iddep -pdf - deerfield regional stormwater district

21
Deerfield Regional Storm Water District Warren County, Ohio Illicit Discharge Detection and Elimination Plan October 2007 Prepared by: Camp Dresser & McKee, Inc.

Upload: others

Post on 11-Feb-2022

2 views

Category:

Documents


0 download

TRANSCRIPT

Page 1: iddep -pdf - Deerfield Regional Stormwater District

Deerfield Regional Storm Water District Warren County, Ohio

Illicit Discharge Detection and Elimination Plan

October 2007

Prepared by:

Camp Dresser & McKee, Inc.

Page 2: iddep -pdf - Deerfield Regional Stormwater District

Deerfield Regional Storm Water District Warren County, Ohio

Illicit Discharge Detection and Elimination Plan

1

1.0 Overview The Illicit Discharge Detection and Elimination Plan (IDDEP) is a program designed to prohibit and effectively eliminate illicit discharges and connections to Deerfield Township’s separate storm sewer system (MS4).

An illicit discharge is defined as any direct or indirect non-storm water discharge to the MS4. Certain types of illicit discharges, unless known to be a source of pollution, are allowable under U. S. EPA regulations and the Ohio EPA Phase II National Pollutant Discharge Elimination System (NPDES) General Permit for Discharges from MS4s:

In addition, Ohio EPA may authorize other types of small, intermittent non-storm water flows if provided sufficient justification that they do not cause pollution.

This IDDEP details DRSWD’s approach to illicit discharge related requirements of Ohio EPA’s permit. It fulfills requirements for minimum control measure (MCM) 3 of Deerfield Township’s Storm Water Management Plan (SWMP), submitted to Ohio EPA in March, 2003. This plan describes the specific responsibilities of the Township and the DRSWD under the SWMP. It includes a dry weather storm water outfall screening protocol and the plan and approach for investigation and elimination of specific types of discharges. Table 1 lists Ohio EPA permit requirements for illicit discharges and the Township’s corresponding response contained in its SWMP.

The Illicit Discharge Detection and Elimination Plan has been prepared by Camp Dresser & McKee, Inc. (CDM) on behalf of the DRSWD. The DRSWD is responsible for administering the plan and compiling compliance data for annual reporting to Ohio EPA.

Waterline flushing

Landscape irrigation

Diverted stream flows

Rising ground waters

Uncontaminated ground water (infiltration, pumped)

Springs

Water from crawl space pumps

Footing drains

Lawn watering

Individual residential car washing

Flows from riparian habitats / wetlands

Page 3: iddep -pdf - Deerfield Regional Stormwater District

Deerfield Regional Storm Water District Warren County, Ohio

Illicit Discharge Detection and Elimination Plan

2

Table 1. Ohio EPA and Deerfield Township Requirements for Minimum Control Measure No. 3

Ohio EPA Phase II NPDES General Permit

Requirements Deerfield Township’s Storm Water Management Plan Requirements

A storm sewer system map showing the location of all outfalls and the names and location of all waters of the United States that receive discharges from those outfalls.

Within the five (5) year permit term, the Township and the district will work with Warren County GIS to create a map of the home sewage treatment systems. An associated database containing the owner’s name and address as well as other information about the HSTS will be connected to the map by Warren County GIS. The District will complete the mapping on the following schedule: 2005 – 30%, 2006 – 35%, 2007 – 35%. After this mapping is complete, the District will be better able to identify problems with older sanitary sewer lines and will work with the Warren County Health Department on a case by case basis to correct these problems.

Within the five (5) year permit term, the Township and the district will work with the Warren County Engineer’s Office to develop a storm drain system map showing the location of all pipes, structures, outfalls, detention basins, and the names and locations of all surface waters of the state within the Township. The Township and the district will also develop and prioritize a list of outfalls that discharge into the Deerfield Township MS4, based on the degree of development and/or other determining factors. The District will complete this goal on the following schedule: 2005 – 30%, 2006 – 35%, 2007 – 35%.

A plan to detect and address non-stormwater discharges, including illegal dumping, into the MS4.

A survey during dry weather of twenty percent (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 again to detect suspected direct connections to the wastewater system and identify areas where wastewater might be leaking into adjacent storm water pipes. In 2005 the District will meet with the Warren County Health Department to discuss this screening.

Through an ordinance or other regulatory mechanism, a prohibition (to the extent allowable under State, Tribal or local law) on non-stormwater discharges into the MS4 and appropriate enforcement procedures and actions.

