Town Of Salina
 Stormwater Management 

Illicit Discharge

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 were required to be determined using GIS or other tools, even if they extended outside of the urbanized area. This will help facilitate trackdown of illicit discharges. The Town of Salina has begun to map storm sewer lines and when grant funds are made available, a complete map of the sewer lines and storm sewer system will 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, the Town of Salina has entered into an Intermunicipal Agreement with Onondaga County to complete this portion of this minimum control measure.


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.


In certain areas that have current Watershed Improvement Strategies and/or Total Maximum Daily Load (TMDL) requirements, the regulated community may also be required to undertake additional activities such as: completing entire system mapping by January 8, 2013; and developing an on-site wastewater system inspection, maintenance and rehabilitation program (including the necessary legal authority to enforce the program). The details associated with these additional requirements are further described, and should be referenced, in the SPDES General Permit for Stormwater Discharges from MS4s.

Table Of Contents:
Selected Activities and BMPs:

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.  The Town of Salina has completed this map and has entered it into the GIS system and will update this information on an annual basis as the system is constantly monitored and surveyed.
Staff, Agency, and/or Organization Reponsible for Completing this Activity:
Frequency of Activity:
  • Program Development: Multi-year cycle
  • Implementation: Multi-year cycle
Status - Program Development:
[ ] 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.
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.

Sewershed Mapping

Description of BMP/Activity:
Identify the boundaries of the storm sewersheds. A storm sewershed is defined as the catchment area that drains into the storm sewer system and includes an examination of surface topography and underlying infrastructure. These boundaries may extend beyond the designated MS4 area to help facilitate trackdown
Staff, Agency, and/or Organization Reponsible for Completing this Activity:
Frequency of Activity:
  • Program Development: Multi-year cycle
  • Implementation: Multi-year cycle
Status - Program Development:
[ ] Completed - This activity has been completed
[ ] Short-Term - This activity will be accomplished within the current reporting year.
[X] 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.

Field Verify Outfall Locations

Description of BMP/Activity:
Field verify outfall locations to insure they exist and are still a functioning part of the storm sewer system. During this activity, previously unknown outfalls may be identified. This task may also relate to activities conducted as part of the "Outfall Mapping" and/or "Outfall Reconnaissance Inventory".
Staff, Agency, and/or Organization Reponsible for Completing this Activity:
Frequency of Activity:
  • Program Development: Multi-year cycle
  • Implementation: Multi-year cycle
Status - Program Development:
[ ] 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.
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.

Outfall Reconnaissance Inventory

Description of BMP/Activity:
Conduct an outfall reconnaissance inventory, as described in EPA's publication "Illicit Discharge Detection and Elimination: A Guidance Manual for Program Development and Technical Assessment". This activity involves outfall screening to detect illicit discharges. The inventory is generally designed to address every outfall within the MS4 designated area at least once every five years
Staff, Agency, and/or Organization Reponsible for Completing this Activity:
Frequency of Activity:
  • Program Development: Multi-year cycle
  • Implementation: Multi-year cycle
Status - Program Development:
[ ] 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.
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:
The Town of Salina adopted and enforces a stormwater management and illicit discharge ordinance to prohibit illicit discharges.
Staff, Agency, and/or Organization Reponsible for Completing this Activity:
Frequency of Activity:
  • Program Development: On-going/Continuous
  • Implementation: On-going/Continuous
Status - Program Development:
[ ] Completed - This activity has been completed
[ ] Short-Term - This activity will be accomplished within the current reporting year.
[X] 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:
  • Program Development: On-going/Continuous
  • Implementation: On-going/Continuous
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.
[X] 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.

Assessment of Illicit Discharge Potential (IDP)

Description of BMP/Activity:
Conduct screening of outfalls and land uses in the context of broader watershed initiatives to identify the potential for generating sites and certain types of illicit discharges. Generally assists in the identification of community needs and priorities, and in the development of a program and implementation strategies geared to the specific illicit discharge potential found within the MS4 designated area.  These properties are scheduled for review within the regular tri-annual fire inspection schedule.
Staff, Agency, and/or Organization Reponsible for Completing this Activity:
Frequency of Activity:
  • Program Development: Multi-year cycle
  • Implementation: Multi-year cycle
Status - Program Development:
[ ] Completed - This activity has been completed
[ ] Short-Term - This activity will be accomplished within the current reporting year.
[X] 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.

Targeted IDDE Inspection Program

Description of BMP/Activity:
Undertake a program to identify specific types of sites, land uses and/or activities that will be the focus of IDDE inspections. Specific types of targeted discharges may relate to, but are not limited to: car washing facilities, restaurants, auto repair shops, refueling stations, commercial and/or industrial areas, older areas of development where infrastructure may be deteriorating, and areas of repeated complaints
Staff, Agency, and/or Organization Reponsible for Completing this Activity:
Frequency of Activity:
  • Program Development: Multi-year cycle
  • Implementation: Multi-year cycle
Status - Program Development:
[ ] 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.
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 Track-Down and Response Procedures

Description of BMP/Activity:
Develop a plan and/or written procedure to investigate and confirm sources of pollution when issues arise due to public input or by scheduled system inspection.
Staff, Agency, and/or Organization Reponsible for Completing this Activity:
Frequency of Activity:
  • Program Development: Single Occurrence (Includes Updates As Needed)
  • Implementation: Single Occurrence (Includes Updates As Needed)
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:
  • Program Development: Single Occurrence (Includes Updates As Needed)
  • Implementation: Single Occurrence (Includes Updates As Needed)
Status - Program Development:
[ ] 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.
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:
  • Program Development: Multi-year cycle
  • Implementation: Multi-year cycle
Status - Program Development:
[ ] 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.
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:
  • Program Development: Multi-year cycle
  • Implementation: Multi-year cycle
Status - Program Development:
[ ] Completed - This activity has been completed
[ ] Short-Term - This activity will be accomplished within the current reporting year.
[X] 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.
[X] 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.

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:
  • Program Development: Multi-year cycle
  • Implementation: Multi-year cycle
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.

Trash and Debris Management

Description of BMP/Activity:
Develop a coordinated system for solid waste management to reduce the likelihood for illegal dumping and pollution of stormwater systems. This activity may include the development of specific recycling programs and collection days such as for household hazardous wastes, green wastes or used oil recycling programs.  The Town of Salina picks up trash at each home weekly and brush each week from March until October.  The town also picks up trash at buildings that have items left if the property owner fails to clean up after recieving a notice.
Staff, Agency, and/or Organization Reponsible for Completing this Activity:
Frequency of Activity:
  • Program Development: On-going/Continuous
  • Implementation: On-going/Continuous
Status - Program Development:
[ ] 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.
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.
Measurable Goals:

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 - approximately 60%
  • Number of outfalls mapped - 59 which are 100% of the outfalls
  • Utilization of GIS-based data collection and reconnaissance procedures
  • Percent of outfalls inspected each year: at a minimum 20% of all outfalls
  • Adoption and enforcement of local IDDE law or ordinance was completed on 5/29/2009 as Chapter 132 of the Town Code.
  • Percent of relevant employees trained - all employees have been trained on illicit discharges.
Program Accomplishments:

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".

Other Related Links:
Other Related Documents:
       
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Printed On June 21, 2011