ILLICIT DISCHARGE DETECTION
AND ELIMINATION PLAN
FOR THE CITY OF PARIS
Planning and Codes Department
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Under the Tennessee Water Quality Control Act of 1977, along with the Federal Water Pollution Control Act, as amended by the Clean Water Act of 1977 and the Water Quality Act of 1987, municipal separate storm sewer systems (MS4s) are authorized to discharge into Tennessee waters. The National Pollutant Discharge Elimination System (NPDES) permit, issued by the Tennessee Department of Environment and Conservation (TDEC) provides regulations for these storm water discharges. Implementation of a Stormwater Management Program with minimum control measures are required for a NPDES General Permit for Discharges from Municipal Separate Storm Sewer Systems. Illicit Discharge Detection and Elimination is a minimum control measure outlining the procedures to detect and remove any illicit discharges and improper disposals within the city’s MS4 to the maximum extent possible.
The City of Paris (City) is a small Phase II MS4. This document contains the City’s Illicit Discharge Detection and Elimination (IDDE) Plan that satisfies the requirements in Section 4.2.3 of the State of Tennessee NPDES General Permit for Discharges from Small Municipal Separate Storm Sewer Systems.
Storm Water Management Coordinators
- Location of all outfalls where MS4 discharges into waters of the state or conveyances owned or operated by another MS4
- Names and location of all waters of the state that receive discharges from those outfalls
- Inputs into the MS4, such as inlets, catch basins, drop structures or other defined contributing points to the outfalls
- General direction of storm water flow.
The City has begun compiling in the city-wide GIS database the components listed in 1-4 above. Currently, approximately 50% of the MS4 system is mapped. Details included in the City’s MS4 map are: all inlets, catch basins, manholes, type of pipe, elevations, flow directions, outfalls, etc. Access to this map is provided for all city employees who need it.
The City will continue to maintain and update this system by:
- Ensuring all MS4 infrastructure is updated in the map.
- Adding to the map new outfalls and inputs that result from new development.
STORM WATER LEGISLATION
Storm Water Management Coordinators, City of Paris City Council
- Prohibit, through ordinance, non-storm water discharges into the MS4.
- Implement Enforcement Response Plan (ERP).
The City of Paris Stormwater Ordinance, Section 5-13-507 effectively prohibits non-storm water discharges into the MS4. The ordinance acts in compliance with this NPDES permit with the intent to reduce contaminants entering the MS4 and improve the water quality of receiving waters. The ERP can be found in Section 5-13-508/509 and outlines the City’s violation policies and penalties.
The City will amend and update the Stormwater Ordinance and ERP as advances are made in engineering, science, and maintenance practices, as they are relevant to the MS4. The Stormwater Ordinance shall remain effective for the City and in compliance with the NPDES permit at all times.
ILLICIT DISCHARGE DETECTION AND ELIMINATION
Storm Water Management Coordinators
- Implement a plan to detect, identify, and eliminate non-storm water and/or illegal discharges.
- Includes standard procedures to identify and investigate potential illicit discharges or other sources of non-storm water.
- The results of all investigations shall be documented and should include the following: locations, times, parameters and sampling results, discovered sources of flows, etc.
The potential for illicit discharges is monitored through the combined efforts of the the wastewater department, the local code enforcement group, and the police and fire departments. Preventative and detection measures are accomplished on a regular basis as a part of everyday duties and include the following:
- Solid waste collection occurs weekly.
- Police are on patrol 24 hours a day.
All existing storm water management facilities are subject to the inspection programs including routine inspections, random inspections, inspections based upon complaints or other notice of possible violations, joint inspections with other agencies inspecting under environmental or safety laws, inspections of areas or businesses of a type associated with higher than usual discharges of contaminants.
Once a problem discharge or area has been found, efforts to find the source of the discharge are necessary. The Storm Water Management Coordinators will coordinate with any departments necessary to determine the location of the source. Common methods that may be used are:
- water sampling/testing,
- dye-testing buildings in the problem area,
- dye- or smoke-testing buildings,
- thorough inspections,
- tracing the discharge upstream, and
- using video to inspect storm sewers.