Draft regulatory guidelines will be developed within one (1) year after the formation of the proposed storm sewer district. Final regulations will be available within two (2) years after the establishment of the district. In any event, these regulatory mechanisms will require the implementation of proper erosion and sediment controls, and controls for other wastes, on applicable construction sites. These procedures will also include site plan review of construction plans that consider potential water quality impacts; procedures for site inspection and enforcement of control measures; sanctions to ensure compliance; and procedures for the receipt and consideration of information submitted by the public. Maximum compliance with the ordinance should be achieved after three (3) years. Improved clarity and reduced sedimentation of local water bodies should be measurable.

The education of public employees, businesses, and the general public about the hazards associated with illegal discharges and improper disposal of waste.

The Township will develop a plan to reduce spill prevention, including spill containment, spill response training and additional training to reduce pollution from Township facilities resulting from automobile maintenance, vehicle washing, and other pollution causing activities.

The district will secure brochures and/or fax sheets from Ohio EPA and USEPA and possibly develop its own newsletter or fact sheet to distribute to all residents of the Township throughout the five (5) year implementation. The Township will try to ensure that each resident receives at least one (1) publication. Additional distribution will be dictated by budget availability.

Page 4: iddep -pdf - Deerfield Regional Stormwater District

Deerfield Regional Storm Water District Warren County, Ohio

Illicit Discharge Detection and Elimination Plan

3

Visual Screening of Storm Water Outfalls Section 2 of the Illicit Discharge Detection and Elimination Plan describes three methods that will be used to detect the presence of illicit discharges:

Field Screening – The DRSWD in conjunction with CDM has developed a schedule for completing dry weather screening efforts prior to the end of 2007. The DRSWD and CDM have developed an inspection protocol for systematic visual screening of the storm water outfalls within the Township boundaries during a dry weather condition, where there has been no rain for two days prior to the field visit, so that all outfalls will have been inspected by the end of the 5-year permit term.

Citizen Complaint Calls – The Township maintains records of citizen complaints, including storm water related issues. The DRSWD will work with the Township to identify relevant citizen complaint records to assist in identifying potential illicit discharge issues.

Township Staff Observations – The Township will train its staff to increase awareness of illicit discharges that may be caused by municipal operation and maintenance practices, as well as to increase staff awareness for the detection and identification of existing illicit discharges discovered during the course of daily operations.

Source Location Reports of potentially illicit discharges received during the detection stage will be logged into a DRSWD-maintained database, with investigation and source location performed by the appropriate agency/department staff. Section 3 describes the various types of methods available to local communities for identifying the source of illicit discharges.

Outfall Mapping – The DRSWD in conjunction with CDM is developing a map of storm water outfalls in support of the illicit discharge detection and elimination program.

Data Management and Reporting – The DRSWD in conjunction with CDM has developed a database for tracking field observations resulting from the dry weather outfall screening efforts.

Investigations – The investigation protocol in Section 3 documents the various methods available for investigating the nature and source of different illicit discharge types.

Source Elimination Section 4 outlines the approach the DRSWD will take to eliminate illicit discharges once their source is identified. This Plan provides several enforcement tools that the DRSWD will implement to facilitate illicit discharge elimination:

Page 5: iddep -pdf - Deerfield Regional Stormwater District

Deerfield Regional Storm Water District Warren County, Ohio

Illicit Discharge Detection and Elimination Plan

4

Illicit Discharge Detection and Elimination Regulations – The DRSWD will develop regulations supplemental to existing state law as well as current Warren County and Deerfield Township regulations/resolutions to provide enforcement authorities for the elimination of identified illicit discharges.

Enforcement Protocol – The Plan identifies appropriate agencies/departments with authority to assist with investigation and elimination of specific types of illicit discharges (see Section 4.0, Table 2).

2.0 Visual Screening of Storm Water Outfalls A multi-faceted illicit discharge detection program has been established. Under this program, illicit discharges are identified through three primary methods:

Dry weather outfall screening

Receipt of complaint calls from the general public, and

Identification of illicit discharges by Township staff during the course of daily operations.

This section describes this program and the various agencies responsible for carrying out specific elements of the IDDEP.

