NCS000407_City of Mount Holly IDDE Plan_20211005

A'T�
fr J
' , CRYof Mount Holly
Illicit Discharge Detection and Elimination
(IDDE) Plan
Prepared by:
FISS
ENVIRONMENTAL
FISS Environmental Solutions, Inc. 1 9331 Tillot Drive, Matthews, NC 28105
FISS Job No, 208-30
July 2012

Illicit Discharge Response Procedures
For all non -emergency concerns of a potential illicit discharge, contact the Stormwater
Coordinator at 704-822-2939. Notify the Stormwater Coordinator the location, type and
quantity of material spilled as well as impacts to surface waters:
Contact 911 if the illicit discharge is creating a life threatening situation.
The Stormwater Coordinator will:
• Access the situation and implement proper clean up procedure.
• Document the following:
- date, time and location of the spill,
name, address and phone number of the responsible party,
type and quantity of product spilled,
- clean up actions completed,
description of environmental impacts name of surface waters impacted,
cause of the spill
description of any mitigating factors (including icy roads, power failure, etc.),
- attach pictures (including date, time stamp and description),
- witnesses to the incident,
persons contacted on -scene
- specific corrective actions you provided including any notices of violation issued, and
include any other relevant information as necessary.
■ If the problem is related to a sewer spill or other City issue, contact the appropriate
department.
• Contact the Mooresville Regional Office (MRO) of the N.C. Division of Water Quality
at 704-563-1599 for all oil spills to the ground greater than or equal to 25 gallons or
spills within 100 feet of a surface water conveyance, including storm drain Inlets,
swales, channels, creeks, lakes, ponds, etc. A spill of any amount that reaches
surface waters must be reported. If after hours, they are to be contacted at 8:00
a.m. the next business day.
• Contact Gaston County Natural Resources at 7D4-922-4181 for sediment & erosion
concerns or fish kills exceeding 100,
• Always perform a follow up investigation to ensure that the cleanup has been
completed in accordance with local and State regulations.

OUTFALL RECONNAISSANCE INVENTORY/ SAMPLE COLLECTION FIELD SHEET
Section 1: Background Data
Subwatershed:
Outfall ID:
Today's date
Time (Military):
investigators;
Form completed by:
Temperature ff)
Rainfall {in j: Last 24 hours.
Last 48 hours
Latitutde_
Longitude;
CPS Unit:
CPS LMK #
Camcra:
Photo ks:
Land Use in Drainage Area {Check all that apply)-
0 Industrial
❑ Ultra -urban Residential
❑ Suburban Residential
❑ Commercial
❑ Open Space
❑ Institutional
Other:
Known industries:
Notes {e.g... origin of outfalI, if known);
Section 2: Outfall Description
LOCATION
MATERIAL
SHAPE
DIMENSIONS (IN.)
SUBMERGED
❑ RCP ❑ CMP
❑ Circular
❑ Single
❑iamelerlDimensions:
in Water
❑ No
❑ PVC ❑ HDPE
❑ Eliptical
❑ Double
❑ Partially
❑ Fully
❑ Closed Pipe
❑ Slccl
❑ Box
❑ Triple
With Sediment_
❑ Other:
❑ Other;
❑ Other;
❑ No
❑ Partially
❑ Fully
❑ Concrete
❑ Trapezoid
Depth.
❑ Earthen
❑ Open drainage
❑ Parabolic
Top Width:
❑ rip -rap
❑ other:
Bottom Width:
❑ Other:
❑ In -Stream
(applicabie wizen collecting samples)
Flow Present?
❑ Yes ❑ No If No, Skip to Section 5
Flow description
(if present)
❑Trickle ❑Moderate El Substantial
Section 3: Ouantitative Characterization
FIELD DATA FOR FLOWING OUTFALLS
PARAMETER
RESULT
UNIT
EQUIPMENT
❑Flow #1
Volume
Liter
Bottle
Time to fill
Sec
Flow depth
In
Tape measure
Flow width
--
Ft, in
'rape measure
❑Flaw lit
Measured length
�'
Ft, In
'rape measure
Time of travel
S
Stop watch
Temperature
° f'
Thermometer
pH
pH Units
Test strip/Probe
Ammonia
mg/L
'lest strip

Outfall Reconnaissa cn a Inventory Field Sheet
Section 4: Physical Indicators for Flowing Outfalls Only
Are Am I'll nvtical Indicatnm Present in the Flnw? ❑ Yes I-1 No r tf Nn Thin rn .4orlinn 5)
INDICATOR
CHECK if
Present
DESCRIPTION
RELATIVE SEVERITY INDEX (1-3)
(Nor❑
[I Sewage ElRancid/sour ❑ Petro I eunVgas
❑ l —Faint
❑ 2 — Easily detected
❑ 3 — Noticeable from ti
❑ Sulfide ❑ Other.
distance
Color
� ❑
❑ Clear Brown Gray Yellow
❑ ElEl❑
l —Faint colors in
❑ 2 —Clearly visible in
❑ 3 — Clearly visible in
❑ Green ❑ Orange ❑ Red ❑Other:
sample bottle
sample bottle
outfall flow
Turbidity
❑
See severity
❑ I — Slight cloudiness
❑ 2 —Cloudy
❑ 3 —Opaque
Floatables
❑ Sewage (Toilet Paper, etc.) ❑ Suds
Ell — Few/slight; origin
❑ 2 — Some; indications
of origin (e.g"
El - Some. origin clear
(e.g., obvious oil
-Does Not Include
Trash!!
❑
❑ Petroleum (oil sheen) ❑ Other
not
not obvious
possible sods or oil
sheen, suds, or fleatin g
sheen)
sanitary materials)
Section 5: Physical Indicators for Both Flowing and Non -Flowing Outfalls
Are ohvsical indicators that are not related to flow nresent? 71 Yes n No W Arb, Skip to Section 61
INDICATOR
CHECK if Present
DESCRIPTION
COMMENTS
Outfall Damage
❑
❑ Spalling, Cracking or Chipping ❑ Peeling Paint
❑ Corrosion
DepositslSLains
❑
❑ Oily ❑ Flow Line ❑ Paint ❑ Other:
Abnormal Vegetation
❑
❑ Excessive ❑ Inhibited
Parr pna! quality
[]
❑ odors ❑ Colors ❑ Floatables ❑ Oil Sheen
❑ Suds ❑ Excessive Algae ❑ Other:
Pipe benthie growth
❑
❑ brown ❑ orange ❑ Green ❑ Other:
Section G: Overall Outfall Characterization
❑ Unlikely ❑ Potential (presence of two or more indicators) ❑ Suspect (one or more indicators with a severity of 3) ❑ Obvious
Section 7: Data Collection
1, Sample for the lab? ❑ Yes ❑ No
2. If yes, collected from- ❑ Flow ❑ Pool
3_ Intermittent flow trap set? ❑ Yes ❑ No If Yes, type: ❑ OBM ❑ Caulk dam
Section S: Any Non -Illicit Discharge Concerns (e.g., trash or needed infrastructure repairs)?

0

I."l 1h;V
City of Mount
Holly
Illicit Discharge Detection and Elimination
(IDDE) Plan
Prepared by:
FISS
.� ENVIRONMENTAL
PISS Environmental Solutions, Inc. 1 9331 Tillot Drive, Matthews, NC 28105
FISS Job Na 208-30
July 2012

