Environment, Health and Safety Manual – Chapter 07.02: Environmental Affairs – Illicit Discharge Detection and Elimination Policy

Title

Environment, Health and Safety Manual – Chapter 07.02: Environmental Affairs – Illicit Discharge Detection and Elimination Policy

Purpose of Policy

The purpose of this Policy is as follows:

  1. To improve the quality of surface water and ground water within the watershed areas owned and maintained by the University of North Carolina at Chapel Hill (UNC-Chapel Hill) by preventing illicit discharges and illicit connections.
  2. To prevent the discharge of contaminated stormwater runoff from UNC-Chapel Hill properties and operations into the storm drainage system and natural waters within UNC-Chapel Hill.
  3. To comply with the requirements of UNC-Chapel Hill’s stormwater permit.
  4. To comply with all United States Environmental Protection Agency and State laws applicable to stormwater discharges.

Definitions

An Illicit Discharge is the discharge of pollutants or non-stormwater materials to the storm drainage system via overland flow or direct dumping of materials into a catch basin or inlet. Examples of illicit discharges include overland drainage from car washing or cleaning paint brushes in or around a catch basin.

An Illicit Connection is the discharge of pollutants or non-stormwater materials into the storm drainage system via a pipe or other direct connection. Sources of illicit connections may include sanitary sewer taps, wash water from laundry facilities, wash water from sinks, or other similar sources.

Illicit Discharges

No University employee, student, visitor, contractor, department, or unit shall cause or allow discharges into the UNC-Chapel Hill storm drainage system which are not composed entirely of stormwater, except for the allowed discharges listed below. Prohibited discharges include but are not limited to: oil, anti-freeze, grease, chemicals, wash water, paint, animal waste, garbage, and litter.

Illicit Connections

The following connections are prohibited, except as provided in “Allowed Discharges” below:

Any drain or conveyance, whether on the surface or subsurface, which allows any nonstormwater discharge, including but not limited to sewage, process water, waste water, or wash water, to enter the stormwater drainage system, and any connections to the storm drain system from indoor drains or sinks.

Allowed Discharges

The following discharges to the storm drainage system are allowed:

  1. Discharges that are specifically permitted under a state or federal stormwater program
  2. Incidental non-stormwater discharges which do not significantly contribute to the pollution of UNC-Chapel Hill surface waters and are limited to the following:
    • water line flushing
    • reclaimed water line flushing
    • landscape irrigation, including but not limited to reclaimed water
    • diverted stream flows
    • rising groundwater
    • uncontaminated groundwater infiltration
    • uncontaminated pumped groundwater
    • discharges from potable water sources
    • foundation drains
    • air conditioning condensate (that does not contain biocide)
    • springs
    • water from crawl space pumps
    • footing drains
    • flows from riparian buffers and wetlands
    • dechlorinated swimming pool discharges
    • flows from emergency fire fighting
    • building wash water without detergents, cleaners, or corrosive additives
  3. In the event that UNC-Chapel Hill determines that any of the above discharges contribute to pollution of campus streams or other surface waters or is notified by a state or federal government agency, such as the North Carolina Division of Water Quality, that the discharge must cease, UNC-Chapel Hill will instruct the responsible person to cease the discharge.
  4. When instructed to cease the discharge, the discharger of substances newly classified as pollutants shall cease the discharge immediately and be given reasonable time to make corrections so that the discharge will not continue into the future.
  5. Nothing in this Policy shall affect a discharger’s responsibilities under federal or state law.

Stormwater Best Management Practices for UNC Pressure Washing

Outdoor power washing can negatively impact water quality if not done correctly. In addition, State and Federal laws dictate the use and disposal of certain cleaning chemicals. Failure to do so can lead to significant fines for both the University and contractors. The following guidelines clarify the correct way to power wash outdoor surfaces.

