Identifying NPDES Violations
Go through the sections below.
Identifying Illicit Discharges
Your agency must investigate potential illicit discharges within its jurisdiction. Staff may be notified of illicit discharges by field observations, public complaints, or referrals from other agencies. To investigate an illicit discharge, you must be able to identify them. Most discharges to the storm drain system are considered illicit. Think of the mantra, "Only rain in the drain". There are some exceptions however: Before we review illicit discharges, review the presentation on "authorized" discharges.
Identifying Stormwater BMP Deficiencies
Stormwater BMPs include any practice that prevents or reduces stormwater pollution. BMPs are needed when an activity is generating pollutants that could discharge in a rain event. Common activities that generate stormwater pollutants include industrial/commercial operations, municipal O&M activities, and construction site operations. BMP deficiencies occur when the facility operator has insufficient practices in place to prevent stormwater pollution. They include:
Uncovered raw and waste material exposed to precipitation
Onsite spills and leaks exposed to stormwater
Stormwater BMPs: How Much is Enough?
Most of the time, identifying BMP deficiencies is straightforward. Sometimes it is more difficult. Difficulties arise when you are not sure whether 1) an activity generates pollution, and 2) existing BMPs prevent stormwater pollution. For example, say there is one piece of trash on the ground at a storage yard, and the facility operator already cleans the property once a day. Is this a BMP deficiency by the facility operator? What if there are 10 pieces of trash on the ground, and cleaning occurs once a week? Where do you draw the line?
The point of this example is not to deter you from identifying and resolving BMP deficiencies. The point is to let you know that sometimes the answer isn't clear. That is the nature of stormwater pollution prevention. It is addressed by using best professional judgement. If you feel that you do not have that best professional judgement, that is OK:Â Most agencies have staff on-hand--either in-house or contracted--that are experienced in NPDES Permit inspections. A good approach may be to discuss with--or defer to--them. Specific protocol is up to your Agency.