TABLE OF CONTENTS
I Introduction
1.1 Purpose
1.2 Requirements and Definitions
1.3 Exampies of Illicit Discharges
2 Planning and Approach
3 Field Screening Procedure
3.1 IDDE Hotline Complaints
3.2 Dutfall Inspection Procedure
3.3 Dutfall Ranking
4 Investigation and Tracing
4.1 Drainage Area and Storm Drain System Investigation
4.2 Analytical Indicators
4.3 Gnsite investigations
5 Equipment and Safety
6 Timing/ Schedule
7 Removal Confirmation and Records
8 Spill Response and Notifications
8.1 Gaston County
8.2 State of North Carolina
8.3 US Environmental Protection Agency
8.4 Contact Phone Numbers
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LIST OF TABLES
Tabie 1
Six Stage Process of an Effective IDDE Program
Table 2
Guide for Completing the Outfall Reconnaissance Inventory (ORI) Field Sheet
Table 3
Analytical Threshold Screening Values (selected from references)
Table 4
Analyticai Indicators and Potential Sources
Table 5
Dry Weather Outfall Inspection Schedule Guide
Table 6
Emergency Contact List
ATTACHMENTS AND REFERENCES
1. Illicit Discharge Hotline Tracking Sheet
2. Outfall Evaluation and Ranking Flow Chart
3. Outfall Reconnaissance Inventory 1 Sample Collection Field Sheet
4. Illicit Discharge Detection and Elimination: A Guidance Manual for Program Development and
Technical Assessment. Brown, E-, Ca.racc, D., and Pitt, R. 2004. Center for Watershed Protection and
University of Alabama_ EPA X-82907801-O.U.S. EPA Office of Wastewater Management, Washington,
D.C.
5. Illicit Discharge Detection and Tracking Guide, Center for Watershed Protection, 121212011
h :,, wHw_cw .urn+duculnersts�cai viewR�7- nllutisrn-drt�Cti es -to �lkic� 1 [l1-illicit-diseharee-d4ti:ction-and-
Trad utguide.litm1
ADDITIONAL REFERENCES, not attached
1. Illicit Discharge Detection and Elimination Program, Summary Report 2000 — 2010, a Comparison of
Oulfall Screening, reporting, and Outfall Inspection Programs, July 2011, Kitsap County Department
of Public Works, Surface and Stormwater Program, Mindy Fohn, Stan Olsen and Mauro Heline.
2. North Central Texas Illicit Discharge Detection & Elimination (IDDE) Field Investigation Guide,
2011 (North Central Texas Council of Governments)
3. Outfall Screening Manual, Snohomish County Department of Public Works, Snohomish Co.,
Washington,Iiqp://www.co.snohomish.wa.. us/documents/DepartmentslPublic_ Worksisurfacewatermanagement/w
ater auality�outfal!_srrceninv-coutfalhnanual_field _►vorLpdt
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I. Introduction
1.1 Purpose
This Illicit Discharge Detection and Elimination kTDDE) Program is required by the City's Municipal
Separate Stormwater Sewer System (MS4) permit. The permit is issued by the NC Department of
Environmental Resources, Water Quality Division under the authority of EPA and the Clean Water Act. The
objective of the IDDE program is to identify and remove non-stormwater discharges that contain pollutants
that discharge to surface waters such as ponds, creeks, streams, rivers and takes. These un-permitted
discharges may include washwaters, sanitary flows, septic system seepage, and other non -allowable flows
that may be tied to the storm drain system.
A reactive approach to detecting illicit discharges includes the following sources of information:
1. Hotline complaints and reports form the public
2. Water quality data indicating impairments(during dry weather)
3. During routine staff activities
The City of Mount Holly's comprehensive IDDE program described herein includes proactive steps
designed to achieve elimination of significant water pollution sources using a systematic cost effective
approach. The following activities are included in the program:
■ Outfall mapping
■ Prioritizing areas
Outfall screening
0 outfall inspection
o dry weather flow water sampling
■ Categorizing outfalls based on findings
■ Source investigation
o Track and confirm
■ Ordinance enforcement
■ Public education
■ Citizen reporting hotline
■ Municipal field staff training to identify and report illicit discharge
Dry Weather Stormwater Outfall Inspections are an integral part of an effective IDDE program. This written
Dry Weather Stormwater Outfall Inspection Protocol contains observationn checklists, schedules, a basis for
prioritizing outfall inspections, procedures for field inspection, criteria for classifying high risk outfalls and
performing additional testing, follow-up reporting and corrective measure documentation.
The plan is intended to be flexible based on available resources_ The flan can be evaluated on an annual
basis to determine the most cost effective techniques based on available funding and manpower.
The ranking of outfalIs provides a basis for measuring and reporting goals for permit compliance within
the City's Stormwater Management Plan.
A spill reporting section is also included as Section 8 to provide the City with notification procedures
and contact information in the event that a release to a water body is discovered as part of the Outfall
inspection program.
This IDDE program prepared for the City of Mount Holly is based on documents available through the
Center for Watershed Protection and University of Alabama (2004 Guidance Manual and 2011 IIlicit
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Discharge Detection and Tracking Guide referenced above) as well as IDDE field work experience by FISS
Environmental Solutions, Inc_ personnel and IDDE implementation assessment reports prepared by Kitsap
County Washington Department of Public Works, and the North Central Texas Council of Governments
(referenced above).
1.2 Requirements and Definitions
The City of Mount Holly has an existing Stormwater Ordinance. According to the City's lllicit Discharge
Ordinance, an illicit discharge is defined as:
"any physical connection or other topographical or other conditions, natural or artificial, which is
not specifically authorized by ordinance or written rule of the City, which causes or facilituttw.
directly or indirectly, an illicit discharge. "
"any discharge into the City of Mount Nally storm sewer system prohihited by the M34 permit, the
terms of which are herehy incorporated by reference into the ordinance.
"Sediment pollution originating from excessive erosion rates on a construction site not otherwise
subject to either the city or Gaston County soil and erosion control ordinances, or sedimentation
pollution entering a municipal storm sewer that causes water quality violation is considered an
illicit discharge.
According to the City's MS4 permit, the definition of an illicit discharge is:
Permit Illicit Dischar e
"Any discharge to a MS4 that is not composed entirely of stormwater except discharges pursuant to
an NPDES permit (other than the NPDES 114W4 permit), allowable non-stormwater discharges, and
discharges resultirrgfrom fire -fighting activities. "
Allowable Discharges are defined under the MS4., (Part 1, 9.)
(a) "Permitted by, and in compliance with, another permit, authorization, or approval, including
discharges of process and non process wastewater, and stormwater associated with industrial
activity; or
(b) Determined to be incidental non-stormwater flows that do not significantly impact water quality
and may include:
• water line and fire hydrant flushing;
• landscape irrigation;
• diverted stream flows;
• rising groundwaters;
■ uncontaminated groundwater injUtration; as defined in 40 CFR 35.2005(20)
• uncontaminated pumped groundwater;
• discharges from uncontaminated potable water sources,
-
• foundation drains;
• air conditioning condensate (commerciallresidential);
• irrigation waters;
• springs-
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• water from crawl space pumps;
• footing drains;
• lawn watering,-
• residential and charity car washing,•
• , f1'ows from riparian habitats and wetlands;
• decidorinated swimming pool discharges;
• street wash water,-
■ flows from emergency fire, fighting.
The Division may require that non-stormwater flows of this type be controlled by the
permittee's Stormwater Plan. "
If these discharges are identified as significant contributors of pollutants to writers of the United
States, the MS4, the City, must address them.
The City's MS4 Permit requires that:
• The permittee conduct reactive inspections in response to complaints and follow-up
inspections as needed to ensure that corrective measures have been implemented by
the responsible party to achieve and maintain Compliance.
■ The permittee track all investigations and document the date(s) the illicit discharge was
observed; the results ofthe investigation; any follow-up of the investigation; and the date the
investigation was closed.
1.3 Examples of Mcit Discharges
The following is a list of common potential illicit discharges:
I . Car 1 vehicle washing
2. Vehicle fueling
3- Driveway 1 parking lot washing 1 power washing
4. Dumping 1 spiIls
5. Equipment washdown
6. Lawn and Landscape and grounds watering and care
7. Swimming pool discharges
8_ Vehicle maintenancetrepair
9. Outdoor material storage
10. Spills and leaks associated with industrial 1 commercial material loading
l l . Grease trap/equipment cleaning
12. Industrial process water or rinse water
13- Concrete and paint washwater
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2. Planning and Approach
The first step that the City should take is to conduct a desktop assessment to organize a perpetual plan for
inspecting each of the city's stormwater outfalls.
The city has an existing stormwater outfall map as required by the M54 permit. As preparation for
implementation of the IDDE Program, the City will need to use the stormwater outfall map to organize
outfalls into areas and to create a schedule in order to visit outfall_ Other information such as sanitary sewers
and septic system service area mapping will also be useful in the planning stage_ The City may choose to
prioritize the areas defined.
The objective is to visit and rank each outfall once during the five year permit cycle (2012 — 2016), with the
goal of ranking each outfall by the end of the permit cycle. In subsequent years, the IDDE program can be
re-evaluated to continue to focus on high risk outfalls. Together with the City's Surface Water Quality
Monitoring Program, Stormwater Public Education 1 Community Hotline, and City public work force
training program, the IDDE program can evolve into an effective program that focuses on fewer outfalls over
time.
A rating system is proposed, where each outfall is given a "grade" or ranking, based on current information
about the outfall. A color coded ranking system is proposed, but an alfa- numeric system (A, B, C, D and F)
could alternatively be used.
For the color ranking system, each outfall is rated as Blue (Unlikely), Green (Potential Intermittent), Yellow
Wotential), Change (Suspec' yind Red (0b4bus), In this way, the program can evolve to use city resources
to most cost effectively locate and eliminate illicit discharges that cause the greatest water quality
impairment. Based on budgetary considerations, the City can focus illicit discharge source tracking and
elimination on the high priority outfalls coded "Red" and "Orange". Once an illicit discharge is eliminated,
the outfall can be re -coded as "Blue" (Unlikely), or other appropriate rating to reflect the confidence level
achieved at eliminating the illicit discharge. This allows some flexibility and judgment within the program.
Beginning in 2012, the city's permitted stormwater outfalls will be screened using a modified version of
"rapid field screening technique' as developed by Brown, E., Caraco, D., and Pitt, R. 2004. After the initial
screening, the program can focus on public education and citizen/municipal reporting hotlines to identify
illicit discharges using very limited water quality sampling. This modified program developed for the City of
Mount molly is based on review of other existing programs (see references) as well as personal field
experience with tracking dry weather discharges.
The approach is to conduct a systematical visual field screening of stormwater outfalls (inspections) in
priority sub -watersheds. The priority sub -watersheds are defined prior to the field work using storm
drainage and sewer maps, stream water quality data and land use. Field screening is conducted during dry
weather to identify potential illicit discharges (i.e., flowing outfalls) and may include indicator monitoring to
characterize flow types to aid in finding sources.
The references sited provide tips for prioritizing sub -watersheds for inspections_ Knowledge of what ranks
an area at a higher risk for illicit discharges can also be used as a guide in assessing each area based on its
characteristics. The City may choose to assess the highest risk priority sub -watershed in the first year,
with the lower priority outfails inspected near the end of the permit cycle.
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Factors that may indicate a higher probability of finding dry weather discharges that should be used in
prioritizing sub -watershed include the following:
■ No. of outfalls per stream mile
Prioritize outfalls to streams that have the greatest number of outfall per stream mile. In accordance
with the referenced 2004 EPA Guidance Manual, "the greater the number of outfalls along a stream.
the higher the risk of an illicit discharge"
■ lndushial and older developments
Areas with a higher density of industrial sites, especially industrial areas more than 40 years old,
have a greater potential for discharges, along with older neighborhoods and developments_
■ Septic tanks
Areas with a higher density of septic systems, and older septic systems (more than 30 years old) are
prone to failure, (Swann, 2001). As a guide, consider that a higher illicit discharge potential may be
suspected if older septic tank density exceeds 100 per square mile. (EPA 2004 Guidance Manual)
• Areas with elevated levels of hotline complaint
If areas within the city show an increase in the number of potential illicit discharges reported, the
outfalls nearby should be a higher priority_
■ Use of stream monitoring data
Areas with poor dry weather surface water quality suggest possible illicit discharges may be present.
If dry weather water quality monitoring data have been collected for local streams, it can be an
extremely useful resource to screen sub -watersheds potential illicit discharges. In particular, look
for extreme concentrations of Fecal Coliform, high ammonia -nitrogen or conductivity. Only data
collected during 24 hour dry weather should be considered since wet weather water duality data will
reflect stormwater runoff. The following benclunarks for individual stream sairiples measured
during dry weather are recommended in the 2004 EPA Guidance Manual (see references) to
indicate, and consequently prioritize, upstream stormwater outfalls:
• Fecal coliform (>1= 1,000 to 5,000 MPNI100 ml)
• Ammonia -nitrogen >/ 0.30 mgll
• Total phosphorus >/= 0.40 mgll
• Conductivity levels that exceed the 90 percentile value for the pooled dataset
Table I below has been prepared as an outline to the City's IDDE program. The program can be
implemented using the six (6) steps described in the table. Details of the program are provided in the
subsequent sections of this plan..
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Table I
Six Stage Process of an Effective LDDE Program
Six Stage IDDE Program
1. DIVIDE OUTFALLS
• Define priority areas
into sub watersheds
• Divided into five sub -watersheds
■ Complete an inspection and screening of
one sub -watershed per year for a 5-year
cycle.
2. INSPECT and TEST
Conduct Outfall Field Screening
outfall during dry weather
• Hotline reports and available stream
monitoring data issues should be also
investigated
■ Observation checklist
Sample dry weather flows (optional)
3. PRIORITIZE each Outfall
• Unlikely
■ Potential (continuous or intermittent)
■ Suspected
■ Obvious
4. INVESTIGATE to find source
■ Detection, testing, sampling and tracing
sources
■ Lab analysis, additional testing
■ Investigative reporting
■ Confirm
• Define corrective actions
5. CORRECTIVE ACTION
■ Elimination, and reporting
■ Ordinance enforcement
• Remove source or report to the State for
permitting
• Corrective measures
■ Spill response
6, TRACK
■ Document follow-up and closure
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3. Field Screening Procedure
Each outfall will be inspected, and tested as needed, according to the procedures described in this section. In
general, all stormwater outfalls are inventoried, and dry weather discharges are observed and screened for
severity. The outfall screening process can also be used to update the stormwater outfall map.
The screening procedure consists of a combination of:
1. Out -fall Reconnaissance Inventory and observation
2. Sampling and analysis of flows with severe visual indicators
An outfall inventory checklist is to be completed for each outfall, and dry weather flow samples may be
collected from outfalls that have severe visual evidence of pollution. Each outfall will be placed in a priority
category, based on evidence obtained in the inspection. The system is structured such that the outfalls that
are highly suspected or have obvious illicit discharges are prioritized for further investigation, so that
resources can be focused on eliminating these sources.
3.1 IDDE Hotline Complaints
In addition to the structured outfall inspection process, potential illicit discharges reported through the
hotline or by city employees working in the field, should be placed on the "suspected" list and given priority_
A useful form for the City's hotline program is provided as Attachment 1 - Illicit Discharge Hotline Tracking
Sheet adapted from the Center for Watershed Protection.
Based on the Center for Watershed Protection IDDE Tool. it referenced, the following types of potential
IDDE Hotline Complaints can be expected, along with the likely sources:
a. Sewage smell, or floatables from storm drain outfall during dry weather flow-
Storm and sanitary sewer cross -connection.
b. Small (<6" diameter) pipe directly discharging to receiving water -
Straight pipe discharge from home or business.
c. Greatly discolored or unnatural smelling liquid (often hydrocarbons) flowing from or pooling on
property or from outfall below property-
■ Dumping.
d. Sewage smell; extra green vegetation; saturated ground-
s Failing septic system.
e. Muddy water; sediment deposits, up stream construction site-
s Poor erosion and sediment control.
3.2 Outfall Inspection Procedure
The primary field screening tool recommended by EPA and the Center for Watershed Protection is the
Outfall Reconnaissance inventory (OR]) field sheet. The procedure and form is described fully in Brown et
aL, 2004 (see references). A copy of this form is provided as Attachment 3.
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An ORI is a stream walk designed to inventory and measure storm drain outfalls, and find, document, and
correct continuous and intermittent discharges without in-depth laboratory analysis.
Outfall screening includes:
• Marking and photographing all outfalls
■ Using stormwater maps and working upstream, within each watershed
• Recording outfall visual characteristics and condition
■ Estimating the flow using simple flow measuring techniques
• Taking samples at outfalls with likely problems
• Scheduling follow up action and tracking
■ Addressing major problems immediately
The Basic screening procedure at each outfall is summarized in the following six (6) steps:
1. Photograph
Take a picture of the outfall and, if the outfall is not already in the City's mapping system,
collect GPS coordinates.
2. Outfall Marking
Label the outfall with spray paint or waterproof marking stick in a prominent location such as the outfall
headwall.
3. Outfall Reconnaissance Inventory (ORI) Field Data Sheet
Complete the ORl form contained in Attachment 3. The form includes:
■ Description of the outfall (e.g., pipe material, diameter),
Description and severity of physical indicators of potential illicit discharges for flowing outfalls
(odor, color, turbidity, floatables)
• Description of the physical (visual) indicators of pollutants at all outfall (flowing and non -flowing),
including damage, stains, deposits, vegetation, pool quality, and benthic pipe growth
• Use Table 2 below as a guide in completing the ORI for each outfall
4. Dry Weather Flow Sample Collection
Collect water quality field data at flowing outfalls. (Optional, depending on the other factors)
Collection of samples is discretionary, and may be limited based on budget constraints. Many
municipalities skip water sampling and proceed to investigate upstream to locate the source. Only
limited sampling in the suspect areas is recommended. A small set of indicator parameters has been
selected based on the existing water quality data in the area. The most cost-effective approach is to use
the municipal laboratory wherever possible, along with contracted laboratory services for additional
parameters where needed. As a starting goal, it is generally recommended that a minimum, 10% of
flowing outfalls are sampled per year.
If the outfall has dry weather flow, two (2) samples can be collected:
• one for on -site analysis of ammonia;
■ one for fecal coliform bacteria
The procedure for collecting a water sample is as follows:
a. Put on sampling gloves
b. Sample the discharge directly into the appropriate sample bottle
C. Do not discard or spill the preservative in pre -preserved sample bottles
d. Label bottles with outfall number, time, and date
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C. Complete the Chain -of --Custody
f. Place bottles in the cooler with ice.
g. Delver to the lab, or call lab for a sample pickup
All samples collected for lab analysis must be preserved as specified by the lab for the specific
parameters being analyzed. Refer to the Standard Methods for the Examination of Water and Wastewater
for more information about sample collection and sample preservation:
http:Ilwww.standardmethods.org/. Note that Fecal Coliform Bacteria samples must be processed within
b hours of collection. For this reason, prior arrangements should be made with the lab, and sampling on
Fridays and the day before holidays must be avoided.
5. held Testing (optional)
Conduct the Ammonia field test following the manufacturer's instructions on the test kit, and record the
results on the ORI form. This test is optional. Based on visual indicators, the inspectors may move
immediately upstream to locate the source.
Examples of field tests include:
• HACH DR120000 Spectrophotometer
■ HACH ISE Test strips
• Hanna and Chemetrics Field Test Strips
G. Dry -Weather Flow Rates
Where flow is observed, the flow should be measured as accurately as possible based upon actual field
conditions. Use of one (1) of the following techniques is proposed:
Flow Method 1:
Utilizing a graduated container, such as a milk jug or bucket marked at 1 gallon increments and a
stopwatch to record the amount of time required to till the container to 1 gallon. Ensure you are
capturing the entire flow. When the flow is only a trickle, use a smaller volume container and follow
the same method_ Use the following equation to calculate flow:
Discharge = Volume filled (gallons) x Time (minutes)_
Flow Method 2.
This method could not be verified and is therefore is not recommended.
Flow Method 3_
Using a tape measure record the cross -sectional area of flow by measuring and record the width of
the flow and the depth of the flow. Using a measuring tape, ping pong ball, and stop watch, to
record the length of time it takes to travel a known distance. Repeat this velocity measurement 3-5
times and average the results. Then use the following equations to calculate the flow rate and record
the results on the ORI form:
Area= Wetted width (ft) x flow depth (ft)
Velocity-- Length of ping pong ball run (ft)1 Time (sec)
Discharge= Area x Velocity (cubic feet per second)
Table 2 below provides a description of data to be collected in accordance with the eight (8) sections on the
ORI form. Section 5 - Outfall Rating in Table 2 is discussed further in Section 3.3 below.
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Table 2
Guide for Completing the dutfall Reconnaissance Inventory (OR][) Field Sheet
Section on Form
Data Collected
Section I
■ Watershed
a Recent rainfall
Background Data
■ Date and time
a Longitude and latitude
a Outfall number
a GIS information
■ Investigators names
a Land use
■ Air temperature
Section 2
a Type of pipe 1 drainage structure or ditch
Outfall Description
■ Flow description
Section 3
■ Flow measurement
Qualitative Characterization
■ Ammonia (optional field test strip or kit)
(Field data for flowing outfails)
Section 4:
■ Odor
Physical Indicators for Flowing
■ Color
Outfalls
■ Turbidity
(Visual observation)
■ Floatables
Section 5:
• Outfall Damage
Physical Indicators For All Outfalls
■ Deposits 1 Stains
Abnormal vegetation
e Poor receiving pool quality
a Pipe benthic growth
Section G:
mirNon-flowing
outt'all with less than 2 physical
Rating of Outfall Characteristics
-
indicators of an illicit dischar e.
Potential
Non -flawing outfall with two or more physical
Based on physical indicators listed in
Sections 4 and 5.
J nterWt
indicators of an illicit discharge.
Potential
]Flowing outfiall no high severity on any physical
indicatom and no lab results exceeding threaholds.
Refer to the Outfall Evaluation and
Ranking Flow Chart in Attachment 2.
Suspect
Flowing outfall with either presence of severe
physical indicator(s) or exceedance of a lab parameter
threshold.
Obviou1-=nffii�rrned-
outfali with high severity of one or more
physcal indicators and sample shows presence of lab
meter indicator; or source is directly observed, or
SectionFlowing
7:
Fecal Colifonn
Potential Data Collection for
a Nitrate + Nitrite
Flowing Dry Weather Discharges
a Phosphates
(Potential Parameters (as determined
a Detergents
necessary):
a Potassium
Section 8-
Any Non -Illicit Discharge Concerns
Trash or needed infrastructure repairs
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3.3 Outfall Ranking
Based on the information collected during the outfall inspection, along with any laboratory analysis results
from sampling, or obvious discharge sources, each outfall is given a status rating. The rank for each outfall
can be changed at any time based on current levels of evidence.
The OutfalI Evaluation and Ranking Flow Chart (Attachment 2) has been prepared for the City to be used as
a guide in qualitatively classifying each outfall_ The rank levels range from "Unlikely Illicit Discharge" to
"Obvious Illicit Discharge". Each rating level can be assigned a color code as follows:
