06-20.00 – Policy on Stormwater Illicit Discharge Detection and Elimination

  1. Policy Statement:

    The purpose of this policy is to establish uniform guidelines that protect the health, safety, and general welfare of the students, staff, and visitors to Towson University (the “University”) and environment through the regulation of non-storm water discharges to the storm drainage system to the maximum extent practicable as required by federal and state law. This policy establishes methods for controlling the introduction of pollutants into the municipal separate storm sewer system (MS4) in order to comply with requirements of the Maryland Department of the Environment’s (MDE) Stormwater Management Program permit for the University.

  2. Definitions:

    1. “Best Management Practices (BMPs)” are defined as schedules of activities, prohibitions of practices, general good housekeeping practices, pollution prevention and educational practices, maintenance procedures, and other management practices to prevent or reduce the discharge of pollutants directly or indirectly to storm water, receiving waters, or storm water conveyance systems. BMPs also include treatment practices, operating procedures, and practices to control site runoff, spillage or leaks, sludge or water disposal, or drainage from raw materials storage. For additional information, refer to the “National Menu of BMPs found in EPA’s National Pollutant Discharge Elimination System (NPDES) General permit Discharges from Small Municipal Separate Storm Water Sewer Systems (MS4).

    2. “De Minimis” is defined as small, minor, or insignificant spills of materials that occur during normal material handling operations (e.g., spills from unloading or transfer of materials, leaks from pipes or valves, minor leaks of process equipment, etc.).

    3. “Hazardous Materials” is defined as any material, including any substance, waste, or combination thereof, which because of its quantity, concentration, or physical, chemical, or infectious characteristics may cause, or significantly contribute to, a substantial present or potential hazard to human health, safety, property, or the environment when improperly treated, stored, transported, disposed of, or otherwise managed. Refer to 40 CFR Part 116 pursuant to section 311 of the Clean Water Act for a list.

    4. “Illicit Connections” are any man-made conveyance, whether on the surface or subsurface, that is connected to a municipal separate storm sewer system (MC4) without a permit, excluding roof drains and other similar type connections, and allows an illegal discharge to enter the storm drain system.

      Examples of Illicit Connections include, but are not limited to, the following:

      1. sanitary sewer piping that is connected directly from a building to the stormwater system;

      2. any drain or conveyance, whether on the surface or subsurface, which allows an illegal discharge to enter the storm drain system including, but not limited to, any process wastewater and wash water to enter the storm drain system, and any connections to the storm drain system from indoor or drains and sinks, regardless of whether said drain or connection had been previously allowed, permitted, or approved by an authorized enforcement agency;

      3. any drain or conveyance connected from a commercial or industrial land use to the storm drain system which had not been documented in plans, maps, or equivalent records and approved by an authorized enforcement agency;

      4. a cross connection between the municipal sanitary sewer and the stormwater systems.

    5. “Illegal Discharge” is any direct or indirect non-storm water discharge to the storm drain system, except as exempted in Section V.B. of this policy.

    6. “Municipal Separate Storm Sewer System (MC4)” means the system of conveyances (including roads with drainage systems, municipal streets, catch basins, curbs, gutters, ditches, man-made channels, or storm drains) owned and operated by the University and designed or used for collecting or conveying storm water that is not used for collecting or conveying sewage.

    7. “Non-Storm Water Discharge” is any discharge to the storm drain system that is not composed entirely of storm water.

    8. “Pollutant” means any environmental contaminant that causes or contributes to pollution. Examples of contaminants prohibited for discharge may include, but are not limited to:

      1. floatables, including trash, debris and other discarded or abandoned objects and accumulations;

      2. construction wastes or materials;

      3. petroleum products including, but not limited to, oil, gasoline, grease, fuel oil, heating oil;

      4. antifreeze and other automotive products;

      5. metals in either particulate or dissolved form;

      6. flammable or explosive materials;

      7. radioactive material;

      8. batteries;

      9. acids, alkalis, or bases;

      10. paints, stains, resins, lacquers, or varnishes;

      11. degreasers and/or solvents;

      12. drain cleaners;

      13. commercial and household cleaning products;

      14. pesticides, herbicides, or fertilizers;

      15. steam cleaning wastes;

      16. pressure washing wastes;

