Illicit Discharge Detection and Elimination: Technical Appendices

184 Pages·2004·2.78 MB·English

Illicit Discharge
Detection and Elimination
TECHNICAL APPENDICES

by the
Center for
Watershed Protection
and
Robert Pitt
October 2004
University of Alabama

TECHNICAL APPENDICES
ILLICIT DISCHARGE DETECTION AND ELIMINATION: A
GUIDANCE MANUAL FOR PROGRAM DEVELOPMENT
AND TECHNICAL ASSESSMENTS

by

Edward Brown and Deb Caraco
Center for Watershed Protection
Ellicott City, Maryland 21043

and

Robert Pitt
University of Alabama
Tuscaloosa, Alabama 35487

EPA Cooperative Agreement
X-82907801-0

Project Officer

Bryan Rittenhouse
Water Permits Division
Office of Water and Wastewater
U.S. Environmental Protection Agency
Washington, D.C.

October 2004
Table of Contents
Illicit Discharge Detection and Elimination: Technical Appendices
Table of Contents
Table of Contents

Appendix A: Generating Sites, Storm Water Regulatory Status, and Discharge Potential....................A-1

Appendix B: Model Illicit Discharge and Connection Ordinance.......................................................B-1

Appendix C: Six Steps to Establishing a Hotline and Reporting and Tracking System..........................C-1

Appendix D: Outfall Reconnaissance Field Sheet...............................................................................D-1

Appendix E: Flow Type Data from Tuscaloosa and Birmingham..........................................................E-1

Appendix F: Laboratory Analytical Procedures for Outfall Monitoring.................................................F-1

Appendix G: Sampling Protocol Considerations.................................................................................G-1

Appendix H: Two Alternative Flow Charts.............................................................................................H-1

Appendix I: User’s Guide for the Chemical Mass Balance Model (CMBM) Version 1.0........................I-1

Appendix J: Using the Chemical Library to Determine the Utility of Boron as an Indicator of
Illicit Discharges.............................................................................................................J-1

Appendix K: Specific Considerations for Industrial Sources of Inappropriate Pollutant Entries
to the Storm Drainage System.........................................................................................K-1

Illicit Discharge Detection and Elimination: Technical Appendices
Table of Contents

Illicit Discharge Detection and Elimination: Technical Appendices
APPENDIX A

GENERATING SITES, STORM WATER
REGULATORY STATUS, AND DISCHARGE POTENTIAL
Illicit Discharge Detection and Elimination: Technical Appendices A-1
Appendix A: Generating Sites, Storm Water Regulatory Status, and Discharge Potential
A-2 Illicit Discharge Detection and Elimination: Technical Appendices
Appendix A: Generating Sites, Storm Water Regulatory Status, and Discharge Potential
The information presented in this Appendix much information as possible on generating
refers to the Standard Industrial sites within a subwatershed that may qualify
Classification (SIC) system. This system has for more intensive scrutiny.
historically been used to classify industries
and other businesses for census, tax, permit Phase 1. Consult publicly available
and other purposes. It should be noted that, databases
more recently, federal agencies, including
EPA, have adopted the North American The federal government has a number of
Industry Classification System (NAICS, databases that may help identify locations
pronounced “Nakes”) as the industry for investigation. The Environmental
classification system. For more information Protection Agency (EPA) operates two such
on the NAICS and how it correlates with databases. The first is the Enforcement and
SIC, visit Compliance History Online (ECHO)
http://www.census.gov/epcd/www/naics.html. database. With this system, facility
compliance history can be queried and
Overview facilities can be found based on geographic
location (county level), or zip code
Identification of land uses that may impact (http://www.epa.gov/echo/index.html). The
water quality in local streams can be a other database is Envirofacts
difficult and time-consuming task. Research (http://www.epa.gov/enviro/). This website
suggests that program managers might wish provides access to multiple EPA databases
to preferentially investigate certain land uses to provide information about environmental
when looking for the sources of possible activities (including Resource Conservation
pollutant loads. These land uses are all and Recovery Act [RCRA] and Toxic
considered to be generating sites where Release Inventory [TRI] facilities) that may
routine operations can produce higher levels affect air, water, and land anywhere in the
of storm water pollutants, and/or present a United States. The website also provides
higher potential risk for spills, leaks or illicit access to Enviromapper, which will display
discharges. There are two basic types of the location of regulated facilities.
generating sites: regulated hotspots that are There are also commercial databases that
known sources of pollution and are subject can provide information on regulated
to federal or state regulations, and industries based on manufacturing or
unregulated hotspots which are operations industrial SIC codes. These databases are
suspected to be potential pollution sources, not free, and have limitations since they are
but which are not currently regulated. designed primarily for marketing.