2.1 Dry Weather Outfall Screening Dry weather outfall screening involves locating outfalls from the MS4 and collecting evidence of dry weather discharges from these outfalls. The objective of dry weather field screening is to develop an overall assessment of dry weather discharges from MS4s, based on the volume and quality of observed discharges, in order to target future illicit discharge investigations toward sources with the highest probability of causing water quality impairment. The storm water outfall locations within the Township currently known to the DRSWD are shown on Figure 1, which were collected during summer 2006 and summer 2007. Ohio EPA has indicated that they expect communities to field screen all MS4 outfalls during the initial 5-year permit term, ending in 2007. This section lays out the DRSWD’s dry weather field screening protocol.

2.1.1 Establish Priority Areas for Dry Weather Field Screening CDM developed priority areas for dry weather screening prior to initiation of the 2006 outfall screening field work. Table 1 lists various types of illicit discharges and indicates the priority for control based upon discussions between the DRSWD and CDM. Highest priority illicit discharges are potentially located throughout the Township; therefore, priorities for outfall screening were based largely on geographic and logistical issues.

Page 6: iddep -pdf - Deerfield Regional Stormwater District

Deerfield Regional Storm Water District Warren County, Ohio

Illicit Discharge Detection and Elimination Plan

5

Figure 1 – Known outfall locations within Deerfield Township Boundaries

Page 7: iddep -pdf - Deerfield Regional Stormwater District

Deerfield Regional Storm Water District Warren County, Ohio

Illicit Discharge Detection and Elimination Plan

6

Table 1. Priority Types of Illicit Discharges within Deerfield Township

Source of Illicit Discharge Responsible Department / Agency Priority

Home Sewage Treatment Systems (HSTSs) Warren County Health Department XXX

Hazardous Materials (HAZMAT) Deerfield Township Fire Rescue Department; the Ohio EPA XXX

Spills / Accidents Deerfield Township Fire Department XXX

Illegal Connections to Storm Sewers Warren County Water and Sewer Department XXX

Dumping Warren County Health Department X

Food Services Warren County Health Department \

Homeowner Property Maintenance Warren County Health Department \

Industry Ohio EPA \ Legend XXX – High Priority Illicit Discharge XX – Moderate Priority Illicit Discharge X – Low Priority Illicit Discharge \ – Addressed on case-specific basis

2.1.2 Inspection Protocol The DRSWD, in conjunction with CDM, developed a protocol for systematically inspecting storm water outfalls. This protocol includes the following key elements:

1. Dry weather screening activities was performed between mid-June and late September 2006, and during July 2007.

2. Screening activities were conducted concurrent with GPS mapping of outfall

locations during dry weather conditions following a period of at least 48 hours without precipitation.

3. Field teams were comprised of two staff members.

4. A field form was completed for each outfall location to document visual

observations as described in item 5 below.

Page 8: iddep -pdf - Deerfield Regional Stormwater District

Deerfield Regional Storm Water District Warren County, Ohio

Illicit Discharge Detection and Elimination Plan

7

5. At a minimum, dry weather screening activities involved observations of the following physical characteristics:

Flows during dry weather conditions Water clarity and color Presence of foam, oil sheen, trash, and/or floatable materials* Presence of bacterial sheen or slimes* Staining of the banks, outfall structure, and/or vegetation* Excessive vegetative growth* Odor*

* These characteristics were documented even if no flow was observed at the time of inspection.

6. Confirmation of suspected illicit discharges/connections was performed via

documented visual observation at the dry weather screening stage, and will be followed up with one or more of the following measures during the investigation and elimination phase:

Chemical and bacterial sampling Televising sewer pipes Dye testing of sewers and/or facilities Smoke testing

7. Field teams utilized the following equipment in performing the outfall inventory

and field screening efforts:

GPS unit Backpack or satchel Digital camera Clipboard with field forms Walkie-talkie / cell phone Tape measure First aid kit Sanitizing hand wash Latex gloves Boots / waders OSHA yellow vests Rain gear Long pants / jeans Letter from Deerfield Regional Storm Water District

Appendix A contains the field data collection form used in the outfall screening process.

Page 9: iddep -pdf - Deerfield Regional Stormwater District

Deerfield Regional Storm Water District Warren County, Ohio

Illicit Discharge Detection and Elimination Plan

8

2.2 Township Staff Observations During normal daily operations conducted by Township staff, these staff may observe evidence of illicit discharges. In addition, these staff may conduct their routine activities in a manner that results in an illicit discharge. Under this Plan, staff will be trained regarding illicit discharges and provided information on appropriate channels for reporting them. This training is closely aligned with training regarding pollution prevention/good housekeeping activities under Minimum Control Measure (MCM) 6, and will be incorporated into a comprehensive training program under this MCM. Field staff that will participate in illicit discharge detection and elimination related activities will be trained regarding:

what are illicit discharges/connections;

techniques for finding and identifying illicit discharges/connections;

techniques for analyzing and recording;

proper methods/procedures for eliminating the illicit discharges/connections;

recognition of naturally occurring phenomena and their sources (bacterial sheens, slimes and films, bryozoans, pollen, blue-green algae and green algae, tannins and foams)

