The permit requirements for Illicit Discharge Detection and Elimination for Minimum Control Measure 3 (MCM 3) are defined in Section 4.2.3-4.2.3.12 of the Jordan Valley Municipalities (MS4) Permit; No. UTS000001

MCM3 Regulation Summary
Minimum Control Measure 3 requires illegal dumping and connection prevention and response programs which the regulation titles Illicit Discharge Detection and Elimination.  See Table A for joining MCM3 sections to SWMP Programs.  

Programs
3.1 Stormwater Maps
3.2 Riverton City Code
3.3 Non-Permit Regulated Enforcement
3.4 Dry Weather Screening
3.5 Emergency Spill Hotline
3.6 Illegal Dumping Hotline
3.7 Illegal Connection
3.8 Swimming Pool
3.9 Household Hazardous Waste Disposal



3.1 Stormwater Maps
Year Executed: 2003
Reference Regulation:
Maintain a current stormwater map
4.2.3.1
Target Pollutants:
sediment, nutrients, trash, petrochemicals, household chemicals, organics
Audiences:
MS4 Employees, General Public, Contractors, Developers, Planners
Description:
Riverton City maintains an online stormwater system maps and it is updated as land develops.  The maps are maintained in GIS and NAD 83 Utah Central State Plane Coordinate system.  This program also includes managing an inventory of stormwater infrastructure and for the City Comprehensive Annual Financial Report (CAFR).
Map shows City drainage infrastructure and tributary surface infrastructure, turn on layers for all City tributary infrastructure. 
Measure of Success:
Update current Stormwater Map at least annually. 
Responsible Staff:
Flood Control Engineer, GIS Specialist
Funding:
Storm Drain Fee, General Fund
Program Documents: Conclusion:
2021-2022
The City stormwater map was updated on a regular basis this report period.  


3.2 Riverton City Code
Year Executed: 2011
Reference Regulation:
Enact ordinance providing municipalities legal authority to detect, investigate, eliminate and enforce illegal connections and dumping.
4.2.3.2, 4.2.3.2.1
Target Pollutants:
Fertilizers, pesticides, herbicides, typical residential landscaping and maintenance pollutants and debris, garage chemicals and petrochemicals and other similar waste.  Waste related to similar activities associated with commercial properties.
Audiences:
MS4 Staff, Residences, Developers, Contractors, Engineers and Planners
Description:
Riverton City updated Riverton City Code in 2011 to support the MS4 regulations.  These ordinances are; 13.20 and 13.25, Stormwater development and Stormwater Utility ordinance respectively.  There are also many existing Riverton City Codes (RCC) that also prohibit activities having negative impact on stormwater quality.
Measure of Success:
Annually evaluate the programs and enforcement actions issues related to ordinance.  Make conclusions and recommendations to City.
Responsible Staff:
Flood Control Engineer, City Attorney
Funding:
Storm Drain Fee, General Fund
Appendix:
Conclusion:
2021-2022
Code revisions were not necessary.  Code provides adequate support for City Design Standards and Stormwater Programs.   Some enforcement actions were dismissed by the court which were process and evidence related not code deficiencies.  



3.3: Non-Permit Regulated Enforcement
Year Executed: 2011
Reference Regulation:
Program with legal authority to detect, investigate, eliminate and enforce, activities resulting in risk to water bodies, illegal connections and dumping.
4.2.3.2, 4.2.3.2.1, 4.2.4.2, 4.2.4.2.1, 4.2.4.2.2
Target Pollutants:
Sediment, fugitive dust, cementitious material, trash, non-stormwater liquids, and nutrients.
Audiences:
Residents, business owners and City staff involved with UPDES enforcement
Description:
Non-regulated events are activities that are not regulated by a Land Disturbance Permit or Long-Term Stormwater Management Plan Agreement.  The events can be residential and business maintenance activities resulting in exposure to drainage system and subsurface waters or it can be intentional illegal dumping events.  Enforcement actions are usually processed by UPDES personnel, the Riverton Police Department or Salt County Health Department initiated by UPDES personnel or directly by these entities.    
Measure of Success:
Annually evaluate the issues related to program enforcement.  Make conclusions and recommendations to City.
Responsible Staff:
Flood Control Engineer, Stormwater Inspector, Ordinance Enforcement, Riverton Police Department, Public Works Director, City Engineer
Funding:  
Storm Drain Fee, General Fund
Program Documents: 
Non-Permit Regulated Enforcement SOP
Conclusion:
2021-2022
UPDES staff recognized non-permit regulated events were needing to be processed differently than permit and agreement activities warranting its own unique SOP.  This program is functioning by necessity under a case-by-case basis and the official written SOP is still in development.



3.4 Dry Weather Screening
Year Executed: 2011
Reference Regulation:
Implement a plan to identify and prevent illegal connections and dumping into storm drain systems.
4.2.3.3, 4.2.3.3.1, 4.2.3.3.2, 4.2.3.4, 4.2.3.5, 4.2.3.5.1, 4.2.3.6, 4.2.3.6.1, 4.2.3.7, 5.2.2, 5.2.2.1, 5.2.3, 5.3, 5.4
Target Pollutants:
All discharges affecting the quality of runoff
Audiences:
UPDES, ordinance staff
Description:
The program involves screening the City stormwater systems outfalls with the pipe cleaning and CCTV program.  It is planned this approach will satisfy the UPDES requirement to screen each outfall at least once during the 5 year term or more as required by the Permit.  The program's purpose is to identify non-stormwater discharges resulting from permanant illegal connections and also to discover evidence of past or current illegal dumping.   The procedure is defined by the Dry Weather Screening SOP and the dry weather screening locations are shown on Riverton City’s online Stormwater Base Map. 
Measure of Success:
Maintain Dry Weather Screen Report, connection investigations, education and enforcement annually.
Responsible Staff:
Flood Control Engineer, Ordinance Enforcement
Funding:
Storm Drain Fee, General Fund
Standard Operations Procedures:
Appendix:
Conclusion:
2021-2022
Only one outfall was inspected this year.   The program has been reviewed and updated to address the program inefficiencies found with this year's annual review.  The previous program was cumbersome to implement and lacked clarity.