Identifying Potential Generating Sites Phase 2. Consult State and Local Agencies

The number and type of generating sites Most states have NPDES permit programs,
present in a subwatershed may vary greatly, and track permit application to some extent.
and currently there is no public database You can consult state or local regulatory
available to identify all the regulated sites in agencies to obtain lists of industries that
a subwatershed. Instead, multiple databases have filed NOIs (Notices of Intent) to obtain
need to be queried to identify generating storm water permits, as well as those that
sites that may be targets for source control have filed under TRI requirements. Other
or illicit discharge investigations. A three- agencies that may have information on local
phase approach is useful for gathering as generating sites include fire departments (for
Illicit Discharge Detection and Elimination: Technical Appendices A-3
Appendix A: Generating Sites, Storm Water Regulatory Status, and Discharge Potential
hazardous waste), and sanitation or regular activities or practices. Column one
wastewater treatment agencies. describes the general industry type. Column
two lists their associated SIC codes, if
Phase 3. Permit Review known. Column three identifies whether an
industry type is subject to NPDES industrial
The final source for information is through a storm water permit requirements (designated
review of local permits. Most permit by “X”). Facilities where only certain
databases have SIC codes as one of the activities or facilities at the site are subject
fields. These codes can be matched against to regulation are noted (this pertains mostly
the SIC codes in Table A.1 that list common to the transport-related industries). In
generating sites under major land use addition, for many “light” industrial
headings. If a local permit database does not facilities, storm water permits are required
exist, it may be worthwhile to simply get the only if material handling equipment or
local phone book and do a quick look for activities, raw materials, immediate
businesses that are similar to those listed in products, final products, waste materials, by-
Table A.1. products, or industrial machinery are
exposed to storm water. Industries where
Compiling the findings from the various this applies are noted with an “**”. If only
databases will provide an initial list of specific SIC codes within a major group
potential generating sites for future qualify for this exception they are noted in
investigation. However, research has found parentheses. Municipal facilities that are
that most of these databases can miss many subject to NPDES MS4 permit requirements
of the industries that are subject to are designated by “MS4.” Column four
regulation (Duke et al., 1999; Duke and identifies those businesses that can be
Shaver, 1999), and further identification considered an unregulated storm water
may be necessary. Field investigations using hotspot (also designated by “X”). Column
techniques such as the Unified five looks at the illicit discharge potential of
Subwatershed and Site Reconnaissance each of the businesses listed. The potential
(Wright et al., 2004) can assist in identifying for a business to produce an illicit discharge
many of these generating sites that should is rated as either high (H) medium (M) or
likely be regulated by communities. Low (L) based on the likelihood that it has a
direct connection to the storm drain system
Reference Tables (direct) or that it can produce a transitory
discharge (indirect).
This appendix is designed to assist in
identifying the land uses and associated Table A.2 is a list of the SIC Codes that are
generating sites in a subwatershed where regulated by the Industrial Multi Sector
routine activities may result in pollution General Permit (MGSP). The list includes
being discharged to the storm drain system. the four-digit SIC code level along with the
There are two tables provided, each of official description. This table is provided
which is described below. for those who wish to know the full
description of each SIC code that is
Table A.1 presents a listing of potential regulated by NPDES industrial storm water
generating sites under common land uses permits.
where illicit discharges can occur based on
A-4 Illicit Discharge Detection and Elimination: Technical Appendices