Power Washing Best Practices
Type of Surface Cleaning Method Proper Disposal
Sidewalks, plazas Without Soap: Dry cleanup first (broom), then wash. Screen wash water, if needed, to catch debris, then discharge water to landscaping, gutter, street or storm drain.
With Soap: Dry cleanup first (broom), then block storm drains and contain runoff. Collect water, screen water to remove solids, and pump wastewater to the sanitary sewer. Make sure pH is between 6 and 10 before disposing of the water into the sanitary sewer. (Contact EHS if you need help verifying the pH.)
Parking lots, Driveways, Restaurant/Food Handling Areas, Dumpster Areas, Loading Docks, Grease Storage With or Without Soap: Clean up any oil, grease, or dumpster discharge using absorbents. Sweep and bag absorbents for disposal. Block storm drains and contain runoff. Collect water, screen water to remove solids, make sure pH is between 6 and 10, and pump wastewater to sanitary sewer.
Contact EHS for assistance with alternative disposal options if there is a high concentration of petroleum products.
Unpainted Building Surfaces, Exterior Brick and Masonry Walls, Wood Decks, etc. Without Soap: Screen runoff for solids. Discharge water to landscaping, gutter, street, or storm drain.
With Soap: Block storm drains and contain runoff. Collect water, screen to remove solids, make sure pH is between 6 and 10, and pump wastewater to sanitary sewer.
Painted surfaces without loose paint (call EHS for assistance to determine paint’s lead content). Without Soap: Use high-pressure water, no soap. Lead-free paint: Screen wash water, if needed, to catch debris, then discharge water to landscaping, gutter, street or storm drain.
Paint contains lead: Collect water, screen to remove lead and solids, make sure pH is between 6 and 10, and pump to sanitary sewer.
Painted surfaces being cleaned to remove paint or graffiti (call EHS for assistance to determine paint’s lead content). With or Without Soap: Block the storm drain and contain runoff. Collect water, screen to remove solids, make sure pH is between 6 and 10, and pump to sanitary sewer.

Please note that biodegradable soap is subject to the same disposal procedures as any other soap.

Enforcement and Penalties

  1. Whenever UNC-Chapel Hill finds that a violation of this Policy has occurred, UNC-Chapel Hill may order compliance by written notice to the responsible person. Such notice may require without limitation:
    1. The performance of monitoring, analyses, and reporting
    2. The elimination of prohibited discharges or connections
    3. Cessation of any violating discharges, practices, or operations
    4. The abatement or remediation of stormwater pollution or contamination hazards and the restoration of any affected property
    5. Payment of any fee, penalty, or fine assessed against UNC-Chapel Hill to cover remediation cost
    6. The implementation of new stormwater management practices
    7. Disciplinary action up to and including dismissal, where appropriate
  2. Such notification shall set forth the nature of the violation(s) and establish a time limit for correction of these violation(s). Said notice may further advise that, if applicable, should the violator fail to take the required action within the established deadline, then UNC-Chapel Hill’s Department of Environment, Health and Safety will initiate work orders for the appropriate corrective actions and the individual or University department will be charged for the cost.

Inspection and Sampling of Outfalls

UNC-Chapel Hill shall, at a minimum, visually inspect outfalls draining one fifth of its geographic area per year during dry weather conditions. Flows suspected of containing illicit discharges due to the presence of odors, colors or sheens shall be tested. Test parameters may include but are not limited to ammonia, detergent, chlorine, phosphorus, nitrogen, pH, conductivity, turbidity, temperature, and dissolved oxygen. The results of the inspections and testing shall be maintained in a geographic information system (GIS) database that links outfall locations to inspection dates, chemical tests conducted, and follow-up procedures implemented to correct any detected illicit discharge. The physical condition of the outfall shall also be noted during the inspections. Illicit discharge data from the GIS database will be used in the preparation of the annual report to the North Carolina Division of Water Quality.

Illicit Discharge Training

Training on how to identify and report illicit discharges and implement good housekeeping and pollution prevention best management practices shall be presented to UNC-Chapel Hill and UNC Health Care System maintenance employees. Training shall consist primarily of classroom training, with online training serving as backup for those unable to attend the classroom training. Following the initial training, training shall be repeated once every three years. UNC-Chapel Hill shall maintain a database of employees who have completed the training and the date that training occurred.

Contact Information

Policy Contact

Environment, Health and Safety
1120 Estes Drive
Campus Box #1650
Chapel Hill, NC 27599-1650
Phone: 919-962-5507

Back to Chapter 07.01 – Environmental Compliance Introduction

Proceed to Chapter 08.01: Low Lead Requirement – Policy on Lead Contaminant Testing in New Potable Water Devices