3.0 Illicit Discharge Source Identification Evidence gained through the illicit discharge detection methods described in Section 2 is used to identify the specific source of the illicit discharge. This section describes three specific methods the DRSWD anticipates using for identifying illicit discharges:

Stream and outfall mapping

Database management and reporting

Drainage system investigations

3.1 Stream and Outfall Mapping The Township and the DRSWD are responsible for mapping the following information:

Streams and other waterbodies

The entire MS4 within the Township, including outfalls

Home Sewage Treatment Systems (HSTSs)

Portions of the MS4 that convey discharges from HSTSs to waterbodies

Page 10: iddep -pdf - Deerfield Regional Stormwater District

Deerfield Regional Storm Water District Warren County, Ohio

Illicit Discharge Detection and Elimination Plan

9

The Township and the DRSWD either currently have or are in the process of developing each of these map components.

3.2 Data Management and Reporting The dry weather outfall screening protocol contains an example field data sheet (Appendix A) for recording field observations of illicit discharges. These data are incorporated into an electronic database containing geographic references that allow the outfall information to be mapped and otherwise integrated with the Township’s future GIS system.

3.3 Investigation Protocol Various options exist for source investigation of identified illicit discharges. Commonly used methods include manhole observations, video inspection, smoke testing, dye testing, aerial infrared and thermal photography, and tracking of illegal dumping. In the event that Township staff receives notification of a potentially illicit discharge, in most if not all cases Township staff will serve as the initial responder for such reports. If the location of the observed discharge falls outside the Township’s jurisdiction (i.e., beyond the public right-of-way) or the investigation of the discharge requires resources and/or expertise beyond the Township’s capabilities, the Township staff will refer the investigation to the DRSWD. Regardless of who performs the investigation, the investigator should first develop a plan based on the outfall screening data and other sewer system and land use data available to the jurisdiction. This plan should provide a rational basis for selecting an appropriate investigation method or combination of methods based upon the field observations and/or the understood nature of the identified discharge. A more detailed discussion of each method is provided below.

3.3.1 Manhole Observations This technique involves following dry-weather flows upstream along the drainage system to determine the potential boundaries of the illicit discharge source. This effort normally includes consulting the drainage system map to determine the next upstream manhole with a junction to search for evidence of discharge. This effort is repeated until a junction is found with no evidence of discharge. At this point, the inference can be drawn that the discharge source is likely located between the junction with no evidence of discharge and the next downstream junction at which signs of the discharge were observed. This investigation method is generally necessary before conducting other investigation efforts.

3.3.2 Video (CCTV) Inspection Mobile video cameras can be utilized to examine storm sewers to identify potential illegal connections to the storm drainage system. This method is beneficial in identifying the source of the illegal discharge as well as creating a VHS or DVD video record of the discharge source.

Page 11: iddep -pdf - Deerfield Regional Stormwater District

Deerfield Regional Storm Water District Warren County, Ohio

Illicit Discharge Detection and Elimination Plan

10

3.3.3 Smoke Testing This method involves injection of non-toxic smoke into storm sewers and subsequently noting the emergence of smoke from sanitary sewer vents in buildings with illegal connections to the storm sewers or from cracks and leaks in the storm sewer lines. The process includes the placement of a smoke bomb or smoke generating machine in a storm sewer manhole below ground and forcing air in afterward.

Note: Professionals in the field have found that the smoke-test method is more effective in infiltration/inflow investigations of the sanitary sewer system than in detection of illegal connections to the storm sewer system.

3.3.4 Dye Testing This method involves flushing non-toxic dye into toilets and sinks and subsequently observing storm sewer and sanitary sewer manholes and storm sewer outfalls and looking for the presence of dye. Notification of building owners and occupants in advance of the performance of this type of testing is required as is obtaining permission for entry, and notification of local public health and state water quality staff in the event that they receive calls from concerned citizens who observe the dye in surface waters.

3.3.5 Aerial Infrared and Thermal Photography This method can be used to locate discharges from outfalls and failing septic systems by using temperature and vegetation as interpretive markers. This method requires special expertise in interpretation of aerial photography. It is still a developing technology and is not commonly used in illicit discharge detection and elimination applications.