The discharger is notified of the violation via verbal warnings and written notice and required to implement any Best Management Practices (BMPs) required by the Storm Water Management Department necessary to prevent additional occurrences. In the event of an illicit connection, it must be removed and if necessary, replaced with approval of the Storm Water Management Department. See Section 5-13-08/09 of the City’s Stormwater Ordinance for details on notification, enforcement and penalties.
Inspections and actions surrounding illicit discharge identification and/or illegal disposal are recorded. As much relevant information from the permit requirements as possible is included.
Future Program Additions
- The City will conduct a weekly personnel visit to potential pollution sites.
- The City will implement formally planned dry weather field screenings on a quarterly basis.
- All inspections, including those that conclude there are no illicit discharge issues, shall be recorded.
COMMUNICATION AND OUTREACH
Storm Water Management Coordinators
- Inform public employees, businesses and general public of hazards associated with illegal discharges and improper disposal of waste.
- A mechanism for the public to report suspected illicit discharges
Existing and Future Program
All city employees working in the field must attend an illicit discharge detection
training in order to accurately and effectively identify any illicit discharges. Educational
opportunities will be available to the public in conjunction with other MS4 public
education efforts. Educational brochures and publications illustrating the importance of
eliminating illicit discharges for public safety, public health, and the environment can be
found on the Storm Water Management’s page of the City of Paris’s website.
Suspected illicit discharges can be reported by calling the City of Paris and complaints are
managed with the INCODE software.
Once a complaint is received, City personnel are required by ordinance to respond.
APPENDIX I: DEFINITIONS
BMP – Best Management Practice
IDDE – Illicit Discharge Detection and Elimination
Illicit Connection – An illegal and/or unauthorized connections to the municipal separate storm water system whether or not such connections result in discharges into that system.
Illicit Discharge – Any discharge to the municipal separate storm sewer system that is not composed entirely of storm water and not specifically exempted under The City of Dyersburg Stormwater Ordinance. This includes, but is not limited to the introduction of pesticides (i.e. Roundup) not approved by the City of Dyersburg Storm Water Management Department.
MCM – Minimum Control Measure
Municipal Separate Storm Sewer System (MS4) – The conveyances owned or operated by the municipality for the collection and transportation of storm water, including the roads and streets and their drainage systems, catch basins, curbs, gutters, ditches, man-made channels, and storm drains.
NPDES – National Pollutant Discharge Elimination System
NPDES Phase II Permit – Permit where conditions are established for discharging stormwater and other non-polluted waters to the Waters of the State. The permit is required for discharges from small MS4s as defined by TDEC.
Outfall – A point source where an MS4 discharges into receiving waters or other MS4s.
Pollutant – Any substance or material which contaminates or adversely alters the physical, chemical, or biological properties of the waters including changes in temperature, taste, odor, turbidity, or color of the water. Such substance or material may include but is not limited to spoil waste, sewage, pet and livestock waste, garbage, sewage sludge, munitions, chemical waste, biological materials, head, wrecked or discarded equipment, rock, sand, soil, yard waste, hazardous household wastes, oil and petroleum products, anti-freeze, litter, pesticides, and industrial, municipal, and agricultural waste discharged into water.
Storm Drain – This kind of drain is either an enclosed pipe or an open channel. They can be qualified as either a major drain, pipes with a diameter of 36 inches or greater and channels that drain into more than 50 acres, or a minor drain, pipes or channels smaller than a major drain.
Stormwater – All storm water runoff, snow melt runoff, surface runoff, street wash waters related to street cleaning or maintenance, infiltration and drainage.
TDEC – Tennessee Department of Environment and Conservation
Waters of the State – All public and private streams, lakes, ponds, marshes, watercourses, waterways, wells, springs, reservoirs, aquifers, irrigation systems, drainage systems, and all other accumulations of water on the surface or underground, natural or artificial, which are contained within, flow through, or border the state.