With this system, the program can evolve to use city resources to most cost effectively locate and eliminate
illicit discharges that cause the greatest water quality impairment by prioritizing Red, then Orange outfalls,
etc.
The chart outlines the decision process set up to classify each outfall based on evidence collected using the
ORI. The components of the flow chart are further discussed below:
1. Primary Physical Indicators
The condition of the outfall is observed initially during the field inspection. The condition of the
outfall, and whether or not the outfall is flowing at the time of the dry weather inspection, can
provide evidence of past or intermittent illicit discharges. Primary indicators recorded during
the ORI include stains, damage to the outfall structure, deposits, and poor receiving water
quality, benthic pipe growth and unusual (dead, excessive, slime, algae) stream side vegetation.
2. Is there Dry Weather Flow?
Depending on the physical indicators observed in the inspection, a non -flowing outfall at the
time of the inspection may be considered "potentially intermittent" if significant indicators are
observed at the outfall.
If there is no dry weather flow and the outfall is in good condition (no more than one negative
physical indicators is present) then the outfall is coded `Blue", which means that illicit
discharges at this outfall are "Unlikely"_
If dry weather flow is not present, but there is evidence of at least two (2) Primary Physical
Indicators of pollution, then the outfall can be classifies as "Green" or having a "Potentially
Intermittent" illicit discharge. This low priority outfall can be placed on a list to re -inspect at a
later date.
3. Dry Weather Flow is Present
If the source is not obvious, then the flow is qualitatively analyzed using visual and olfactory
(smell) clues including odor, color, turbidity, and floatables. These are termed "Visual Flow
Physical Indicators" of contamination_ These flow related observations are rated in terms of
severity, and samples of the flow may be collected, if desired.
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The flow can be tested for parameters including Ammonia, and additional samples can be
collected for laboratory analysis if desired. Field tests kits are available to determine the
ammonia concentration in the field. The literature threshold screening levels for Ammonia in
dry weather discharges vary widely. The CWP Illicit Detection and Tracking Guide (12/2011)
cites a threshold of >0.1 mg/1 of Ammonia as evidence of an illicit discharge. Table 3 is a list of
typical threshold values used by other municipalities. This table can be used as a guide to
evaluate analytical data if it is collected form a suspected illicit discharge to determine the
appropriate rank to be assigned to the outfall. Thresholds should be adjusted to reflect local
conditions.
If none of the Visual Flow Physical Indicators are rated as "severe", as recorded on the ORI
form, then the technician may choose to take additional samples to be analyzed in the lab.
However, this plan stresses source tracking in lieu of laboratory testing to discover sources. If
no field or lab analysis of the flow is made, then the outfall can be ranked as "Yellow" -
"Potential" in accordance with the chart.
If the field samples and or lab samples do not indicate pollution, then the outfall is also classified
as "Yellow" or as a "Potential" illicit discharge, which can he re -inspected at a later date, based
on the number of outfalls with a higher priority.
If, based on the observations of the flow and 1 or analytical testing of the flow, there is
sufficient evidence of contamination, then the outfall is classified as "Grange" or "Suspected"
illicit discharge. Additional samples may be collected. "Orange" outfalls should be traced to
detect and eliminate the source.
If the flow has at least one severe physical indicator of contamination and water quality tests
suggests an illicit discharge, then the outfall is coded as "Red" with an "Obvious" illicit
discharge to be investigated and eliminated.
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Table 3
Analytical Threshold Screening Values (selected from references)
Level of
Parameter
certainty
Ammonia
Fecal
Total
Detergents
Potassium
Phosphates
Nitrate +
the dry
(mg/1)
Coliform
Coliform
(mg/I)
(mg/1)
(mg/I)
Nitrite
weather
(cfu/100 MI)
(cfu/I00 MI)
Nitrogen
How is an
(mg/1)
Blicit
Discharge
CWP Guide (2011)
Suspect
> 0.1
> 10,000
> 0.25 > 6.0
Kitsap County (2000-2010
Potential
0.1 — > 0.2
200 - c 500
0.5 - < 1.0
1 - < 1.5
I.0 — 3.0*
Suspect
0.2—>1.0
500-<
1-<2.0
1.5-<5.0
3-<I0
2000
Obvious
>/= 1.0
> 2000
>/= 2.0
>/= 5.0
>/= 10
North Central Texas 2011)
Level of
1.0
400
0.2
0.5
1.0
concern
Snohomish County, W shington
Action
> 3 mg/l
> 5,000
> 3 mg/1
> 1.0
Level
* Nitrate- N only
* * http: //www. co. snohom i sh .wa. us/docu►n enWDepartments/Pub l ic_ W ork s/surfacewatermanagem en t/water
qua l ity/o utfal l_screening/outfallm an ual_f iel d_work.pdf
4. Follow Up and Tracking
All outfalls with a confirmed illicit discharge will require a drainage area investigation as
described in the next section. If the outfall is determined to have a potential illicit discharge
"Greed" or "Yellow" based on physical indicators, but samples do not exceed established water
quality thresholds, the outfall should be re -visited two additional times during the permit cycle to
determine if an intermittent discharge may be present. Ideally, the follow-up inspection will
occur on a different day of the week than the original visit and/or at a different time of day.
Any dry weather flow where the source is obvious should be placed on the "Red" or "Obvious"
illicit discharge list so that corrective action can be initiated. If a visual observation of an illicit
discharge is obvious, such as excessive suds or sewage odors, an investigation should be
initiated immediately.
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4. Investigation and Tracing
When dry weather flow is present at an outfall and/or other observations suggest a Suspected or Obvious
illicit connection or discharge, a source tracking investigation should be initiated to locate and eliminate the
potential pollution source(s). A source tracking system consists of several investigative techniques
including:
• Visual inspection at manholes and upstream storm drains
• Sandbagging or damming to collect intermittent discharges
■ Smoke testing
• Dye testing of plumbing fixtures
■ Video testing
• Lab analysis
• Infrared aerial photography analysis
■ Septic tank/system inspections
4.1 Drainage Area and Storm Drain System Investigation
Investigate the conveyance system by moving up -stream from the outfall until the source of
pollution is located or point source pollution is ruled out using the following steps. Accurate storm
and sanitary sewer mapping is a prerequisite to conducting an effective storm drain investigation.
1. Identify storm drain system of ditchesgines and inlets -
Identify the conveyance system up -stream of the outfall.
Z. Locate drainage system nodes -
Locate points within the outfall's conveyance system where the drainage branches.
3. Visually screen the conveyance system -
Walk or drive the entire length of each segment looking for visual and olfactory indicators of the
potential pollutants).
4. Follow the flow -
Follow the dry weather flow up -system until a potential source is reached_ or to the last known
conveyance point.
5. Where flow is not observed but an intermittent discharge is suspected -
Locate ajunction manhole, and partially dam all inlets to the structure for the next 48 hours
when no precipitation is forecasted. Inlets can be damned by blocking a minimal percentage of
the pipe diameter at the invert using sandbags, caulking, weirs/plates, or other temporary
barriers. The manhole can be subsequently re -inspected (during dry weather) to capture
suspected intermittent discharges.
6. Identify land use -
Identify the land uses within the conveyance system and decide whether the visual and olfactory
indicators are unique to a specific land use to narrow the search.
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4.2 Analytical Indicators
This plan stresses field observations, ranking and source tracking in lieu of sample collection and analysis to
discover sources. If samples are collected and analyzed for the purpose of ranking outfalls, the presence of
indicator parameters can be used as a guide in identifying possible sources of illicit discharges and can assist
in the tracking investigation.
If sampling is done, sample at the site of the potential source or the last known conveyance point. Also
collect a sample of the dry weather flow at the outfall to verify that the flow at the potential source is the
same as the flow at the outfall. The sampling parameters may include Fecal Coliform, Ammonia, Potassium,
FIuoride, Phosphates, Nitrite + Nitrate and Surfactants_ Additional parameters may be added depending on
land use, and the visual and olfactory indicators present. Table 4 below, is a list of possible sources that
correspond to various indicator parameters.
Table 4
Analytical Indicators and Potential Sources
Indicator
Comments
Possible Source
Parameter
Ammonia
Can change into other nitrogen forms as
■ Sewage
flow travels to the outfall
■ Se to e
Nitrate + Nitrite
High levels of nitrate may indicate
■ Septage
Nitrogen
biological waste or runoff from heavily
fertilized areas;
Nitrites are often used as corrosion
inhibitors in industrial process and
cooling water and are used in food as
preservatives
Fecal Coliform
Can be found in the feces of human and
■ Sewage
other warm blooded animals from direct
discharge
Detergents
■ Sewage
■ Laundry wash water
■ Other wash water
Potassium
■ Sewage
■ Septage
■ Laundry wash water
■ Industrial liquid wastes
■ Commercial liquid wastes
Fluoride
• Tap water
Phosphates
• Fertilizer
■ Industrial waste
4.3 On -Site Investigations
There are five (5) basic techniques that can be used to investigate and determine the source of an illicit
discharge:
1. Dye testing,
2. Video testing
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3. Smoke testing
4. Infrared aerial photography analysis
S. Septic tank/system inspections
Before performing any dye or smoke testing, make sure to contact other city departments, spill response
agencies, and the local wastewater treatment plant and downstream municipalities to let them know you are
testing.
These techniques can also be also used when conducting a follow-up investigation once an illicit discharge
has been found. Refer to the CWP IDD Tracking Guide Manual (Attachment 5) for detailed information on
how to use these techniques.
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5. Equipment and Safety
The field inspection and investigative work performed by city employees should be conducted under the City
of Mount Holly safety procedures and standards in place for city personnel. As a supplement to the City's
policies, a brief description of some of the safety considerations to be followed as part of the IDDE program
is outlined below. This list is not intended to be all inclusive. The information is based on guidelines in the
Illicit Discharge ,Detection and Tracking Guide, by the Center for Watershed Protection, 2011.
RECOMMENDED SAFETY GUIDELINES
A. CREWS
1. Minimum two staff per crew
2. Make sure that someone knows where your crew is scheduled to be
B. CLOTHING
1. Long pants, closed toed shoes, gators are strongly recommended
C. WEATHER
1. Monitor the weather; do not conduct Feld work during unsafe weather conditions such as
flooding, thunderstorms, and severe heat or cold conditions.
D. STREAM WALKS AND SAMPLE COLLECTION
1. Wear waders with high traction soles
2. Avoid skin contact when suspected water is polluted, and wear protective gloves
3 _ Wash hands and use san itizer after contact with potentially polluted water
4. Were highly visible orange vests during hunting season, and when near traffic.
5. Follow Material Safety Data Sheets when handling any chemicals, including using the
proper gloves, safety eyewear, and proper disposal of reagents.
E. MANHOLES AND OTHER STRUCTURES
1 _ Wear steel -toed shoes and use proper lifting tools and procedures when removing manhole
covers.
2. Minimize the time the manhole is open, and do not leave the manhole open and unattended.
3_ Do not enter or put your head below the rim of the manhole opening_
4. Place barricades around open manholes located in open spaces such as roadways and
parking lots.
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A list of suggested equipment is provided below.
EQUIPMENT LIST
A. Field Binder with Maps
1. Roads
2. Streams
3. Storm drain network
4. Septic systems
B. Field Equipment
l . One -liter clean, sterile sample bottles
2. Cooler and ice
3. Backpack
4. Zip lock bags
5. Camera
b. Cell phones or hand-held radios
7. First aid kit
8. Flash light or head lamp
9. GPS unit
10. Spray paint (or other outfall marker)
11. Surgical gloves
12. Tape measure
13. Graduated wide -mouth container to measure flow
14. Waders (snake proof where necessary)
15. Stop watch or timer
16. Ping -pang ball
C. Forms, etc.
L Clip boards and pencils
2. Chain -of Custody Forms
3. Outfall Reconnaissance Inventory Forms
4. Inspection notification letter documenting legal authority to gain access to property during field
inspection
5. Contact information of police and emergency response personnel in case of spills or active illicit
discharges
D. Optional
1. Portable Spectrophotometer and reagents (can be shared among crews)
2. Insect repellant
3. Machete/clippers
4. Sanitary wipes or biodegradable soap
5. Test strips or probes (e.g., pH and ammonia)
Program managers should also consider requiring/recommending field crews be vaccinated
against Hepatitis B, particularly if the crews will be accessing waters known to be
contaminated with illicit sewage discharges. Local health department officials should be
contacted to explore this issue in more detail prior to making a decision.
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6. Timing and Schedule
Routine on -going inspections of stormwater outfalls are a primary part of an effective IDDE program. The
goal is to complete the outfall Inspection on every stream mile in the Mount Holly MS4 within the next
permit cycle. After the initial inspection of all outfalls, the program is set up to continue long-term
inspections for outfalls based on a priority rating.
The optimal time to conduct outfall inspections and tracking of sources is during the late Fall through early
Spring, when deciduous vegetation is dormant, and leaves are not present. This is the time when it is easier
to obtain access to the outfalls and observations of the outfalls are Iess hindered by vegetation.
In North Carolina, "leaf -off' months are typically fate November through early March. This 15 - 18 week
time period is merely optimal, and inspections can be conducted year round if necessary to fit with city work
force availability and to allow each outfall to be inspected in the permit cycle.
Stormwater outfall inspections must be conducted during dry weather. Generally, "dry weathers' can be
defined as a time when no rainfall has occurred in the area draining to the outfalI for a period of at least 48
hours. Ground water levels should also be low. For example, during a season of unusually high
precipitation resulting in elevated groundwater levels, the number of outfalls with ground water may be
higher, resulting in both illicit discharges masked by groundwater flow, and time consuming efforts spent on
sampling and tracking flowing "Potential" Illicit discharges that are composed of allowable groundwater
sources.
Table 5 below is a general schedule template that can be used be the City to develop a specific OutfalI
Inspection Program. Since the City is well into the first year of the current permit cycle, the schedule
provided below is based on a 4 year period_ The last year of the schedule can be used to evaluate the cost
effectiveness and results of the IDDE program.
Inspect all outfalls at least once per permit period. If the City is able to inspect complete outfall inspections
at a greater pace, the schedule can be adjusted accordingly. Depending on the resources that the City has
available for IDDE program and the number of stormwater outfalls currently inventoried, as well as the
number of "Potential", "Suspected", and" Obvious" illicit discharges detected as the program is
implemented, this schedule can be adjusted to ensure that resources are focused on the actual elimination of
Illicit Discharges as they are detected.
Outfall inspections can be conducted using the outfall map, and for wanting entire stream reaches. (Refer to
Illicit Discharge Detection and Tracking Guide Center for Watershed Protection 2011). While some
municipalities actually walk each of the streams, this process can be intrusive for property owners. The City
of Mount Holly can decide what works best.
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Table 5
Dry Weather Outfall inspection Schedule Guide
Schedule
Sub -watershed
Outfall Numbers
Permit term
As defined by background data
review
Initial
Re -Inspect
(Review of Outfall Map, surface water
inspection
quality data. ,number of outfalls in each
sub -watershed and riorit are 0))
(each outfall)
Year 1
Outfall No. a — a'
First 25%
Current running list of
"Potential" anal
'Potential Intermittent'Outfalls
Year 2
Outfall No. b — b'
Next 25 %
Current naming list of
"Potential" and
"Potential Intermittent" Out -falls
Year 3
Outfall No. c — c'
Next 25 %
Current running list of
"Potential" and
"Potential Intermittent" Outfalls
Year 4
OutfalI No. d — d'
Remaining
Current running list of
25%
"Potential" and
"Potential Intermittent" Outfalls
Year 5
Evaluate IDDE program cost effectiveness-
(1) Where "a" = Outfall no. 1 and "d"' = the last outfail. Replace [a, a', b, b', c, c', d, and d'] with actual outfall
numbers.
Dry weather flows that are ranked as "Potential", "Suspected" and "Obvious" are sampled and tested
indicator pollutant parameters. "Suspected" and "Obvious" illicit discharges, coded as "Red" and "Orange"
are investigated and traced to the sources. The City should keep a record of the number and percentage of
flowing outfalls sampled and traced each year of permit cycle.
After the initial inspection cycle is complete, the next cycle should be focused on priority outfalls, based on
City stream water quality data collected as part of the City's separate Surface Water Quality Monitoring
Program, and re -inspection of outfalls with "Potential" discharges, rated as "Green" and "Yellow".
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7. Removal Confirmation and Records
After completion of the removal of each illicit discharge, the outfall should be re -inspected to verify
corrections_ Once the Illicit discharge is eliminated, the Outfall can be re -ranked as a `Blue" outfall,
indicating it is "clean" and "unlikely" to be have any illicit discharges. Verification records can also include
records from plumbers and/or contractors regarding work completed to remove the illicit connection.
Measurement of the progress of the City's 1DDE program should be tracked using metrics that may include
the following:
l . Number and percent of outfalls screened
2. Number and percent of manholes inspected
3. Number and percent of illicit discharges discovered
4. Number and percent of illicit discharge sources identified using:
■ Visual inspection
■ Field testing (sampling)
s Temporary damming
Dye testing
• Video inspection
S. Number of illicit discharges eliminated
5. Current number and percentage of outfalls with each rating category
This information can be used as measurable results for reporting under the City's MS4 permit, and to
measure the cost effectiveness of source tracking and investigative techniques.
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8. Spill Response and Notifications
During implementation of the IDDE program, City personnel may discover active spills or discharges to the
storm sewer system of ditches, pipes or outfall, to the ground, or directly to surface waters. In preparation
for discovery of a spill or release, this section is provided as a guide for reporting the spill to county, state
and federal authorities, as required.
In the event of a discharge of harmful quantities of oil, both the National Response Center and the State and
Local Emergency Response Centers should be contacted immediately. The party responsible for a spill is
who is required to report the spill to authorities.
01iL
Harmful quantities are defined as discharges of oil that (1) violate water quality standards, or (2) cause a film
or sheen upon or discoloration. of the surface of the water or adjoining shorelines or cause a sludge emulsion
to be deposited beneath the water surface or upon adjoining shorelines,
HAZARDOUS SUBSTANCES
Spills or releases of hazardous substances are subject to reporting requirements under state and federal
regulations. The MSDS of a chemical should be examined upon a spill or release of that chemical.
Although a chemical may be perceived as harmless, it may be made up of hazardous constituents (such as
the paints used on -site that contain xylene, toluene, or ethyl benzene) that have reportable quantities and
require special clean-up procedures.
Reportable spills includes all releases during a 24-hour period of oil or hazardous substance in an amount
equal to or in excess of Reportable Quantities (RQs) under Section 31 I of the Clean Water Act, Section 102
of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and extremely
hazardous substances under Section 344 of the Superfand Amendments and Reauthorization Act, Title III
(SARA Title III). These regulations are listed in Title 40 of the Code of Federal Regulations, parts 110, 117,
302 and 355 respectively. These regulations are subject to future amendments. Current RQ lists should be
consulted for each spill in 44 CFR 110, 117, 302, and 355_
8.1 Gaston. County
Gaston County, North Carolina, addresses spill reporting in its Stormwater Ordinance as follows:
"Spills or leaks of polluting substances released, discharged to, or having the potential to be
released or discharged to a s tormwater conveyance system, shall be contained controlled, collected
and properly disposed.
All affected areas shall be restored to preexisting conditions.
Persons in control of the polluting substances and persons owning the property on which the
substances were released or discharged shall immediately notes Gaston County Emergency
Management of the release or discharge, as well as making any required notifications under state
and federal law. Notification shall not relieve any person of airy expenses related to restoration,
loss, damage, or any other liability which may be incurred as a result of said spill or leaf nor shall
such notification relieve any person from other liability which may be imposed by State or other
law. "
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Contact information:
Emergency Management Information fine
704-866-3004
Reporting Telephone Number
704-866-3350 M-F 8AM-5PM
704-866-3300 after hours
Mailing_ Address
P.D. Box 1578, Gastonia, NC 28053 -1578
8.2 North Carolina
Reporting of oil spills in the State of North Carolina is regulated under NC General Statutes - Chapter 143
Article 21 A as follows:
1 d3-215.85. Required Notice
`A person who owns or has control over petroleum that is discharged into the environment
shall immediately take measures to collect and remove the discharge, report the discharge
to the Department within 24 hours accordance with the requirements of this Article if the
volume of the petroleum that is discharged is 25 gallons or more or if the petroleum causes
a sheen on nearby surface water or if the petroleum is discharged at a distance of 100 feet
or less from any surface water body.
If the volume of petroleum that is discharged is less than 25 gallons, the petroleum does not
cause a sheen on nearby surface water, and the petroleum is discharged at a distance of
more than 100 feetfrom all surface water bodies, the person who owns or has control over
the petroleum shall immediately take measures to collect and remove the discharge.
If a discharge of less than 25 gallons of petroleums cannot be cleaned up within 24 hours of
the discharge or if t he discharge causes a sheen on nearby surface water, the person who
owns or has control over the petroleum shall immediately notes the Department "
The NC Division of Water Quality (DWQ) has an Emergency Response webpage that provides reporting
instructions;
h tp-/—/VortaI.nedenr.org�%veblw_qlhomellr
During the normal workday - Monday - Friday, 8 a.m. through 5 p.m. —Contact:
NCDWQ Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville, NC 28115
704-663-1699
Do not leave a message. Make sure that you speak to an actual person so that you can share information that
may be necessary to a fast response.
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Outside of normal business hours, call the 24-hour emergency Hotline (after hours and on weekends)
NCNENR Emergency No.
1-800-858-0368
8.3 CIS Environmental Protection Agency (EPA)
The EPA has an on-line spill reporting form where Spills and other Environmental Violations can be
reported: htiJi;ll�vwu.epa.7uy;rptehurtt��vialaunns_htmtir�part
For emergencies and other- sudden threats to public health, such as:
0 oil and/or chemical spills,
o radiation emergencies, and
a biological discharges,
Call the National Response Center at 1-800-424-8802.
&4 Contact Phone Numbers
Table 6 below lists telephone numbers of local and state emergency service contacts, utility companies and
other important spill notification numbers.
Table 6
Emergency Contact List
SERVICE/AGENCY
CONMIIIENTS
TELEPHONE
Charlotte Fire Department/Police
24-hour Operator
911
Department/Medical Emergency
M-F Sprn-5pm
704-866-3350
Gaston County Emergency Coordinator
after hours
704-866-3300
National Response Center
24-hour Operator
800-424-8802
NCDENR Mooresville .Regional Office
Local office
704-663-1699
North Carolina Department of Environment and
8.00 am — 5:00 pm
919-733-3867 or
Natural Resources Emergency Management
919-733-3899
Office
24 hours
800-858-0368
US EPA Waste Management Division
If dealing with a waste
404-562-8651
Piedmont Natural Gas Emergency Service
24-hour Customer Service
704-525-3620
Duke Power Company (for transformer oil)
24-hour Customer Service
704-594-9400
Hepaco, Inc.
24-hour Spill Response
704-598-9787
{Emergency Response Clean -Up Contractor}
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f
I. Illicit Discharge Hotline Tracking Sheet
2. Outfall Evaluation and Ranking
Chart

