Every MS4 Has Illicit Discharges. Whether you want to admit it or not!

Tom Schneider & Diana McDonald


What is the difference between an illegal discharge and an illicit discharge? Can you identify both illegal and illicit discharges? Where are they most likely to occur? Is your program to just go out and look for wet spots? There are all kinds of questions we can be asking ourselves when we talk about the IDDE program.

This presentation will help you look at your IDDE program from the perspective of the regulator. It will give you various ways to determine who in your MS4 should have an industrial stormwater permit because we all know that if they are supposed to and don’t, and they discharge, they have illicit discharges. We’ll touch on domestic discharges, industrial discharges, intentional discharges, and unintentional discharges.

We’ll talk about who should be part of your IDDE program. What types of activities should you, as an MS4, encourage your citizens to participate in?

The IDDE program is a huge part of your stormwater program. Treat it as the major player it is.

Tom Schneider

Co-Presented by Thomas Schneider CPESC & Diana McDonald

As Head of Storm Water Compliance at Stormcon, L.L.C., Tom Schneider brings 28 years of experience and extensive training in storm water regulations focusing on construction site erosion and sediment control. Mr. Schneider works directly with local, state, and federal agencies as well as working one on one with clients to develop and implement storm water programs that will fit their needs. In the past, Mr. Schneider has been invited to testify in front of congressional subcommittees in regard to NPDES issues.

 

Diana retired from the Environmental Protection Agency after spending 30 years in the Water Program, the last 17 years in Stormwater. She started out monitoring inspections and enforcement actions, and quickly moved to the Enforcement side of the Branch where she became an Enforcement Officer and credentialed inspector. As an inspector, she conducted inspections at facilities that fell under both the Construction General Permit and the Multi-Sector General Permit. She was also part of the teams that conducted audits of the MS4 programs in the Region. At the time of her retirement in early 2014, she had conducted audits in all but four of the Phase I MS4s in the Region, and two Phase II’s. In addition to her duties as an inspector/auditor, she was an Enforcement Officer issuing enforcement actions and assessing penalties to non-compliant operators under the Stormwater program. During her 17 years in Stormwater she served on numerous workgroups, teams, and focus groups helping to form policy and guidance, as well as development of penalty policies for the three stormwater groups. Since her retirement, Ms. McDonald has worked as an environmental consultant. Currently, she is Vice President of a company that works exclusively with MS4s, conducting pre-audits, developing Stormwater Management Plans and performing training for all the minimum control measures of the stormwater program. She acts as a consultant for Stormcon, LLC, a sister company to MSSS Compliance.