      17. soaps, detergents, or ammonia;

      18. swimming pool or spa filter backwash;

      19. chlorine, bromine, or other disinfectants;

      20. heated water;

      21. domestic animal wastes;

      22. sewage, fecal coliform and pathogens;

      23. recreational vehicle waste;

      24. animal carcasses;

      25. fats, oils, greases and other food wastes;

      26. bark and other fibrous materials;

      27. lawn clippings, leaves, or branches;

      28. silt, sediment, concrete, cement or gravel;

      29. dyes;

      30. chemicals not normally found in uncontaminated water;

      31. noxious or offensive material of any kind;

      32. any other process-associated discharge except as otherwise allowed in this section;

      33. any hazardous material or waste not listed above.

    9. “Storm Drainage System” is defined as any publicly owned (federal, state or political subdivision thereof) facilities in which storm water is collected and/or conveyed. This includes, but is not limited to, any roads with drainage systems, municipal streets, gutters, curbs, inlets, piped storms, pumping facilities, retention and detention basins, natural and human-made or altered drainage channels, ditches, reservoirs, and other drainage structures.

    10. “Storm Water” is any surface flow, runoff, and drainage consisting entirely of water from any form of natural precipitation (e.g., rain or snow) and resulting from such precipitation.

    11. “Wastewater” is any water or other liquid, other than uncontaminated Storm Water, discharged from a facility.

  3. Responsible Executive and Office:

    Responsible Executive:
    Vice President for Administration & Finance and Chief Financial Officer (CFO)

    Responsible Office:
    Environmental Health and Safety

  4. Entities Affected by this Policy:

    This policy applies to all University staff, faculty, students, and contractors working on campus.

  5. Procedures:

    1. Prohibition of Illicit Discharges

      No University employee, student, visitor or contractor shall throw, drain, or otherwise discharge, cause, or allow others under its control to throw, drain, or otherwise discharge into the University’s Storm Water drainage system any Pollutants or waters containing any Pollutants, other than Storm Water. This includes the construction, use, maintenance or continued existence of unlawful or Illicit Connections made to the storm drain system.

    2. Allowable and Conditional Discharges

      1. The following discharges are allowable discharges and shall not be considered illicit discharges unless the University determines that the type of discharge, singularly or in combination with others, is causing or is likely to cause pollution of University surface or ground waters:

        1. diverted stream flows;

        2. rising ground waters;

        3. uncontaminated ground water infiltration – as defined in 40 CFR 35.2005(20);

        4. uncontaminated pumped ground water;

        5. foundation drains;

        6. air conditioning condensation;

        7. irrigation water from agricultural sources that is commingled with urban stormwater;

        8. springs;

        9. water from crawl space pumps;

        10. footing drains;

        11. flows from riparian habitats and wetlands;

        12. discharges from emergency fire-fighting activities;

        13. discharges from EHS permitted dye-testing activities (Requires written permission from EHS at least 2-business days in advance);

        14. other discharges specified in writing by EHS as being necessary to protect public health and safety;

        15. The prohibition shall not apply to any Non-Storm Water Discharge permitted under an NPDES permit, waiver, or waste discharge order issued to the discharger and administered under the authority of the United States Environmental Protection Agency (EPA), provided that the discharger is in full compliance with all requirements of the permit, waiver, or order and other applicable laws and regulations, and provided that written approval has been granted for the permitted discharge to the storm drain system.

      2. The following discharges are conditional discharges and shall not be considered Illegal Discharges for the purposes of this chapter if they meet the stated conditions, or unless EHS determines that the type of discharge, whether singly or in combination with others, is causing or is likely to cause pollution of surface water or groundwater.

        1. Potable water, including water from line flushing, hyper-chlorinated water line flushing, fire hydrant system flushing, and pipeline hydrostatic test water. Planned discharges shall be de-chlorinated to a concentration of 0.1 ppm or less, pH-adjusted, if necessary and in volumes and velocities controlled to prevent re-suspension of sediments in the stormwater system.

        2. Lawn watering and other irrigation runoff are permitted but shall be minimized.

        3. De-chlorinated swimming pool discharges. These discharges shall be de-chlorinated to a concentration of 0.1 ppm or less, pH-adjusted, if necessary and in volumes and velocities controlled to prevent re-suspension of sediments in the stormwater system.