Tab 1

Incident ID:
Responder Information
Call taken by:
Call date:
Cali time:
Precipitation (inches) in past 24-48 hrs:
Reporter Information
Incident time:
Incident date:
Caller contact information (optional):
Incident Location {complete one or more below}
Latitude and longitude:
Stream address or outfall #:
Closest street address:
Nearby landmark:
Primary Location Description
Secondary Location Description:
❑ Stream corridor
(In or adjacent to stream)
ElOutfall
Elin-streamflow
❑Along banks
❑ Upland area
(Land not adjacent to stream)
0 Near storm drain
El Near other water source (storm water pond, wetland, etc.):
Narrative description of location:
Upland Problem Indicator Description
❑ Dumping
❑ OiVsolvents/chemicais
❑ sewage
❑ Wash water, suds, etc.
❑ other:
Stream Corridor Problem Indicator Description
Odor
❑ None
❑ Sewage
❑ Rancid/Sour
❑ Petroleum (gas)
❑ Sulfide (rotten eggs);
natural gas
El Other: Describe in "Narrative, section
Appearance
El "Normal"
ElOil sheen
❑ Cloudy
❑ Suds
❑ Other: Describe in "Narrative" section
Flnatahles
❑ None:
I ElSewage (toilet paper, etc)
ElAlgae
ElDead fish
❑ Other: Describe in "Narrative" section
Narrative description of problem indicators:
Suspected Violator (name, personal or vehicle description, license plate #, etc.):
Source: Illicit Discharge Detection and Elimination, Center for Watershed Protection, Oct. 2004