3.3.6 Tracking Illegal Dumping This approach involves the development of a coordinated system for collecting and tracking reports of illegal dumping. It also involves investigating the dumped material for evidence about the entity that dumped the material and information about the material to facilitate design of an appropriate cleanup method. This type of system can help pinpoint this commonly elusive source of illicit discharges.

3.3.7 Investigation Costs The following cost information has been abstracted from Illicit Discharge Detection and Elimination: A Guidance Manual for Program Development and Technical Assessments (CWP 2004). Smoke, dye, and video investigation methods are relatively costly and staff intensive. The budget for implementation of these methods is dependent on investigation specific factors such as the complexity of the drainage network, density and age of buildings, and complexity of the surrounding land use. Wayne County, Michigan estimated dye testing costs at $900 per facility (CWP 2004). Video testing ranges from approximately $1.50 to $2.00 per linear foot of pipe, though the cost increases by $1.00 per foot in the event that pipe cleaning is required prior to investigation (CWP 2004). Aerial infrared thermography is a very expensive option,

Page 12: iddep -pdf - Deerfield Regional Stormwater District

Deerfield Regional Storm Water District Warren County, Ohio

Illicit Discharge Detection and Elimination Plan

11

with costs for cameras alone ranging from $250,000 to $500,000 (CWP 2004). Additional detailed cost information for equipment required to perform various illicit discharge investigation methods is provided in Appendix B (CWP 2004).

4.0 Illicit Discharge Elimination Ohio EPA’s permit requires the Township to establish the necessary legal authority to detect, investigate, and eliminate illicit discharges. The limitations of the Township’s statutory authority for this and other elements of the Phase II NPDES requirements led to the formation of the DRSWD. The DRSWD will develop regulatory provisions to include:

An evaluation of existing Warren County and Township Departments, including the Warren County Health Department, the Deerfield Township Fire Department, the Ohio EPA, and provisions of standard Ohio building, plumbing, and fire codes adopted by most communities. It is likely that the County and Township departments already have extensive legal authority to address many types of illicit discharges.

Dedicated DRSWD regulations to solidify the necessary legal authorities for illicit discharge detection and elimination.

This section outlines a consistent enforcement approach in the event that an illicit discharge is identified, either as a result of dry weather screening activities or as part of a follow-up investigation of identified priority areas. The type of discharge that is observed will determine the level of coordination necessary for further investigation and elimination of the discharge, involving the appropriate department or agency.

4.1 Illicit Discharge Regulations The DRSWD will adopt regulatory provisions for illicit discharge detection and elimination in 2007. These regulations are expected to include provisions to access and inspect suspected illegal discharges from and illicit connections to municipal separate storm sewer systems (MS4s) within the DRSWD boundaries. These regulations will also define allowable and prohibited discharges, and establish penalties related to continued violation of the regulations by failure to disconnect an identified illicit discharge.

4.2 Enforcement If the nature and source of an identified illicit discharge is clearly understood, then the DRSWD will either take enforcement action or directly refer enforcement to the appropriate agency/department. Table 2 summarizes the various types of illicit discharges and the corresponding agencies/departments with enforcement authority for a particular discharge type. It also identifies the portions of applicable state and local regulatory provisions conferring authority to certain agencies/departments to deal with specific illicit discharge types. If the nature and/or source of the observed or reported discharge is/are not thoroughly understood, additional investigation must be

Page 13: iddep -pdf - Deerfield Regional Stormwater District

Deerfield Regional Storm Water District Warren County, Ohio

Illicit Discharge Detection and Elimination Plan

12

performed to determine the nature of the discharge and/or identify the source. Once the nature and source of the identified discharge is understood, the appropriate agency/department will be contacted to coordinate the elimination of the illicit discharge.

Table 2. Relevant Sections of the Applicable Regulations Enabling Elimination of

Various Types of Illicit Discharges

Source of Illicit Discharge

Responsible Agency / Department and Phone Number

Relevant Section(s) of State and Local Regulations

HSTSs Warren County Health Department (Phone: 513-695-1228)

Ohio Administrative Code 3701-29 – Household Sewage Disposal Systems – This portion of Ohio state law establishes standards to be enforced by the local board of health for siting, design, installation, alteration, operation, monitoring, maintenance, and abandonment of HSTSs to protect public health and the environment.