        4. Street and sidewalk wash water, water used to control dust, and routine external building wash down that does not use detergents are permitted if the amount of street wash and dust control water used is minimized. At active construction sites, street sweeping must be performed prior to washing the street.

        5. Non-stormwater discharges covered by another NPDES permit, provided that the discharges are in full compliance with all requirements of the permit, waiver, or order and other applicable laws and regulations; and provided, that written approval has been granted for any discharge to the storm drain system.

        6. Other non-stormwater discharges which are in compliance with the requirements of TU’s campus Stormwater Pollution Prevention Plan (SWPPP).

    3. Prohibition of Illicit Connections

      The construction, use, maintenance, or continued existence of Illicit Connections to the storm drain system are prohibited. This prohibition includes, without limitation, Illicit Connections made in the past, regardless of whether the connection was permissible under law or practices in effect at time of construction. A person is considered to be in violation of this policy if they connect a line conveying sewage to the MS4 or allows such a connection to continue.

    4. Notification of Spills

      To report improper discharges or if you observe individuals discarding waste into a storm drain system, water basin, pond, retention basin or stream on campus, please contact the Towson University Police Department (TUPD) immediately. Any person responsible for a spill or a facility or operation, or responsible for emergency response that has information of any known or suspected release of materials which are resulting or may result in Illegal Discharges or Pollutants discharging into Storm Water, the storm drain system, or waters of the state shall immediately take all necessary steps to ensure the discovery, containment, mitigation, and proper reporting of such release.

      In the event of a release of non-Hazardous Materials, contact EHS within 24 hours via the , phone, or by calling TUPD. TUPD shall contact EHS.

      If a hazardous material of any amount enters a storm sewer, immediately notify TUPD who shall immediately notify EHS. Failure to provided notification of a release above is a violation of this policy.

    5. E. Compliance

      1. The University may suspend or cease activities and operations that are not in full compliance with this policy.

      2. Whenever the University finds that a violation of this Policy has occurred, EHS may require 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 Illicit Connections or discharges;

        3. cessation of any violating discharges, practices, or operations;

        4. the abatement or remediation of Storm Water pollution or contamination hazards and the restoration of any affected property;

        5. payment of any fee, penalty, or fine assessed against the University to cover administrative and remediation cost;

        6. the implementation of new Storm Water source control or treatment BMP’s;

        7. disciplinary action up to and including dismissal, where appropriate.

      3. 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 of any additional penalties should the violator fail to take the required corrective action within the established deadline. EHS will then initiate work orders for the appropriate corrective actions and the violator or University department will be charged for the cost.

      4. The remedies listed in this policy are not exclusive of any other remedies available under any applicable federal, state, or local law.

    6. Enforcement

      1. Enforcement for student violators will follow the TU Office of Student Accountability and Restorative Practicess Code of Student Accountability.

      2. Enforcement for University employees (Faculty and Staff) shall follow the Towson University Policy for discipline or termination:

        Policy No. 07-05.25 – Disciplinary Action for Employees.

      3. Enforcement for Visitors (Non-TU Faculty, Staff or Students)

        1. Individuals, depending on the nature and severity of the violation, may be referred to MDE for prosecution for violation of federal and state laws and regulations.

        2. During normal University business hours (Monday-Friday, 8am-4pm), contact EHS to report violations.

          If the violator is still on the scene, also immediately contact TUPD.

        3. After normal duty hours, weekends and holidays, contact TUPD at to report violations.

    7. Questions

      Questions concerning this policy should be directed to Towson University’s Department of Environmental Health and Safety at either the  or by phone.

    8. Effective Date, Review, and Approval

      This policy will become effective upon the date of approval by the Provost and Executive Vice President for Academic and Student Affairs. This policy, and any related procedures, shall be reviewed annually.

Related Policies:

TU Policy 07-05.25, Disciplinary Actions for Employees

TU Code of Student Accountability

Approval Date: 02/12/2016

Effective Date: 02/12/2016

Approved By: President’s Council 02/10/2016

Signed By: President’s Council

How to Request the Policy PDF

This online version of the policy may include updated links and names of departments. To request a PDF of the original, signed version of this policy, email the Office of the General Counsel, .