Investigation Notes
Initial investigation date:
Investigators:
El No investigation made
Reason:
Referred to different department/agency:
Department/Agency:
Investigated: No action necessary
El Investigated; Requires action
Description of actions:
Hours between call and investigation:
Hours to close incident:
Date case closed:
Notes:
Source: Illicit Discharge Detection and Elimination, Center for Watershed Protection, Oct.
2004

'L.isa Hagood
From: [e-mail]
Sent: Thursday, October 18, 2012 6:17 AM
[e-mail]
bject: Re: Question
Hi Lisa,
Great to see you and chat last week.
Did you find anything unusual when you looked upstream from Noles Drive? After the rain earlier this week I checked the
stream and didn't see anything unusual... but it sti11 looks funky compared to years past. Thanks for all your help.
Jim
In a message dated 10/10/2012 1:44.31 P.M. Eastern Daylight Time, lisa,[e-mail] writes;
Friday at 3 works for me - enjoy the wedding
From: [e-mail][mailto:Travelingman19471,daol.com]
Sent: Wednesday, October 10, 2012 11:48 AM
To: [e-mail]
Subject: Re: Question
I'm sorry but tomorrow won't work for me. I'm going to a wedding at 3 PM. I could do anytime in the morning or
Friday at 3 if either works for you. Let me know. Thanks again for your help and support on this.
In a message dated 10/10/2012 11 i40:02 A.M. Eastern Daylight Time, I_is_a__ha_ [e-mail] writes.
I am back at work today but have been in training class- how does tomorrow afternoon look for you?
Same time?
My son has that stomach virus going around school
From: [e-mail] mailto:Travelin man1947CCJaol.com]
Sent: Tuesday, October 09, 2012 8:43 AM
To: 1 isa. hagood (-d) mtho,l iy. as
Subject: Re: Question
That's not a problem. I hope it's nothing serious. Let me know when you can reschedule.

Jim
In a message dated 10/9/2012 8:41:48 A.M. Eastern Daylight Time, lisa.haaood(2mtholly,us writes
Jim
I am sorry, but I will have to reschedule our meeting for this afternoon. My son's school just
called me saying he is sick and 1 am leaving work to go get him.
Lisa
From: Trayelinciman1947Cwaol.com[mailto:[e-mail]]
Sent: Monday, October 08, 2012 4:56 PM
To: [e-mail]
Subject: Re: Question
3:00 is fine. See you then. Thanks.
In a message dated 10/8/2012 4:52:31 P.M. Eastern Daylight Time, hsa.haclooclCc�mtholly us
writes:
I am free all afternoon (after 1:30) — and don't want to have you change your
schedule — is 3:00 ok?
From: Travelingman194.7�cuaol,com mailto:Travelin manl947 cuaol.corr2]
Sent: Monday, October 08, 2012 4:07 PM
To: [e-mail]
Subject: Re: Question
Sure ... what time? ! can tell you that going upstream gets rough. t followed it until I hit
Kudzu head high and quit.

I just find it strange after all these years that the flow has stopped ... and not the oily
crap. Makes me wonder.
Let me know a target time and I'll be here. Thanks so much.
Jim
in a message dated 10/8/2012 4:03:13 P.M. Eastern ❑aylight Time,
[e-mail] writes:
Hi -- and of course I remember you.
What you are describing sounds strange. I can come out and look/
investigate upstream, but the earliest I can make it is tomorrow afternoon.
If there is oil, Mount Holly has an "illicit discharge" ordinance that we can
get the violator to clean up for be financially responsible) for clean-up.
Finding the violator is sometimes difficult though.
Are you available tomorrow afternoon?
Thanks, Lisa
Lisa W. Hagood, PE
i
MOU i
4
HOLLY
City of Mount Holly
400 East Central Ave.
Mount Holly, NC 28120
704-951-3020 (o) 704-323-9319 (c)
p- itjol
�Yr Ocrober
3

From: Travel ingman1947�aol.corn [mailto:Traveli_ng_manl947(8)aol.com]
Sent: Monday, October 08, 2012 3:17 AM
To: tisa.hagood(a)mtholly.us
Subject: Question
Hi Lisa,
Don't know if you remember me or not. Jim McKinnish @ 248 Antelope
Drive. You did the work on the curbing and the stream bed at the rear of my
home.
I have a question and I'm not sure where to direct it. I noticed a few weeks
ago that the stream flow at the rear of my house just stopped. I've lived here
19 years and it has never completely stopped. I thought someone may have
dammed it up somewhere up stream and attempted to follow it but the under
growth was just too much. When we had recent rain the flow returned and I
thought nothing of it. Today while getting leaves off the adjacent area I
noticed the flow was once again almost completely gone. The disturbing
part is that there appears to be some type of oily residue on the rip rap and
what water is in the stream bed appears to have an oily substance on the
surface. I worked for 25 years in the chemical business and know how
illegal dumping can target small tributaries that feed into other major bodies
of water. Who would you suggest I contact to come take a look at this? I
don't know it Gaston County has an EPA officer ... do you?
Any help you can give me to direct me is appreciated.
Best regards,
,Jim McKinnish

wmOorin
�.�.�.. Financial Corporation
September 5, 2012
Danny Jackson
Mt. Holly City Manager
400 East Central Ave.,
Mount Holly, NC 28120
RE: NCDENR Notice
Dear Mr. Jackson:
8614 Westwnod Center Drive
Suite 500
Vienna, VA 22182
[phone] ■ Fax [phone]
Enclosed please find a notice from NCDENR regarding the property located at 1212 W. Catawba Avenue, Mt. Holly, NC
28120.
If you have any questions, please feel free to call me directly at [phone].
Sincerely,
Mooring Financial Corporation
wza"161110-
Dan Briotti
Asset Manager
dbrititti(a�mooringfinancial.cotii

Al�'Av
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue, Govemor Division of Waste Management Dee Freeman, Secretary
UST Section Dexter R. Matthews, Director
August 9, 2012
Mooring Financial Corporation
8614 Westwood Center Drive, Suite 500
Vienna, Virginia 22182
Attention: Daniel J, Brioth
Re: Notice of No Further Action
15A NCAC 2L .0407(d)
Risk -based Assessment and Corrective Action
for Petroleum Underground Storage Tanks
Belmont Textile Machinery Company
1212 West Catawba Avenue, Mount Holly
Gaston County
Incident Number: 36173
Risk Classification: Low
Dear Mr, Briotti:
Please note that this correspondence replaces the original Notice dated July 31, 2012. The Notice
of Residual Petroleum received by the UST Section, Mooresville Regional Office on May 3, 2012 has
been reviewed. The review indicates that groundwater contamination meets the cleanup requirements for
a low -risk site but exceeds the groundwater quality standards established in Title 15A NCAC 2L .0242.
The UST Section determines that no further action is warranted for this incident. This
determination shall apply unless the UST Section later finds that the discharge or release poses an
unacceptable risk or a potentially unacceptable risk to human health or the environment. Pursuant to Title
15A NCAC 2L .0407(a) you have a continuing obligation- to notify the Department of any changes that
night affect the risk or land use classifications that have been assigned.
Be advised that as groundwater contamination exceeds the groundwater quality standards
established in Title 15A NCAC 2L .0202, groundwater within the area of contamination or within the area
where groundwater contamination is expected to migrate is not suitable for use as a water supply.
As groundwater contamination exceeds the groundwater quality standards established in Title
15A NCAC 2L .020, pursuant to NCGS 143B-279.9 and 143B-279.11, you must file the approved Notice
of Residual Petroleum (attached) with the Register of Deeds in the county in which the release is located
and submit a certified copy to the UST Section within 30 days of receipt of this letter. This No Further
Action determination will not become valid until the UST Section receives a certified copy of the Notice
of Residual Petroleum which is filed with the Register of Deeds.
As groundwater contamination exceeds the groundwater quality standards established in Title
IrA NCAC 2L .0202, public notice in accordance with 15A NCAC 2L .0409(b) also is required. Thus,
An Equal Opportunity I Affirmative AClion Empioynr - 50 % Recycled 1 10 % Post Consumer Paper

Mooring FinaneW Corporation
August 9, 2012
Page 2 of
within 30 days of receipt of this letter, a copy of the letter must be provided by certified mail, or by
posting in a prominent place, if certified mail is impractical, to the local health director, the chief
administrative officer of each political jurisdiction in which the contamination occurs, all property owners
and occupants within or contiguous to the area containing contamination, and all property owners and
occupants within or contiguous to the area where the contamination is expected to nugrate. Within 60
days of receiving this no further action letter, this office must be provided with proof of receipt of the
copy of the letter or of refusal by the addressee to accept delivery of the copy of the letter or with a
description of the manner in which the letter was posted. This No Further Action determination will not
become valid until rRihlic notice requirements are completed. Interested parties may examine the Soil
Cleanup Report/ Site Closure bequest by contacting this regional office and may submit comments on the
site to the regional office at the address or telephone
This No Further Action determination applies only to the subject incident; for any other incidents
at the subject site, the responsible party must continue to address contamination as required.
If you have any questions regarding this notice, please contact the at the address or telephone
number listed below.
Sincerely,
4pm Z�
Brad C. Newton, P.G.
Hydrogeologist H
Mooresville Regional Office
ee. Rusty Norris Elm Environmental Solutinns
Gaston County Health Department
UST Regional Offices
Asheville (ARO) — 2090 US Highway 70, Swannanoa, NC 28778 (828) 2964500
Fayetteville (FAY) — 225 Green Street, Suite 714, 5ystel Building, Fayetteville, NC 28301 [phone]
Mooresville (MOR) — 6I0 East Center Avenue, Suite 301, Mooresville, NC 28115 [phone]
Raleigh (RRO)— 1628 Mail Service Center, Raleigh, NC 27699 (919) 7914200
Washington (WAS)-- 943 Washington Square MAIL, Washington, NC 27889 [phone]
Wilmington (WIL) — I27 Cardinal Drive Extension, Wilmington, NC 28405 [phone]
Winston-Salem (WS) — 585 Waughtown Street, Winston-Salem, NC 27107 [phone]
Guilford County Environmental Health, 400 West Market Street, Suite 300, Greensboro, NC 27401, [phone]

Ij 1 f r ❑❑ t LIED L
� , i � � ffr � (• l' � I ^,w i tiers. -
- 1 a
ZZ
I I fl 5DEl
3597710
_
ram_ 4
? C [ C-j

Tab 2

Outfall Evaluation and Ranking Flow Chart
Start
Inspect Outfall Primary
Record physical Physical Indicators
description
Outfall damage
Deposits / stains
Abnormal vegetation
Poor receiving pool quality
Pipe benthic growth
Is l5
r<Yesthe yes there dry
source weather
obvious flow
� 7
No
Measure Flow
Field test for
Ammonia and
collect lab
samples
(optional)
No
No,Are
there 2 or
more
Primary
Physical
Indicators
present
Visual Flow Physical Indicators I
SeVerity I
(flow related)
Odor
Color
Turbidity
Floatables
(not including trash)
Is _
at least one or
more Visual
Flow Physical
Indicators
rated 3 or higher
7
Yes
Lab
resu Its
indicate
pollution
Yes
No
Dot
Lab
results
indicate
pollution
Y
Yes
No Suspected
ar nn data illicit Discharge
Obvious
illicit Discharge
Obvious
illicit Discharge
Unlikely
Illicit Discharge
Yes Potential Intermittent
Illicit Discharge
RE -INSPECT
Later or
set flow trap
RE -INSPECT
later
No Potential
or no data Illicit Discharge
Consider
additional
> sample analysis
HighNij
INVESTIGATE - TRACE
priority
SOURCE
• Smoke test
• Dye test
Top
Video test
priority
CORRECTIVE
ACTION
Adopted and modified from North Central Texas Illicit Discharge Detection & Elimination (IDDE) Field Investigation Guide, 2011

