Stormwater Management
Illicit Discharge Detection and Elimination
The illicit discharge detection and elimination (IDDE) minimum control measure consists of best management practices (BMPs) and program elements that focus on finding and addressing non-stormwater discharges and/or non-permitted discharges that may be entering the municipal separate storm sewer system (MS4).
Regulated MS4s are required to establish plans to detect and eliminate illicit discharges including discharges not composed entirely of stormwater. They must map all outfalls from the storm sewer system to surface waters (not only from pipes, but also from road ditches, swales and other stormwater carriers), and must inform public employees and the community about the hazards of illegal discharges and improper waste disposal. Further, illicit discharges to the storm sewer system must be prohibited by ordinance or regulation, and the prohibition must be enforced.
The MS4 is required to develop and maintain a map showing: the location of all outfalls and the names and location of all surface waters of the State that receive discharges from those outfalls. By March 9, 2010, the preliminary boundaries of the permittee's storm sewersheds should be determined using GIS or other tools, even if they extend outside of the urbanized area. This will help facilitate trackdown of illicit discharges. When grant funds are made available, a map of the sewer lines and storm sewer system should be completed.
The MS4 is required to field verify outfall locations and conduct an outfall reconnaissance inventory that addresses every outfall within the MS4 designated area at least once every five years.
An IDDE program should also address non-stormwater discharges, including illegal dumping. The program must include: procedures for identifying priority areas of concern (geographic, audiences, or otherwise); a description of priority areas of concern, available equipment, staff, funding, etc.; procedures for identifying and locating illicit discharges (trackdown); procedures for eliminating illicit discharges; and procedures for documenting actions.
To meet the IDDE program requirements, the MS4 has selected the following Best Management Practices (BMP's) and activities to ensure the reduction of all pollutants of concern in stormwater discharges to the maximum extent practicable.
Outfall Mapping Description of BMP/Activity:
Create and maintain a map of all storm sewer system outfalls and identify the names of receiving waterbodies. The map will identify each outfall with a unique identifier and will link the outfall to a table of outfall properties collected
Staff, Agency, and/or Organization Reponsible for Completing this Activity:
Frequency of Activity:
Status - Program Development:
[X] Completed - This activity has been completed
[ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. Status - Implementation:
[ ] Completed - This activity has been completed
[ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [X] On-Going - This activity will be undertaken throughout all years of the permit. |
Total Storm Sewer System Mapping Description of BMP/Activity:
Create and maintain a map of the entire storm sewer system including features such as connecting pipes, catch basins, manholes, and outfalls. Additional information collected may include, but is not limited to: direction of flow, pipe type and size, number of inputs and outputs, and condition of the feature.
Staff, Agency, and/or Organization Reponsible for Completing this Activity:
Frequency of Activity:
Status - Program Development:
[X] Completed - This activity has been completed
[ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. Status - Implementation:
[ ] Completed - This activity has been completed
[ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [X] On-Going - This activity will be undertaken throughout all years of the permit. |
Illicit Discharge Detection and Elimination (IDDE) Law or Ordinance Description of BMP/Activity:
Draft, adopt and enforce a stormwater management ordinance or other regulatory mechanism to prohibit illicit discharges.
Staff, Agency, and/or Organization Reponsible for Completing this Activity:
Frequency of Activity:
Status - Program Development:
[X] Completed - This activity has been completed
[ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. Status - Implementation:
[ ] Completed - This activity has been completed
[ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [X] On-Going - This activity will be undertaken throughout all years of the permit. |
Administration of IDDE Programs and Policy Description of BMP/Activity:
Establish IDDE program responsibility, communication, coordination and authority within local departments and agencies. Evaluate existing capabilities, identify needs and designate key staff and their roles in the IDDE program. This activity may also involve the creation of a tracking system to document local management response and enforcement efforts.