HAZMAT

Deerfield Township Fire Rescue Department (Phone: 513-459-0875) OR The Ohio EPA Emergency Response Unit (Phone: 800-282-9378 or 614-644-3196)

Ohio Administrative Code 1301-7-7-27 – (3) 2703.3 Release of hazardous materials. Hazardous materials in any quantity shall not be released into a sewer, storm drain, ditch, drainage canal, creek, stream, river, lake or tidal waterway or on the ground, sidewalk, street, highway or into the atmosphere.

Exceptions: 1. The release or emission of hazardous materials is allowed when in compliance with federal, state, or local governmental agencies, regulations or permits. 2. The release of pesticides is allowed when used in accordance with registered label directions. 3. The release of fertilizer and soil amendments is allowed when used in accordance with manufacturer's specifications.

(a) 2703.3.1 Unauthorized discharges. When hazardous materials are released in quantities reportable under state, federal or local regulations, the fire code official shall be notified and the following procedures required in accordance with paragraphs (C)(3)(a)(i)(2703.3.1.1) to (C)(3)(a)(iv)(2703.3.1.4) of this rule.

(i) 2703.3.1.1 Records. Accurate records shall be kept of the unauthorized discharge of hazardous materials by the responsible person.

(ii) 2703.3.1.2 Preparation. Provisions shall be made for controlling and mitigating unauthorized discharges

(iii) 2703.3.1.3 Control. When an unauthorized discharge caused by primary container failure is discovered, the involved primary container shall be repaired or removed from service. (iv) 2703.3.1.4 Responsibility for cleanup. The person, firm or corporation responsible for an

Page 14: iddep -pdf - Deerfield Regional Stormwater District

Deerfield Regional Storm Water District Warren County, Ohio

Illicit Discharge Detection and Elimination Plan

13

Table 2. Relevant Sections of the Applicable Regulations Enabling Elimination of Various Types of Illicit Discharges

Source of Illicit Discharge

Responsible Agency / Department and Phone Number

Relevant Section(s) of State and Local Regulations

unauthorized discharge shall institute and complete all actions necessary to remedy the effects of such unauthorized discharge, whether sudden or gradual, at no cost to the jurisdiction. When deemed necessary by the fire code official, cleanup may be initiated by the fire department or by an authorized individual or firm. Costs associated with such cleanup shall be borne by the owner, operator or other person responsible for the unauthorized discharge.

Spills / Fires / Accidents Deerfield Township Fire Rescue Department (Phone: 513-459-0875) Same as above

Illegal Connections to Storm Sewers

Warren County Water & Sewer Department (Phone: 513-695-1377) Warren County Water & Sewer Regulations

Dumping Warren County Health Department (Phone: 513-695-1228)

Ohio Administrative Code 3745-27-5 (C) - No person shall conduct, permit, or allow open dumping. In the event that open dumping is occurring or has occurred at a property, the person(s) responsible for the open dumping, the owner of the property, or the person(s) who allow or allowed open dumping to occur, shall promptly remove and dispose or otherwise manage the solid waste in accordance with Chapter 3734, of the Revised Code, and shall submit verification that the solid waste has been properly managed.

Ohio Revised Code 3767-14 - No person shall intentionally throw, deposit, or permit to be thrown or deposited, coal dirt, coal slack, coal screenings, or coal refuse from coal mines, refuse or filth from a coal oil refinery or gasworks, or whey or filthy drainage from a cheese factory, into a river, lake, pond, or stream, or a place from which it may wash therein. No person shall cause or permit petroleum, crude oil, refined oil, or a compound, mixture, residuum of oil or filth from an oil well, oil tank, oil vat, or place of deposit of crude or refined oil, to run into or be poured, emptied, or thrown into a river, ditch, drain, or watercourse, or into a place from which it may run or wash therein. Prosecution for a violation of this section must be brought in the county in which such coal mine, coal oil refinery, gasworks, cheese factory, oil well, oil tank, oil vat, or place of deposit of crude or refined oil is situated.

Food Services Warren County Health Department (Phone: 513-695-1228)

Ohio Administrative Code 3717-1-5.4 - Requires that waste and refuse receptacles at food service establishments to be leak-proof (Section D) and in good repair (Section L).