3.5 Emergency Spill Hotline
Year Executed: 2013
Reference Regulation:
Implement an emergency dumping, spill, response, containment and enforcement program.  Provide a hotline easily accessible on the webpage.
4.2.3.9, 4.2.3.9.1, 4.2.3.10
Target Pollutants:
Residential, automotive and construction products are anticipated and the primary focus
Audiences:
MS4 Staff, General Public, Emergency Personnel, Developers, Contractors
Description:
The Hotline Link is provided under the "I WANT TO". quick links on the City Front page.  This page provides 4 phone numbers and two one sentence definitions for Emergency Spill and Illegal Dumping Hotline.   It is also understood that residents calling in an emergency will simply call City numbers until they get a response.  Response procedure is explained by the SOP.   The program also includes residential education documents for non-critical residential spills usually only warranting education.
Measure of Success:
Maintain an Emergency Spill and Dumping Hotline Report.  Evaluate and report recommendations annually.
Responsible Staff:
Flood Control Engineer, Ordinance Enforcement, Public Works Director
Funding:
Storm Drain Fee, General Fund
Program Documents: Standard Operations Procedures:
Emergency Spill and Illegal Dumping Hotline
The same SOP is used for both Emergency Spill and Illegal Dumping.
Appendix:
Conclusion:
2021-2022  
For document management reasons illegal dumping response reporting was separated from emergency spill reporting however the response process is still the same.  One significant spill occurred this report period.  Staff responded in accordance to SOP resulting in adequate containment and clean up.  The spill was contained on impervious surface there no additional reporting was necessary. 



3.6 Illegal Dumping Hotline
 Year Executed: 2016
Reference Regulation:
4.2.3.3, 4.2.3.3.2, 4.2.3.4
Target Pollutants:
All non-stormwater discharges
Audiences:
General Public, MS4 staff
Description:
The Hotline Link is provided under the "I WANT TO". quick links on the City Webpage.  This page provides 4 phone numbers and two one sentence definitions for Emergency Spill and Illegal Dumping Hotline.   It is also understood that residents calling in active dumping incident will simply call City numbers until they get a response but when the dumping is not an emergency situation they will can the appropriate contacts at the above Hotline Page.  The City webmaster required the Emergency Spill Hotline and Illegal Dumping to be  located under the described link with the other similar quick link City functions rather than the front page.  The Staff response is explained by the SOP.  This program also includes dumping of liquids discovered during routine camera monitoring operations.
Measure of Success:
Maintain Illegal Dumping Report.  Evaluate incidences and include when and how illegal dumping was corrected.
Responsible Staff:
Stormwater Manager
Funding:
Stormwater User Fee, Sales Tax
Standard Operations Procedures:
Emergency Spill and Illegal Dumping Hotline
The same SOP is used for both Emergency Spill and Illegal Dumping.
Appendix:
Illegal Dumping Report

Conclusion:
2019-2020
Illegal connections were found but all have been either roof downspouts or land drains.

3.7 Illegal Connections
Year Executed: 2016
Reference Regulation:
4.2.3.4, 4.2.3.5.1,
Target Pollutants:
All non-stormwater discharges
Audiences:
General Public, MS4 staff
Description:
Pipe camera operations includes identification of illegal connections and prohibited UPDES discharges in addition to pipe inventory and flood control conveyance verification.
Measure of Success:
Maintain Illegal Connections Report.  Evaluate incidences and include when and how illegal connections were corrected.
Responsible Staff:
Stormwater Manager
Funding:
Stormwater User Fee, Sales Tax
Standard Operations Procedures: Appendix: Conclusion:
2019-2020
Illegal connections were found but all have been either roof downspouts or land drains.


3.8 Swimming Pool
 Year Executed: 2021
Reference Regulation:
x.x.x.x
Target Pollutants:
Chlorine
Audiences:
Residents
Description:
xxxx.
Rational: 
xxxx.
 
Measure of Success:
xxxx.
Responsible Staff:
Stormwater Manager
Funding:
Stormwater User Fee, Sales Tax
Standard Operations Procedures:
xxxx
Appendix:
Quick Link
Conclusion:
2021
xxxx.


3.9 Household Hazardous Waste Disposal

Year Executed: 2003
Reference Regulation:
4.2.3.8
Target Pollutants:
All non-stormwater discharges
Audiences:
General Public
Description:
Riverton City through the Interlocal Cooperation Agreement has co-permitted with SLCo Public Education and Outreach Program.  Their program includes Household Hazardous Waste Disposal program that meets the requirements of this MCM.  The accountability is defined by Task 2 of Co-Permit Accountability Document.
Rational: 
Co-Permitting with SLCo on this item was the most efficient and effective way to inform and provided the public this vital MCM.
Measure of Success:
This program is co-permitted with Salt Lake County and is measured by Salt Lake Counties Program.  See Salt County Coalition Annual Report Jordan Valley Municipalities Report
Responsible Staff:
Stormwater Manager
Funding:
Stormwater User Fee, Sales Tax
Appendix:
Conclusion:
2019-2020
Program 3.5 is function as intended and no changes are necessary.  



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