Staff, Agency, and/or Organization Reponsible for Completing this Activity:
Frequency of Activity:
Status - Program Development:
[X] Completed - This activity has been completed
[ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. Status - Implementation:
[ ] Completed - This activity has been completed
[ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [X] On-Going - This activity will be undertaken throughout all years of the permit. |
Employee Education and Training Description of BMP/Activity:
Inform and educate employees on the hazards associated with illicit discharges
Staff, Agency, and/or Organization Reponsible for Completing this Activity:
Frequency of Activity:
Status - Program Development:
[X] Completed - This activity has been completed
[ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. Status - Implementation:
[ ] Completed - This activity has been completed
[ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [X] On-Going - This activity will be undertaken throughout all years of the permit. |
Inform and Educate Businesses and Industry Description of BMP/Activity:
Inform and educate local businesses and industry regarding the hazards associated with illicit discharges
Staff, Agency, and/or Organization Reponsible for Completing this Activity:
Frequency of Activity:
Status - Program Development:
[X] Completed - This activity has been completed
[ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. Status - Implementation:
[ ] Completed - This activity has been completed
[ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [X] On-Going - This activity will be undertaken throughout all years of the permit. |
Inform and Educate the General Public Description of BMP/Activity:
Inform and educate the general public regarding the hazards associated with illicit discharges
Staff, Agency, and/or Organization Reponsible for Completing this Activity:
Frequency of Activity:
Status - Program Development:
[X] Completed - This activity has been completed
[ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. Status - Implementation:
[ ] Completed - This activity has been completed
[ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [X] On-Going - This activity will be undertaken throughout all years of the permit. |
Storm Drain Stenciling Program Description of BMP/Activity:
Install and maintain permanent markers on all stormwater system catch basins and other stormwater system features that inform individuals that dumping is prohibited as the storm system drains to a nearby lake or stream
Staff, Agency, and/or Organization Reponsible for Completing this Activity:
Frequency of Activity:
Status - Program Development:
[X] Completed - This activity has been completed
[ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. Status - Implementation:
[ ] Completed - This activity has been completed
[ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [X] On-Going - This activity will be undertaken throughout all years of the permit. |
IDDE Hotline Description of BMP/Activity:
Establish a hotline by telephone, as a web-based tool, or by other means where the general public can contact the MS4 to report suspected IDDE issues
Staff, Agency, and/or Organization Reponsible for Completing this Activity:
Frequency of Activity:
Status - Program Development:
[X] Completed - This activity has been completed
[ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. Status - Implementation:
[ ] Completed - This activity has been completed
[ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [X] On-Going - This activity will be undertaken throughout all years of the permit. |
Dye/Smoke Testing Description of BMP/Activity:
Dye testing and/or smoke testing generally assist in the detection and tracking of illicit discharges and help to pin-point the exact source of the discharge. These techniques involve flushing non-toxic dye or injecting non-toxic smoke into storm sewer lines or other features, then noting the presence of the indicator in illegal connections, cracks, outfalls, etc.
Staff, Agency, and/or Organization Reponsible for Completing this Activity:
Frequency of Activity:
Status - Program Development:
[X] Completed - This activity has been completed
[ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. Status - Implementation:
[ ] Completed - This activity has been completed
[ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [X] On-Going - This activity will be undertaken throughout all years of the permit. |
Non-Stormwater Discharges Description of BMP/Activity:
Evaluate and update lists of non-stormwater discharges to insure that no exempt discharge is a substantial contributor of pollutants to the storm sewer system.
Staff, Agency, and/or Organization Reponsible for Completing this Activity:
Frequency of Activity:
Status - Program Development:
[X] Completed - This activity has been completed
[ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. Status - Implementation:
[ ] Completed - This activity has been completed
[ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [X] On-Going - This activity will be undertaken throughout all years of the permit. |
Regulated communities are required to collect and report information about the development and implementation of their stormwater program. Specific information that the MS4 is required to collect is generally included in the Annual Report and may also be reflected in related Self-Assessments (as applicable). MS4s are also required to identify "Measurable Goals" that will help them evaluate accomplishments and progress over time. The following "Measurable Goals" have been specifically identified for this Minimum Control Measure:
- Percent completion of outfall mapping - 100%
- Percent completion of system mapping - 100%
- Percent of outfalls inspected each year - 100%
- Number of illicit discharges detected - 2
- Number of Illicit discharges addressed, corrected or eliminated - 2
- Adoption and enforcement of local IDDE law or ordinance - December 7, 2006
- Percent of relevant employees trained - 100%
- Quantity of educational materials distributed - 1,800 at least 2 times a year
- Number of idde calls to hotline - 2
Activities and BMPs that have been accomplished to date for this Minimum Control Measure are included within the required MS4 Stormwater Annual Report form and Municipal Compliance Certification. Copies of these documents can be found at the following link (Annual Reports). Copies of various documents and specific products relating to this minimum control measure are included under "Related Documents".
A summary of the effectiveness of this program, associated BMPs, activities and an assessment of measurable goals can be found under the heading "Program Reporting and Effectiveness".
Illicit Discharges Local Law #6
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