Homeowner Property Maintenance

Warren County Health Department (Phone: 513-695-1228)

Ohio Administrative Code 3701-36-15 - Nuisance control - Each board of health shall

Page 15: iddep -pdf - Deerfield Regional Stormwater District

Deerfield Regional Storm Water District Warren County, Ohio

Illicit Discharge Detection and Elimination Plan

14

Table 2. Relevant Sections of the Applicable Regulations Enabling Elimination of Various Types of Illicit Discharges

Source of Illicit Discharge

Responsible Agency / Department and Phone Number

Relevant Section(s) of State and Local Regulations

provide environmental health services in such a manner that the community may be free of public health nuisances. To comply with minimum standards under this rule, each local health department shall abate reported public health nuisances by:

(A) Responding to all complaints received within an appropriate time (performance indicator: log of complaints received and time of response);

(B) Identifying those complaints that are public health nuisances within an appropriate time (performance indicator: record of investigations);

(C) Resolving public health nuisances within an appropriate time (performance indicator: record of actions taken and results).

Industry

Ohio EPA Central Office Storm Water Section (Phone: 614-728-3392)

OEPA General Industrial Permit No. OHR000003 - addresses industrial storm water discharges pursuant to Phase I NPDES.

Page 16: iddep -pdf - Deerfield Regional Stormwater District

Deerfield Regional Storm Water District Warren County, Ohio

Illicit Discharge Detection and Elimination Plan

15

APPENDIX A DRSWD

Storm Water Outfall Inspection Form

Page 17: iddep -pdf - Deerfield Regional Stormwater District

16

Insp

ectio

n Im

age

Anal

ytic

al R

esul

tsLa

b An

alys

is ID

: An

alyz

ed B

y:Fe

cal C

olifo

rm:

(Col

onie

s/10

0 m

l)Am

mon

ia (m

g/l):

Tem

pura

ture

(C):

pH:

Con

duct

ance

(us)

:Ph

osph

orus

(mg/

l):D

is O

xyge

n (m

g/l):

Com

men

ts:

Rec

omm

enda

tions

Act

ion

Req

uire

d:

N

o

P

erfo

rm P

robl

em S

ourc

e In

vest

igat

ion

Sam

plin

g St

rate

gy:

Oth

er P

aram

eter

s/R

esul

ts

Des

crip

tion:

Sam

ple

Col

lect

ed:

Yes

N

oS

ampl

e ID

:

Com

men

ts:

Out

fall

ID N

o.R

ecei

ving

Stre

am:

Com

mun

ity:

Cre

w M

embe

r:C

rew

Mem

ber:

Tim

e of

Las

t Rai

n:

>

48 h

rs

<72

hrs

>

72 h

rs

Cre

w L

eade

r:

Pro

ject

:In

spec

tion

Info

rmat

ion

Insp

ectio

n D

ate:

Tim

e:

Ty

pe:

Loca

tion

Des

crip

tion:

Age

ncy:

Dep

artm

ent:

Pip

e Fl

ow:

Non

e

<1

/4 p

ipe

<1/2

pip

e

<

3/4

pipe

Ful

l

C

omm

ents

:

Ful

l

T

rickl

eP

ipe

Subm

erge

nce:

Non

e

<1/

4 pi

pe

<

1/2

pipe

<3

/4 p

ipe

Sam

plin

g In

form

atio

n

Page 18: iddep -pdf - Deerfield Regional Stormwater District

Deerfield Regional Storm Water District Warren County, Ohio

Illicit Discharge Detection and Elimination Plan

17

APPENDIX B (CWP 2004)

Page 19: iddep -pdf - Deerfield Regional Stormwater District

18

Common Field Equipment Needed for Dye, Video, and Smoke Testing (2004 costs)

Item Approximate Cost 1 Digital Camera $200 Clipboards, Pens, Batteries $25 1 Field Vehicle $15,000 - $35,000 1 First Aid Kit $30 1 Spotlight $40 1 Gas Monitor and Probe $900 - $2,100 1 Hand-held GPS Unit $150 2 Two-way Radios/ Cell Phones

$250 - $750

1 Manhole Hook $80 - $130 1 Mirror $70 - $130 2 Reflective Safety Vests $40 Rubber/Latex Gloves (box of 100)

$25

1 Can of Spray Paint $5 4 Traffic Cones $50

Equipment Costs for Dye Testing (2004 costs)

Product Water Volume Cost

Dye Strips 1 strip / 500 gallons $75 - $94 per 100 strips

Dye Tablets 0 – 50,000 gallons $40 per 200 tablets

Liquid Concentrate (Rhodamine WT) 0 – 50,000 gallons $80 - $90 per gallon $15 - $20 per pint