Tab 3

Illicit Discharge Detection and Tracking Guide
APPENDIX[ A. OUTFALL RECONAISSANCE INVENTORY (ORI) FORM
01-1F-ALL REcoR-NAI55ANCE L\L-LN-oRv! 5 VdP'LE COLIJECT110IN FIELD SHEET
Section i - Baek-ornunrk Data
submtetshed:
Qut6ll ID.
Toth{ s date:
TbAe i%UUtm
lay eshgatas;
Fatm completed icy:
T at m {°Fr Ramfaa (ia): East 24 hatas: L2048 hems:
Latitude: Ltmmmde:
GPS unit GPS I_\SR
Camara:
Photo.0s:
Land Use m Drmmge .Lea (Cheek ali than gph-l:
❑ Iadnstztal Rmidmn"I ❑ Comma,-4 l
Other;
Notes (e-c-, o6on of oot afu If jmQp9y:
❑ Opm Spade ❑ SulmxbanF_tndt , © Imarateanal
Knoaalnd vnas;
aeceto¢ _: v¢taau
LOCATION
Closed Pipe
Nf— eje
DIMENSIONS (INN SUBMERGED
Dupetff, cmcul r- — In Rater
❑ do
Boa:h--w-� ❑?snzll}''
❑ Fnlh••
£]ap4cal Kith Sediment.
h--w- ❑Vo
❑ Pl).
❑ Fnllr
❑ Trapezoid ❑ Other_ Depth Bottom R'idrh:
❑ Canttrtr ❑ rip -rap ❑ Fstthm —
❑ Open drainage ❑ Patabobe Top Width
❑ In -Stream Complete Snvm Discharge form
Finks Present". ❑ Yes D No 1J_So, SIV to Section r FioreDtscription ❑ Trickle ❑ Moderate © Substantial
-Tidal" ❑ ve's El No, Ifses. 5e43e 0 Flood ❑Ebb Time-
MATERIAL
❑ RCP ❑ C?4IP
❑ Fvc ❑ EiDPE
❑ Sted
❑ Othc
r fireinn it.
Ai��n rie.eiae !'H �a•�v►er•irse:nn
SHAPE
❑ Cncular
❑ $:mt+
❑ FEhptieal
❑ Douhk
❑ Sox
❑ Triple
❑ fir —
❑ od—
FIELD DATA FOR FLOWING OUTFAILS
PARAMETER RESULT UNFf EQLIPMEm
won' .6i
7skmie
Iiber
Bock
Time to fill
Sec
Sktpratch
0F74ty 'v2
Flow depth
In
Tape measear
{oaly for Aet•-
ontFalls]
LL aML4nidih
It
Tape meastae
Flim. width
Ft_ In
Tape umsar
I]Flosr *3
Flow depth
In
Tape measmr
Fir of tracd lave
1_ 1 3-
Sec
Stop APnmb
Meastued lmz;b
Ft La
Tape meassae
Ammm a
toe-L
Specific ion probe T77e-
llkcit ❑lscharge Deteclion and Elimination
Center for Watershed Protection p. 25 of 29

Illicit Discharge Dete[tion and Tracking Guide
❑utfnll Reconnali5ance Inventory Field Sheet
Section 4: Physical Indicators for Flov%ing 0utfaUs Only
Afir 1tw Ahc;iril TnAirrfnrc arrant iti thr 41mr`� F-1 Yec r \n eT{tin Cfin M �.rfMS. {
INDICATOR
CHECK If
Present
DESCRIPTION
RELATIVE SEVERITY INDEX (t-3)
Odor
❑
❑ Sewage ❑ Rancid -sofa ❑ Petroleumgas
❑ i —Faint
❑'—Eesih' detected
❑ 3—Nottceable from a
❑ Sulfide ❑ Other
distance
Color
❑
❑ Clear ❑ Broisp ❑ Gray ❑ Yellow
❑ l —Faint colors in
C]' — Cleary iiubk in
❑ 3 — Clearly risible is
❑ Green ❑ Orange ❑ Red Omer
smvle bottle
sample borde
out fall flov4
Turbidity'
❑
Seem-trity
❑1—SbehteIOU dint Ss
❑2--Cloud)•
❑3—Opaque
Fleatab[es
Not Inc hide
❑
❑ Snvage (Toilet Paper, etc.] ❑ Suds
[� 1— Few lieht; origin
❑ '— — Some: indications
of o6gin (e,g ,
❑ 3 - Some; origin Clear
(e g„ ob�lOUS ail
.Dw
Trash! !
❑ petrokt= (oil sheen) ❑ Other.
not obi ious
Po ssibie suds or oil
sheen, suds. ar Aoatin S
411leS[)
+n+tart' nratenals)
Section 5: Physlcal Indicators for Both Flowing and 'son -flowing Outfalls
1r n1l v eII i ,A ien Inrc 011t -1r. not r►l�twd to CT nrrerri r' n Yre n Nn i Yin 10F :n Co,^rin;s fig
INDICATOR
CHECK 11 Present
DESCRIPTION
COMMENTS
Outfall Damagr
❑
❑ Spallm; Cracking or Chipping ❑ Peeking Paint
❑ Carrosion
Bcposits Stains
❑
❑ Oita' ❑ Flow Line ❑ Paint ❑ OdWr.
abnormal Vegetation
❑
❑ Excessive ❑ [nhibited
Poor pool quahh'
©
❑ Odors ❑ Colors C]Floatabies C] Oil Sheen
❑ Suds ❑ Excessive Algae ❑ Other
Pipe benthic growth
❑
❑ 9roilm ❑ Orange 0 Crteen © Other,
Section o: Overall ❑U(fa H C Laracterizalion
❑ LTAL-ely ❑ Potential (pfesence of two or more indicators) ❑ Su, pect (one or more indicators with a seventy of 3) ❑ Obvious
Section': Data Collection
1. Sample for external tab" ❑ YES ❑ No 1 Sample for CW 7 ❑ Yes ❑ No 3. Sterile sample for bacteria analysis` ❑ Yes ❑ No
4, Sample(s) collected front ❑ Flow ❑ Pool
5. Duplicate collected' ❑ Yes ❑ No Ifyes, dieckappropriarr: ❑ ExtemalIab ❑ C%;T ❑ Sterile
Section 3: kny;ou-Illicit Discharge Concerns {e.g-, trash or needed infrastructure repairs) or other Notes?
Centerf
Illicit Discharge Defection and El minallon

Tab 4

ir'
:4441 [i
by the
Center for
Watershed Protection
and
Robert Pitt
University of Alabama
DischaraE
ollf[i
October 2004

Illicit Discharge
Detection and Elimination
A Guidance Manual for Program Development and
Technical Assessments
by
Edward Brown and Deb Caraco
Center for Watershed Protection
Ellicott City, Maryland 21043
and
Robert Pitt
University of Alabama
Tuscaioosa, Alabama 35487
EPA Cooperative Agreement
X-82907801-0
Project Officer
Bryan Rittenhouse
Water Permits Division
Office of Water and Wastewater
U.S. Environmental Protection Agency
Washington, D.C.
October 2004

Table of Contents
Table of Contents
Foreword . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I
Acknowledgments .......... ......... . . .... ........ . .............. ill
List of Tables ...... . . ... . .... .. .. . . .. .. . . ... .. . .. . .. . . .. ... . . . . . .. viii
List of figures .......... . . ............. . .... .. ...... . . ... ... . ... . . . ix
Introduction . . . . .... .. . .... . ....... . . . . .. .. . . ... .. . . . .. ... . ....... t
Chapter T_ The Basics of Illicit Discharges .................................... 5
1.1
Important Terminology and Key Concepts . , . . . . . . . . . . . . .
. . . . . . . . . . 5
1.2
The Importance of Illicit Discharges In Urban Water Quality . . . . . . . . . .
. . . . . . . . . . 15
1.3
Regulatory Background For Illicit Discharges . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . 16
1.4
Experience Gained in Phase I. . . . . . . . . . .. . . . . . . . . . . . . . .
. . . . . . . . . 19
Chapter 2: Components of an Effective IDDE Program . . . ......... .. . . . ...
. . . . . . . . . 23
2.1
Management Tips to Develop an Effective IDDE Program .. . . . . . . .
. . . 25
Chapter 3: Auditing Existing Resources and Programs .............................
29
3.1
Audit Overview . . . . . . . . . . . . . . . . , . . . . . , . . . . . . . . . . _
. . . . . . .. . . 30
3.2
Develop Infrastructure Profile . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . 32
3.3
Establish Legal Authority . .. .. .. .. . . . . . .. . .. . . .. . . ..
.. ... , ... 32
3A
Review Available Mopping .... . . .. . . . . ... . . . .
33
3.5
Availability of Field Staff . .. .... . . . ... .... .. . . .. .. .. . . .
. . . .. . . .. _ 33
3.6
Access to Laboratory Analysis . , . . . . . . . . . . . , . . , , . .
. . . . . , . , . 34
3.7
Education and Outreach . . . . . . . . . . . . . . . . . , . . , .
34
3.8
Discharge Removal Capability and Tracking. . . . . . . , . . . , . . . , . . ,
, . . , . , . . , . 35
3.9
Program Funding. . . . . . . . .. . . .. . . . . . . . . . . . . . . . . . . . . . .
. . . .. . . . . 35
3.10
The Initial IDDE Program Plan . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . 38
Chapter 4: Establishing Responsibility and Legal Authority ............. . ............
39
4.1
Identify Responsible Deportment/Agency . . . . . . . . . . . . . . . . . . .
. . . . . . . . 40
4.2
❑eveiop Local Illicit Discharge Ordinance . .. . . . . , . .. . . . ..
. . . .. . . . . . 40
Chapter 5: Desktop Assessment of Illicit Discharge Potential ... . . . .. , . . . . ..
... . . . ... 45
5.1
Overview of Desktop Assessment of Illicit Discharge Potential ..... .....
... .. .. . . . 46
Chapter 6: Developing Program Goals and Implementation Strategies ..... . .............
57
6.1
Overview of Goals and Strategies Development ... , , , .... _ . . .
... . . , , , . 58
6.2
Develop Initial Program Goals . . . .. , . . . . . . , .. . . . . . . _ . . . . .
. . . . . . . . . . 58
6.3
Crafting Implementation Strategies . . . . . . . . . . . . . . . . _ . .. . . _ .
. , . . . . . . . . 60
Chapter 7: Searching for illicit Discharge Problems in the Field ........................
63
7.1
Overview of Searching for Illicit Discharge Problems in the Field . . . . . . . . .
. . . . . . . . . . 64
7.2
The Out -fall Reconnaissance Inventory (ORI) . . . . . . . . . . . . . . . .
. . . . . . . . . . 64
7.3
Interpreting ORI Data .. . .. ...... . .. ... . . . .. ... ... . ..
. .. ..... .. 65
lilicit Discharge Detection and Elimination: A Guidance Manual v

Table of Contents
Table of Contents
Foreword ........ ,............................................. i
Acknowledgments ...... . . . ............ ............................. iii
Liss of Tables.... . ........ ....... ... , . .... .......... . .. . . ........ AN
List of Figures . . . . . .. . . . . . . .. .............. .. . . . . . . .. . . . . . . . .. , . . . , ix
Introduction......................................................1
Chapter 1: The Basics of Illicit Discharges ........ . ........................... 5
1.1
Important Terminology and Key Concepts . . . . . . . , , . . , . .. . . . . .
.. . . . . , .. . 5
1.2
The Importance of Illicit Discharges in Urban Water Quality . , , . , .. . ...
, . . , . . . . . 15
1.3
Regulatory Background For Illicit Discharges . . . . . . . . . . . , . . . . . . ..
. . . . . . . . 16
1.4
Experience Gained in Phase I. , . . . .. . . . . . . . . . . . . . . .. . . . . . .
. . . . . . . . . . 19
Chapter 2: Components of an Effective IDDE Program ...... . ............... . ...... 23
2.1
Management Tips to Develop an Effective IDDE Program . . . . . . . . . . .
. . . . . . . . . 25
Chapter 3: Auditing Existing Resources and Programs ............................ , 29
3.1
Audit Overview . . . . . . . .. . . . . . . .. . . . . . . . _ _
_ - _ . 30
3.2
Develop infrastructure Profile . . . . .. . , . . . . . . .. , . . . . . . . . . . .
. . . . .. .. . . 32
3.3
Establish Legal Authority . . , . . . . . , , . . . . . . . , , . . , . . . .
. . - - - 32
3.4
Review Avaliable Mapping . . . . . . . . . . . . . . . . . .
. . , . . . .. . . 33
3.5
Availability of Feld Staff . . .. . . . . . . . . . . . . . . .
33
3.6
Access to Laboratory Analysis .. .......... . . ...... . . .... -
- ... ... . 34
3,7
Education and Outreach .. . . . ..... .. .. . . . . . .. . .. ... ... .
. ... . - - . 34
3.8
Discharge Removal Capability and Tracking . . . . . . . . . . . . . . . .. . . .
. . . . . . . . . . 35
3.9
Program Funding .. . . . .... ........ .. . . . . .. .... .. .... ......
. .. . - 35
3.10
The Initial IDDE Program Plan .......... .. . . . . .. ...... .. .. ..
. .... . . . . 38
Chapter 4: Establishing Responsibility and Legal Authority . ........ ..... . ...... . .. . . 39
4.1
Identify Responsible Department/Agency . . . . . . .
44
4.2
Develop Local Illicit Discharge Ordinance . . . . . , . . . . . . .
. . . . . . . . . . 40
Chapter 5: Desktop Assessment of Illicit Discharge Potential . ........................
45
5.1
Overview of Desktop Assessment of Illicit Discharge Potential . . . . . . . . .
. . . . . . . . . 46
Chapter 6: Developing Program Goals and Implementation Strategies . .............. .. .. 57
6.1
Overview of Goals and Strategies Development . . . . . ... . ... . ....
... ... . , , 58
6.2
Develop Initial Program Goals .......... . . ....... ...........
.... .. .. 58
6.3
Crafting Implementation Strategies .. .. . .... . .. ... . . ................
. . 60
Chapter 7: Searching for Illicit Discharge Problems in the Field .... ... ..... . ..... . . . .. . 53
7.1
Overview of Searching for Illicit Discharge Problems in the Field .. ... - -
64
7.2
The Ouffall Reconnalssance Inventory (ORI) . . . . . . . . . . . . . . . .. . . .
. . , , , , . . 64
7.3
Interpreting ORI Data ..... ....... . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . 65
Nkcit Discharge Detection and Elimination: A Guidance Mama! v

