Prevention of Illicit Discharge
Within Manhattan, Kansas
Ellen Calhoun, Ryan Flickner,
A. Meredith Smythe, Kelsi Steele
Outline
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Project Overview
Project Objectives
National Pollutant Discharge Elimination System
Illicit Discharge
Common Illicit Discharges
Clean-Up Procedure
Environmental Impact
Employee Training
Emergency Procedure
Haz-Mat
Conclusions and Recommendations
Project Overview
 Our Service Learning project was to assist
the City of Manhattan in establishing an illicit
discharge prevention plan that fulfills a
minimum control measure established
through NPDES.
Project Objectives
 Define regulations presented in NPDES
 Develop a plan for the prevention of illicit discharges
into the stormwater sewer
 Formulate a list of potential contaminants, the actions
required, and the environmental impact of the
contaminants.
 Formulate a spill prevention and spill clean-up
procedures.
National Pollutant Discharge
Elimination System (NPDES)
 Established by Federal Water Pollution
Control Act (FWPCA) Amendments of 1972
 Requires that facilities that release pollutants
into waters of the US to obtain a permit
 Has 4 goals…
National Pollutant Discharge
Elimination System (NPDES)
 Goal 1
 Eliminate the
discharge of pollutants
into navigable waters
of the United States
National Pollutant Discharge
Elimination System (NPDES)
 Goal 2
 Protect fish, shellfish
and wildlife
National Pollutant Discharge
Elimination System (NPDES)
 Goal 3
 Provide safe water for
recreational purposes
National Pollutant Discharge
Elimination System (NPDES)
 Goal 4
 Prohibit the release of
toxic discharges
National Discharge Pollutant
Elimination System (NPDES)
 Permit (EPA definition)
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“a license for a facility to discharge a specified
amount of a pollutant into a Office of
Wastewater Management - Water Permitting
receiving water under certain conditions;
however, permits may also authorize facilities
to process, incinerate, landfill, or beneficially
use sewage sludge.”
National Discharge Pollutant
Elimination System (NPDES)
 Types of Permits
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Individual
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Customized to the specific facility
General
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Envelop multiple facilities within a specific
category
Currently Manhattan, Kansas has neither type
of permit on record with the EPA website
Illicit Discharge
 Any discharge into a storm water drain or
treatment plant that is not composed entirely
of storm water
 Exempt items: wetlands, diverted stream
flows, springs
 Exempt under certain conditions: foundation
drains, landscape irrigation, individual
residential care washing, sidewalk washing,
as well as flows from emergency fire fighting
activities
Common Illicit Discharges
 Our focus: oil, grease, gasoline, paints, yard
wastes, garbage, household chemicals, and
pesticides
 Cause for concern: chlorinated pool water,
cigarette butts, sanitary sewer flows,
commercial car wash wastewater,
construction debris, and food wastes
Clean-Up Procedure
 Yard Waste – Compost
Pile
 Garbage
 Paper Litter – Recycle
 Plastic Bottles – Recycle
Source: http://www.bidisposal.com/images/YARDWASTE.jpg
Clean-Up Procedure
 Motor Oil, Gasoline,
Source:
http://www.homedepot.co
m/cmc_upload/HDUS/E
N_US/asset/images/eplus/
130232_3.jpg
Grease, Paint
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Shut off all possible
ignition sources
Transfer excess
pollutant into spill proof
container.
Remove remaining
residue use an
absorbent such as
earth, sand, or
vermiculite.
Source:
http://www.phasmidsincyb
erspace.com/Pictures/Verm
iculite.JPG
Clean-Up Procedure
 Acid/Base
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Neutralize an acid with soda ash, sodium
bicarbonate, or lime
Neutralize a base with citric acid or dilute
hydrochloric acid
 Liquid Detergent
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Transfer into another container
Remove residue with absorbents
Flush with water
Safety Equipment
Source: http://www.dickblick.com/items/329/07/32907
-OA2ww.jpg
 Safety Goggles
 Rubber or Nitrile Gloves
Source:
http://www.ritop.com/informa
tion/images/ya127c.jpg
 Respirator
 Protective Clothing
Source:http://www.ritop.com/inf
ormation/images/glass1bk.jpg
Environmental Impact
 If any discharge enters the stormwater sewer
contact the National Emergency Response
Center
 Absorbent pillow can be used to contain the
pollutant until remediation can occur
 It is important to act quickly to prevent
substantial damage to the ecosystem.
Employee Training
 Employee training is crucial in pollution prevention
 The EPA recommends at a minimum the following in
a program
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Maintenance training
Maintenance schedules
Long-term inspection training
Procedure for properly disposing of waste when
removed from storm sewers
Ability to transfer knowledge through public education
Finance planning for enough funding
Employee Training
 Options for training
procedures:
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Visual: posters,
bulletin boards
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Verbal: employee
meetings, courses
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Field training:
hands-on
demonstrations
Employee Training
 Record process of training programs
 Senior management involvement is vital
Employee Training
 Advantages
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Cost effective
Easily implement able
Able to be Duplicate/ can be standardized
 Disadvantages
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Senior management apathy
Employee lack of motivation
Lack of Incentives to become involved
Prioritization
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List all illicit disposal incidents that have been
reported but not yet investigated and place in one of
the following categories:
1.
2.
3.
4.
5.
6.
7.
8.
Hazardous, affecting public health and safety
Hazardous, affecting the environment (receiving
waters, air, etc…)
Hazardous, affecting property
Hazardous, other
Non-hazardous, affecting public health and safety
Non-hazardous, affecting the environment (receiving
waters, air, etc…)
Non-hazardous, affecting property
Remaining incidents
Emergency Procedure
 Contact the Fire
Department immediately
with information
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Type/cause of incident
Types of chemicals
involved
Resources available on
site
Possible injured
personnel
Source:
http://www.ecy.wa.gov/programs/spills/incidents/willapa/willapaphoto
s/willabase.jpg
Haz-Mat
 Hazardous Materials Division
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Within the Kansas State Fire Marshal’s Office
Supports local first responders by isolating
hazardous materials
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Accidents and/or Acts of Terrorism
Haz-Mat
 Kansas Haz-Mat Response Team
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Within the state boundaries, regardless of
local government jurisdiction
Haz-Mat
 Regional Response
Teams
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Coffeyville
Colby
Emporia
Ford County
Hays
Manhattan
Newton
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Overland Park
Salina
Sedgwick County
Seward County
Topeka
Wellington
Haz-Mat
 Kansas State Fire Marshal’s Office
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Teams can respond to most areas in Kansas
within an hour or less
Can haz-mat incidents and accidents as well
as terrorist events
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Chemical
Biological
Radiological
Nuclear (CBRN)
Haz-Mat
 To Request a Response Team
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Call the toll-free hotline
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Call the group pager
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(1-866-KHAZMAT)
(785-357-3261)
website
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(www.myairmail.com)
Both hotline and website
forward to the group pager
Conclusions
 Manhattan has accomplished two out of the six
minimum control measures.
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Public education and outreach
Public participation and involvement
 Recommendations to accomplish next minimum
control measure
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Two or more city workers become trained in hazardous
materials protocol
Obtain a MSDS database
Keep on hand absorbents such as: sand, earth and
vermiculite.
Acknowledgements
 Dr. Alok Bhandari, Team Advisor
 Steve Hampton, Assistant City Engineer
Questions?