Powder 50,000 + gallons $77 per lb

Dye Wax Cakes 20,000 – 50,000 gallons $12 per one 1.25 ounce cake

Dye Wax Donuts 50,000 + gallons $104 - $132 per 42 oz. donut Price Sources: Aquatic Eco-Systems http://www.aquaticeco.com/ Cole Parmer http:/www.coleparmer.com USA Blue Book http:/www.usabluebook.com

Page 20: iddep -pdf - Deerfield Regional Stormwater District

19

Equipment Costs for Video Testing (2004 Costs) Equipment Cost

GEN-EYE 2TMB&W Sewer Camera with VCR & 200’ Push Cable $5,800 100’ Push Rod and Reel Camera for 2” – 10” Pipes $5,300 200’ Push Rod and Reel Camera for 8” – 24” Pipes $5,800

Custom Saturn III Inspection System 500’ cable for 6-16” Lines

$32,000 ($33,000 with 1000 foot cable)

OUTPOST • Box with build-out $6,000 • Generator $2,000 • Washdown system $1,000 Video Inspection Trailer • 7’x10’ trailer & build-out $18,500 • Hardware and software package $15,000 • Incidentals $5,000 Sprinter Chassis Inspection Vehicle • Van (with build-out for inspecting 6” – 24” pipes) $130,000 • Crawler (needed to inspect pipes >24”) $18,000 • Software upgrade (optional but helpful for extensive pipe systems) $8,000 Sources: USA Blue Book and Envirotech

Equipment Costs for Smoke Testing Equipment Cost

Smoke Blower $1,000 to $2,000 each Liquid Smoke $38 to $45 per gallon Smoke Candles, 30 second (4,000 cubic feet) $27.50 per dozen Smoke Candles, 60 Second (8,000 cubic feet) $30.50 per dozen Smoke Candles, 3 Minute (40,000 cubic feet) $60.00 per dozen Sources: Hurco Tech, 2003 and Cherne Industries, 2003

Page 21: iddep -pdf - Deerfield Regional Stormwater District

20

Methods to Eliminate Discharges

Technique Application Description Estimated Cost

1. Service Lateral Disconnection, Reconnection

Lateral is connected to the wrong line

Lateral is disconnected and reconnected to appropriate line $2,5001

2. Cleaning Line is blocked or capacity diminished

Flushing (sending a high pressure water jet through the line); pigging (dragging a large rubber plug through the lines); or rodding $1 / linear foot2

3. Excavation and Replacement

Line is collapsed, severely blocked, significantly misaligned, or undersized

Existing pipe is removed, new pipe placed in same alignment; Existing pipe abandoned in place, replaced by new pipe in parallel alignment

For 14” line, $50-$100 / linear foot (higher number is associated with repaving or deeper excavations, if necessary)2

4. Manhole Repair

Decrease ponding; prevent flow of surface water into manhole; prevent groundwater infiltration

Raise frame and lid above grade; install lid inserts; grout, mortar or apply shortcrete inside the walls; install new precast manhole.

Vary widely, from $250 to raise a frame and cover to ~ $2,000 to replace manhole2

5. Corrosion Control Coating Improve resistance to corrosion

Spray- or brush-on coating applied to interior of pipe. < $10 / linear foot2

6. Grouting Seal leaking joints and small cracks Seals leaking joints and small cracks.

For a 12” line, ~ $36-$54 / linear foot2

7. Pipe Bursting Line is collapsed, severely blocked, or undersized

Existing pipe used as guide for inserting expansion head; expansion head increases area available for new pipe by pushing existing pipe out radially until it cracks; bursting device pulls new pipeline behind it

For 8” pipe, $40-$80 / linear foot4

8. Slip Lining

Pipe has numerous cracks, leaking joints, but is continuous and not misaligned

Pulling of a new pipe through the old one.

For 12” pipe, $50-$75 / linear foot2

9. Fold and Formed Pipe

Pipe has numerous cracks, leaking joints

Similar to sliplining but is easier to install, uses existing manholes for insertion; a folded thermoplastic pipe is pulled into place and rounded to conform to internal diameter of existing pipe

For 8-12” pipe, $60-$78 / linear foot3

10. Inversion Lining

Pipe has numerous cracks, leaking joints; can be used where there are misalignments

Similar to sliplining but is easier to install, uses existing manholes for insertion; a soft resin impregnated felt tube is inserted into the pipe, inverted by filling it with air or water at one end, and cured in place. $75-$125 / linear foot2

1CWP (2002) 21991 costs from Brown (1995) 3U.S. EPA (1991) 4U.S. EPA (1999b)