Tabie of Contents
7.4 Design and Implementation of an Indicator Monitoring Strategy . . . . . . . . . . . . . . . . . 66
7.5 Field and Lab Safety Considerations. . . . . . .. . . , . , . . . . . . . . . . . . . . . . . . . . 68
Chapter 8: Isolating and Fixing Individual Illicit Discharges - - - - - - - - - - -- - - - - - - - - - - -- - - 49
8.1 Overview of Isolating and Fixing Individual Illicit Discharges , , . , , , . . . . .. .. .. .. . . 70
8.2 Isolating Illicit Discharges . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . 70
8.3 Fixing illicit Discharges. . . . . . . . . . . . . _ . _ _ . . . . . . . . . . . . . . . . . . . . . . , 73
Chapter 9: Preventing illicit Discharges ......... . ....... . .. .... . . ..... . ..... 75
9.1 Overview of Preventing Illicit Discharges . .. ... . . . . . . . . . . . . . . . . . . . . . . . . . . 76
9,2 Methods to Identify Opportunities for Illicit Discharge Prevention . . . . . . . . . . . . . . . . . . 76
9.3 Preventing Illicit Discharges from Neighborhoods .... . ... . . . . . .. .. .. .. ... .. . 76
9A Preventing Illicit Discharges from Generating Sites . ....... . .. . ... . . .. .. . . . . 80
9.5 Preventing Illicit Discharges from Municipal Operations . . ... . . ..... .. .. .. ... .. . 83
9.6 Budgeting and Scoping Pollution Prevention . ....... .. . . .. . . .. .... .. .. . .. . 86
Chapter 10: IDDE Program Tracking and Evaluation . . .. .... ........ . . ...... .... .. 87
10,1 Overview of Program Evaluation . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 88
10.2 Evaluate the Program . ... . ... .. .... .. .. . . . .. . . .. . . . . . .. . . .. . .. . 88
Chapter 11: The Outfall Reconnaissance Inventory (ORt) ............... ... ......... 91
11.1 Getting Started . ....... . ......... .. .. .. . ... ..... .. . ... .. .. . .. . 91
11.2 Desktop Analysis to Support the ORI . . . . .. .. . . . . . . . . . . . .. . . . . . . . . . . . . . . 94
11.3 Completing the ORI ... .. ............... . . .. . ............. .. , . .96
11.4 ORI Section 1- Background Data ...... ........... ... . ... .. . .... . . . .. . 98
11.5 ORI Section 2- Outfa0 Description .... . ..... ...... ... . . . .... . .. . . . . . . 99
11.6 ORI Section 3- Quantitative Characterization for Flawing Outfalls . . . . . . . . . .. . . . . . . 101
11.7 ORI Section 4- Physical Indicators for Flowing Outfalls Only . . . . . . . . . . . . . . , . , 103
11.8 ORI Sheet Section 5- Physical Indicators for Both Flowing and Non -Flowing Outfalls. , , . . . . 107
11.9 ORI Section 6-8 Initial Outfall Designation and Actions ... .. ........ ..... . . . . 109
11.10 Customizing the ORI for Your Community . . . .. . . . . . . . . . . . . . .. . . . . . . . . . . . .110
11.11 Interpreting ORI Data . . . . . . . . . . . . . . . . . . . . . . . . , . . , . . . _ . . . . . . . . . .112
11.12 Budgeting and Scoping the ORI . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .136
Chapter 12: Indicator Monitoring .........................................
119
12.1
Indicator Parameters to ldentify Illicit Discharges .. ... ... ...... , ... .. .... ...
.121
12.2
Sample Collection Considerations .... ............ ...... , ............
122
12.3
Methods to Analyze Indicator Samples . .. . . .... ... . ... ... . ... .. .. . . ...
124
12.4
Techniques to Interpret Indicator Data . ...... .... .. .... .. . ..... .. . . ...
130
12.5
The Chemical Library .... .............. . .... ...... , ....... .. ...
136
12.6
Special Monitoring Techniques for Intermittent or Transitory Discharges. , . . . . , . . . . . . .
138
12.7
Monitoring of Stream Quality During Dry Weather . ...... . ..... . . . . . . . . . . . ..
.141
12.8
The Costs of Indicator Monitoring . . . .. . . . . .. . . . ... . . .. .. . . . . . .. . . . . . .
144
Chapter 13: Tracking Discharges to A Source . . . ................. ......... . . ... 147
13.1 Storm Drain Network Investigations . . . . . . . .. . . . . . . . . . . . . . , . . . . . . . . . . . .147
13,2 Drainage Area Investigations . . .. . . ... . . .... .. . . ... . . . . . . ..... ... .. 158
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Table of Contents
13.3 On -site InvestlgatOns . . . . . , . . . . . . . . . . . . . . 159
13A Septic System Investigations . . . . . . . . . . . . . . . . . . . . . . . 165
115 The Cast to Trace discharge Sources . . . . . . . . . . . . . . . . . . .170
Chapter 14: Techniques to Fix Discharges . . . . .. .............................. 173
14.1 Implementation Considerations . . . . . . . , . . . . , . , , , , . , .173
References . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . .. . .. . . R-1
Appendix A: Generating Sites, Storm Water Regulatory Status, and Discharge Potential. . . . . . . . . . A-1
Appendix B: Model Illicit Discharge and Connection Ordinance. . . B-1
Appendix C: Six Steps to Establishing a Hotline and Reporting and Tracking System. . C-1
Appendix D. Outiail Reconnaissance Inventory Field Sheet. . . . . . . . . . . . . . . . . . D-1
Appendix E: Flow Type Data From Tuscalooso and Birmingham. . . . . . . . . . . . . . . _ . . . . _ . . . E-1
Appendix F: Laboratory Analytical Procedures for Outtall Monitoring . . . . . . . . . . . F-1
Appendix G: Sampling Protocol Considerations .. . . ..... .. ... . . . . . . ..... . .. .. . .G-1
Appendix H: Two Alternative Flow Charts . . . _ _ _ . _ . . . . . . . . H-1
Appendix I: User's Guide for the Chemical Mass Balance Model (CMBM) Version 1.0 . 1-1
Appendix J. Using the Chemical Library to Determine the Utility of Boron as an Indicator
of Illicit Discharges. . .. . . . . . . . .. . . . .. . . . . . . . . . . . . . . . . . . . . J-1
Appendix K: Specific Considerations for Industrial Sources of Inappropriate Pollutant
Entries to the Storm Drainage System . . . . .. . . . . . . . . . . . . . . K-1
Illicit Discharge Detection and Elimination: A Guidance Manual Vli

