owner
¼ Provide notice to property owner
¼ Disconnect as soon as practicable (24 hours? 48 hours? Days?
Weeks?)

¼ Track and document corrective action

Part 2 – Example Programs
Racine, WI
An example of a fully implemented
and functioning IDDE Program
 City of Racine Statistics

¼ Population ~ 80,000
¼ “Fully Urbanized”
¼ 197,515 liner feet of storm sewer (37.4 miles)
¼ 113 “outfalls”
¼ 55 “major outfalls”
6 Root River – 26
6 “North Lake Michigan” – 8
6 “South Lake Michigan” – 13
6 Pike River - 8
 City of Racine Permit / Requirements
¼ Phase I/II hybrid (WPDES Root River Group Permit)
¼ Permit Start Date January 7, 2004
¼ Requirements
6 Ordinance Submittal to DNR by December 31, 2004 (Sec. 98-401
to 98-405 Adopted January 18, 2005)
6 IDDE Response Procedures due December 31, 2004
6 Initial IDDE Field Screening Completed by December 31, 2005
6 On-going Field Screening Program Proposal by December 31, 2005
6 Sewer System Map due December 31, 2006
City of Racine IDDE Program Development
¼ Program Review Included Public Works and Engineering
Departments
¼ IDDE Program
6 Overall Strategy (of inspection and education)
6 Initial Field Screening Procedures
• Outfalls
• Frequency
• Timing
• Sample Documentation Form
• Test Kit Procedures
• Initial Follow-up
City of Racine IDDE Program Development
¼ IDDE Program (cont)
6 On-going Field Screening Procedures
• Eliminated Dry and ‘Clean’ Outfalls
• Added Health Department Outfalls
6 Investigation Procedures
• Drainage System Review
• “Confirmation Sampling”
• Tracking Pollutant(s) of Interest (Isolation)
• “Windshield Survey”
City of Racine IDDE Program Development
¼ IDDE Program (cont)
6 Investigation Procedures “Toolbox”
• Individual Permit Review
• Building Plan Review
• Leak Detection Survey
• Televising
• Smoke Testing
• Dyed Water Testing
6 Elimination Procedures
6 Public Reporting Procedures
6 Sanitary Sewer Infiltration
 City of Racine 2005 Summer Monitoring

¼ Initial Monitoring Conducted Summer of 2005

¼ 55 Outfalls Identified for Monitoring
¼ Results:
63 Outfalls could not be located in the field
6 31 Outfalls “Wet”
61 Outfall (RR 57) Determined to be “Minor” but Tested Anyway
6 21 Outfalls Registered “hits” (6 with 2 Parameters)
• 12 Detergents
• 10 Chlorine
• 5 Copper
 City of Racine 2005 Fall/Winter Monitoring

¼ Second Monitoring Conducted November of 2005

¼ Results:
6 13 Outfalls “Wet” or Active
68 Outfalls Registered “hits” (1 with 2 Parameters)
• 4 Detergents
• 4 Chlorine
• 1 Copper
6 Good Correlation to Prior Results

¼ Total 2005 Program Costs ~$34,000

6 Sampling and report
 City of Racine 2006 Monitoring

¼ Will Conduct Monitoring at 8 Health Dept. Outfalls

¼ Will Conduct Prioritized Follow-up Investigation
6 Outfalls with 2 or more Parameters
6 Outfalls with Highest Individual Test Parameters

¼ Will Follow Investigation Procedures Outlined Previously

¼ Based on Entire 2005 Sampling Results
 Racine Program Budget
¼ 2006 IDDE Program Budget is $110,000
6 Annual field screening (11 outfalls)
6 Drainage system review (13 outfalls)
6 Isolation field screening (92 locations)
6 Leak detection survey (6 locations)
6 Televising assistance (10 locations)
6 Smoke testing (10 locations)
6 Dyed water testing (10 locations)
6 Connection elimination coordination
6 Annual report and monthly meetings
6 $50,000 in reserve
 City of Racine RR57 Disconnection

¼ Summer Screening Identified Suspect Illicit Connection

¼ NOT one of the Major Outfalls in Monitoring Program
¼ Wet – Constant but Variable Milky Flow (with Floatables)
¼ Tested Positive for Detergents and Copper
¼ Reported to City Following Observation
¼ Utilized City Televising Contract
¼ Identified Connection
¼ Notified Owner
¼ Owner Corrected
 Other IDDE Examples

¼ Cudahy
¼ St. Francis
¼ South Milwaukee
QUESTIONS /
DISCUSSION