Table of Contents
List of Tables
1. Comparative `Fingerprint" of Flow Types . . . . . . . .. . . . . . . . . . . . . . . . . . .
, . . . . . . .8
2. Land Uses, Generating Sites and Activities That Produce Indirect Discharges . . . . . .
. . . . . . . . 12
3, Linking Other Municipal Programs to IDDE Program Needs .. ...... .... . . . ....
.... .. 21
4. Key Tasks and Products in IDDE Program Implementation . . . . . . . . . . . . . . . . .
. . . . . . . . . 24
5. Comparison of IDDE Components - . . . . . . . . .. . . . . . . . .
. . . . . . . . 25
6, Potential Local Agencies and Departments to Contact During an Audit . . . . .
, . . . , . . . 30
7. Potential IDDE Audit Quesfions. ... . .. . . . . . . . .. , . . . . . . . . . .
. . . . . . . . 31
8. Codes and Ordinances with Potential Links to IDDE. . . . . . . . .. . . . . . .. .
. . . . - . . . 33
9. Summary of Annual Phase I IDDE Program Costs , . . . . . . . . . . . . . . . . . . .
. . . . . . . . 36
10. Average Correction Costs, .. , . , , . . . . , . . . . . . . . , , . .... . . . .
, . . , . . 36
11. IDDE Program Costs .. . . . . . . . . . . . . . . . . . . ... . .. .. . .. . .
. . . .. . . . . 37
12. Summary of IDDE-Related Enforcement Tools . . . . . . . . . .. .. . . . .. . . . . .
. . . . . . . . 44
13. Useful Data for the Desktop Assessment. . . , , , . . . . . , . .. , . . . _ . . . . .
_ . .. . . 48
14. Defining Discharge Screening Factors in a Community . . . . . . . . .. . . . . , . , .
. . , . . , . . . 50
15. Prioritizing Subwatershed Using IDP Screening Factors ....... . ........ . ..
..... . 53
16. Community -wide Rating of Illicit Discharge Potential . . . . . . . . . . . . . . , , . . .
. . . . , . . , 54
17, Measurable Goals for an IDDE Program . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . 60
18. Linking Implementation Strategies to Community -wide IDP ... . .. . . .. . . . . ..
. . . . .. . . 61
19. Customizing Strategies for Unique Subwatershed Screening Factors . .. .. . . ... .
. . . .. . . . . 62
20. Field Screening for an IDDE Program ..... .. . . . .. . ... ......... , .
, . . , . .. . . 65
21. Field Data Analysis for an IDDE Program . .. . . .. .... . ... . ...
66
22. Indicator Monitoring Considerations. . . , . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . 66
23. Benefits and Challenges of a Complaint Hotline . . ... ... ...... . ... . . . .
. . ... . . . . 70
24. Steps to Creating and Maintaining Successful IDDE Hotline . . . . . . . . . . . . .
. . . . . . . . 71
25. IDDE Complaint Hotline Costs , .. . , . . . , , . . . . . . , . . . . . . .. . . . . . .
. . . . , , . . . 71
26. Methods to Fix Illicit Discharges .. . ......... ......... . ..... . .. . .
, . ..... . . 74
27. Common Discharges Produced at Generating Sites ... .......... ... .. . ...
.... , . . 81
28. Summary of Local Household Hazardous Waste Collection Programs , . , ..... .
. . . . . . . . . 85
29. Estimated Costs for Public Awareness Program Components . . . . . . .. . .. . . .
. . . . . . . . . 86
30. Resources Needed to Conduct the ORI... ... . ... .......... ...... ...
..... . . 92
31. Climote/Weather Conditions for Starting the ORI . ......... .. . . . .. . .. .
.. .. .. . . . 92
32. Outfaiis to Include in the Screening ... _ - .. _ _
_ _ - _ - . 96
33. Special Considerations for Open Channels/Submerged Outfalls . . . . . . . . . . . .
. . . . . . ...111
34. Outfoll Designation System Using ORI Data . . . . . . . . . . . . . . . . . . . . . . . . .
. . .115
35. An Example of ORI Data Being Used to Compare Across Subwatersheds . . . . .
. . . . . . .115
36, using Stream and OR] Data to Categorize IDDE Problems . . . . . . . . . . . . . . .
. . . . . . . . .115
37, Typical Field Equipment Costs for the ORI ..... ...... .... .. .. ... .. . .
. . .. .. .. .116
38. Example ORI Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . .117
39. Indicator Parameters Used to Detect illicit Discharges. .. . . . . . . . , , . . . . . .
. . . .. . . . 122
40. Equipment Needed for Sample Collection . . . . . . . . . . .. . . . . . . . . . . . .
. . . . . . 123
41. Basic Lob Supplies . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . 126
42. Analytical Methods Supplies Needed . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . 127
43. Chemical Analysis Costs . . . .. .. .. . , . . . . . . . . . . . . . . . , , . . , . . .
. . . . . . , , 128
44. Typical Per Sample Contract Lab Costs . . . , . . . . . . , . . . . . . . . . . . . . . . .
_ . . . . . , 130
45. Benchmark Concentrations to Identify Industrial Discharges . . . . . . . . . . . . . .
. . . . . . . . 134
46. Usefulness of Various Parameters to identify industrial Discharges . . . . . . . . . . .
. . . . . . . . 135
47, Where and How to Sample for Chemical "Fingerprint" Library . . ,
, . . . . . . .137
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48. Evaluation of the Flow Chart Method Using Data from Birmingham, Alabama . . . . . _ . . .. . .
139
49. Follow -Up Monitoring for Transitory Discharges .. . . . . . . . . . . . . . . . . . . . . . . . . . . .
142
50, Typical "Full Body Contact Recreation" Standards for E. coil . . . . . . . . . . . . . . . . . . . . . . .
143
51. Example In -Stream Nutrient Indicators of Discharges . . . . . . . . . . . . . . . . . . . . . . . ,
143
52. Indicator Monitoring Costs; Two Scenarios .. . .. . . , . . . . . . . . . . . . . . . . . . . . . .
145
53, Methods to Attack the Storm Drain Network . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . .
148
54. Basic Field Equipment Checklist . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
152
55. Field Procedure for Removal of Manhole Covers ... . . . ... . ..... .. ... . .. . ....
153
56. Techniques to Locate the Discharge . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . .
160
57, Key Field Equipment for Dye Testing . . . . . . . . . . . . . . . . .. . . . .. . . . . . . . . .
.161
58. Dye Testing Options ...... ... ... , ....... , , , ... , .. .. ..
162
59. Tips for Successful Dye Testing . . . .. .. . . . . . . . . . . . . , . . . . . _ .
163
60. Septic System Homeowner Survey Questions . . . . . . . . . . . . . . . . . . . . . . . ...
.167
61, Common Field Equipment Needed for Dye, Video, and Smoke Testing . . . . . . . . . . . . . . . . .
.170
62. Equipment Costs for Dye Testing . . . . . . . . . . . . . . . . . . . . . . ... . . . . ... . . . . . . .
.171
63. Equipment Costs for Video Testing . . . . . . . . . . . . . . .... _ ...
.171
64. Equipment Costs for Smoke Testing . . . . . . . . . . . . . . . . . . . . . . . . .. , . . . . .
.171
65, Methods to Eliminate Discharges . .. . . . . .. . . ........ . . .. . .. .. . . .. . ......175
List of Figures
1. Sewer Pipe Discharging to the Storm Drain System . . . . . . . . . . . . . . . . . 7
2. Direct Discharge from aStraight Pipe. , , , , , , , , , , , , , . , , , . , . . , . .
, . , . . . .8
3, A Common Industrial Cross Connection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . 9
4, Accident Spills Are Significant Sources of Illicit Discharges. . , . . . . . . . . . . . . .
. . . . . 9
5. Dumping at a Storm Drain Inlet . . . . . . . . . . . . . . . . . . . . , . , . , . . . . , .
. , , . . . 10
6. Routine Outdoor Washing and Rinsing Can Cause Illicit Discharges . . . . . . . . . . . . .
. . . . . . 10
7, Non -Target Landscaping Irrigation Water . . . . . . . . . . . . . . . .. . . . . . . . . . . .
. . . . . . 10
8. GIS Layers of Outfolls in a Subwatershed . . . . . . . . . . . . . . . . . . . . . . . .. . . . . .
. . . . . . 49
9. Communities With Minimal (a), Clustered (b), and Severe (c) Illicit Discharge Problems . , ,
. . . . , , 55
10, Measuring an Outfall as Part of the ORI . .. . ... .. . . . . . . . . .. . . ... . . . ..
.... .. 64
11. Some Discharges Are Immediately Obvious .......... . .. . .... ... ..... ......
. 64
12, IDDE Monitoring Framework . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . 67
13. Process for Removing or Correcting an Illicit Dischagge . . . . . . . , . . , . . , . . . . . .
, . , . . , 74
14. Storm Drain Stenciling May Help Reduce illicit Discharges.. . . . . .
. . . . . . 77
15. Home Mechanic Changing His Automotive Fluids, . . .. . . . . .. . . . . . . . . . .. . .
. . . . . . 78
16. Household Hazardous Wastes Should be Properly Contained to Avoid Indirect Discharges
.. . . . , 79
17, Swimming Pools Can Be a Source of Illicit Discharges .. . . . . . . . . . . . . . . . . . . . . .
. . . .. . 80
18. Spill response Often Involves Portable Booms and Pumps . ........ ...... ... .
. . . . . . 82
19. Walk All Streams and Constructed Open Channels . . . . . . . . . . . . . . . . . . .
. . . . . . 91
20. Example of a Comprehensive Emergency Contact List for Montgomery County, MD . . .
. . . . . . 94
21. Survey Reach Delineation. . . . . . . . . .. . ... .. . .. . . . . . . . . . . . .. . . . . .
. . . . . , 95
22. Typical Outfall Types Found in the Field . . . . . . . . . . . . . . . . . .
. 97
23. Section 1 of the ORI Field Sheet . . . . . . . . . . . . . . . . . . . . . . . . . . . , . , , ,
. , . , . , 98
24. A Variety of Outfall Taming Conventions Can Be Used . . . . . . . . . . . . . . . . . . . .
. . . . . . 99
25. Corrugated Plastic Pipe . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . 99
26. Section 2 of the OR] Field Sheet . . . . . , . . . , , . . . . . . . . . . . .
. . . . . 100
27. Measuring Outfoll Diameter . . . . . . . . . . . . . . . . . . . . . . . . , , , ,
, . , , . 100
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Table of Contents
28. Characterizing Submersion and Flow . . . . . . . . . . . . . . . . . . . . . . . .. . .. , . ..
101
29, Section 3 of the ORI Field Sheet . . . , . . . . . . . , . . . . . . . . . . . . . . . . . . . . .. . . ,
102
30. Measuring Flow (as volume per time) . . . .. .. . . . . . . . . . . . . . . . . . . . . . . . . . . . .
102
31. Measuring Flow (as velocity times cross -sectional area) . . . . . . . . . . . .. . . . . . . . . . . . .
103
32. Section 4 of the ORI Field Sheet . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
103
33. Using a Sample Bottle to Estimate Color and Turbidity . . _ . . . - _ . . . .
104
34. interpreting Color and Turbidity . . . . . . . . .. . . . . . .. . , . , , , . . , . , . , , , , , . . ,
105
35. Determining the Severity of Flootables .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
106
36, Synthetic Versus Natural Sheen .. . .. . ... . ...... .. ... ... . . . , ... ... .. ....
107
37. Section 5 of the ORI Field Sheet. . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . .
107
38. Interpreting Benthic and Other Biotic Indicators . . . .. . . .. . . . . . . .. . . . . . .. . . . . . .
108
39. Typical Findings at Both Flowing and Nan -Flowing Outfalls .. .... .. .... .... .... ....
109
40. Sections 6-8 of the ORI Field Sheet . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .... . .
.110
4). Cold Climate Indicators at Illicit Discharges . . . . . . . . . . . . . . . . . . . . . . . . .... , . , . ,
.112
42, One Nological Indicator is this Red -Eared Slider Turtle , , , , , , , , , , , , , .. .... , . . , .
.112
43. Sample Screen from ORI Microsoft Access Database . . . . . . . . . . . . ... . . , . . . . .. . ..
.114
44. iDDE Monitoring Framework . ................. ..... ..................
.119
45. Analyzing Samples in the Back of a Truck . . . . . . . . . . . . . . . . . .. . . . . . . . .. . . .
126
46. Otfice/Lab Set-up . . . . . . . . . . . . . .. . . . . . . . . .. . . . . . . . . .. . . . . . ... . . . .
126
47. Flow Chart to Identify Illicit Discharges in Residential Watersheds .. . . . ... ........ ... .
.131
48.OBM Trap That Can Be Placed at an Outfall ............. . . ... .... , .... .. ..
140
49. Stream Sentinel Station , I , . I I . I . . , . . . I I , . I . I . . .. , . . . . . . . . . .
.141
50. Example Investigation Following the Source Up the Storm Drain System . . . . . . . . . . . . . . .
148
51. Key Initial Sampling Points Along the Trunk of the Storm Drain ...... .... .... I .......
150
52. Storm Drain Schematic Identifying 'Juncture Manholes" . . . . . . , . . . . , . . . . .
.151
53. A Process For Following Discharges Down the Pipe . . . . . . . . . . . . . . . . , - . . . , , . ,
.151
54. Traffic Cones Divert Traffic From Manhole inspection Area. . . . . . . . . . . . . . . . . . . .
152
55. Manhole Observation and Source Identification ......... ... .......... .... ....
153
56. Techniques to Sample from the Storm Drain . . . . . . . . . . . . . . . . . ... . . , . . . . . . . .
154
57. Use of Ammonia as a Trace Parameter To Identify an illicit Discharge, , , , , , , , , , , , , , , , ,
155
58. Boston Water and Sewer Commission Manhole Inspection Log . . . . . . . . . . .. . . . . . . . .
156
59. Example Sandbag Placement . . . . . . . .. . . . . . .. . . . , , . .. . , . . . . , .
157
60. Optical Brightener Placement in the Storm Drain . . , . .. . . , . . . . , . , .. . , . , . . ,
168
61, Symptom and Diagnosis .. . . . . .... . . . . . .. . . .. i . , ... , . , . , ... I .. , .... .
159
62, Laundromat Discharge . . . . , . , . . . , , ...... ... . ... . ..... . .. . . . . . . . . .
159
63. Dye Testing Plumbing . . . . . . . . . . . . . . . . , . .. . , . . . . . . . . .. . . . . . ... . . . . .
160
64. Dye Testing In a Manhole... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
.161
65. Camera Being Towed . . . . , , . , , . . . . . . . . . . . . . . . . . . . . . .. . .
164
66. Tractor -Mounted Camera ... ...... . . ..... ....... .. . . .... ... .... .... .
164
67. Review of an Inspection Video .. . .. . . .. . . . ... . . . . . .. .. . . . . . . . , . . . .
164
68. Smoke Testing System Schematic . , . , . ... ... . . ,
165
69. Smoke Candles . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . ..
165
70. Smoke Blower .... ...... .. .. . . . . . . . . .... . . .. . . . . . . .. .. . . . . . . . . .
166
71, Surface Indicators , . . . . . . . . , . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
168
72. Aerial Thermography Showing Sewage Leak . . , . . . . .. . . . . . . . . . . . . . . . . . . . . . . .
169
73, Dead Vegetation and Surface Effluent are Evidence of a Septic System Surface Failure. . , . . . .
169
x Illicit Discharge Detection and Elimination: A Guidance Manual

Introduction
Introduction
An up-to-date and comprehensive manual
on techniques to detect and correct
discharges in municipal storm drains has
been unavailable until now. This has been
a major obstacle for both Phase I and Phase
II National Pollutant Discharge Elimination
System (NPDES) municipal separate storm
sewer system (MS4) communities that
must have programs in place that detect,
eliminate, and prevent illicit discharges to
the storm drain system. Smaller Phase iI
communities, In particular, need simple
but effective program guidance to comply
with permits issued by the Environmental
Protection Agency (EPA) and states.
This manual provides communities with
guidance on establishing and implementing
an effective illicit Discharge Detection and
Elimination (IDDE) program.
Studies have shown that dry weather
flows from the storm drain system may
contribute a larger annual discharge mass
for some pollutants than wet weather storm
water flows (EPA, 1983 and Duke, 1997).
Detecting and eliminating these illicit
discharges involves complex detective work,
which makes it hard to establish a rigid
prescription to "hunt down' and correct all
illicit connections. Frequently, there is no
single approach to take, but rather a variety
of ways to get from detection to elimination.
Local knowledge and available resources can
play significant roles in determining which
path to take. At the very least, communities
need to systematically understand and
characterize their stream, conveyance, and
storm sewer infrastructure systems. When
illicit discharges are identified, they need
to be removed. The process is ongoing
and the effectiveness of a program should
improve with time_ In fact, well -coordinated
IDDE programs can benefit from and
contribute to other community -wide water
resources -based programs, such as public
education, storm water management, stream
restoration, and pollution prevention.
This manual incorporates the expenience
of more than 20 Phase I communities that
were surveyed about their practices, levels
of program effort, and lessons learned
(CWP, 2002)_ These communities took
many different approaches to solve the
IDDE problem, and provided great insights
on common obstacles, setting realistic
expectations and getting a hard _job done
right. Many of the IDDE methods presented
in this manual were first developed and
tested in many Phase I communities_
Specific techniques applied in a community
should be adapted to local conditions, such
as dominant discharge types, land use, and
generating sites.
Designed with a broad audience in mind,
including agency heads, program managers,
field technicians and water quality
analysts, this manual is primarily focused
on providing the thousands of Phase ii
communities that are now in the process of
developing IDDE programs with guidance
far the development and implementation of
their own programs. The manual has been
organized to address the broad range of
administrative and technical considerations
involved with setting up an effective IDDE
program. The first 10 chapters of the Manual
focus on "big picture" considerations needed
to successfully get an IDDE program off
Illicit Discharge Detection and Elimination' A Guidance Manual

Introduction
the ground. The final four chapters provide
detailed technical information on the
methods to screen, characterize and remove
illicit discharges in MS4 communities.
These chapters present the state -of -the -
practice on specific monitoring techniques
and protocols.
fn general, the content of this manual gets
progressively more complex and technical
toward the end_ The basic organization
of the manual is outlined below. The
information is provided to help_
■ Define important terminology and
understand key illicit discharge concepts
• Conduct an audit to understand
community needs and capabilities
• Establish adequate legal authority
• Develop a tracking system to map
outfalls and document reported illicit
discharges
• Conduct desktop analyses to prioritize
targets for illicit discharge control
• Conduct rapid reconnaissance of the
stream corridor to find problem outfalls
• Apply new analytical and field methods
to find and fix illicit discharges
• Educate municipal employees and the
public to prevent discharges
• Esti mate costs to run a program and
conduct specific investigations
Chapter 1. The Basics of 11licit Discharges —
The many different sources and generating
sites that can produce illicit discharges are
described in Chapter 1. The chapter also
outlines key concepts and terminology
Chapter 2. Components of an Effective
Illicit Discharge Program —This chapter
presents an overall framework to build
an IDDE program, by outlining eight key
components of good programs. Each of the
following eight chapters is dedicated to a key
program component. The first page of the
program component chapters is notated with
a puzzle icon labeled with the applicable
program component number.
Chapter 3. Audit Existing Resources and
Programs— This chapter provides guidance
on evaluating existing resources, regulations,
and ongoing activities in your community to
better address illicit discharges.
Chapter 4. Establish Responsibility,
Authority and Tracking— This chapter
presents guidance on how to identify the
local agency who will be responsible for
administering the 1DDE program, and
how to establish the legal authority to
control illicit discharges by adapting an
existing ordinance or adopting a new one.
The chapter also describes how to set
up a program tracking system needed to
document discharges and local actions to
respond to them.
Chapter S. Desktop Assessment of
Illicit Discharge Potential- The fifth
chapter describes desktop analyses
to process available mapping data to
quickly characterize and screen illicit
discharge problems at the community and
subwatershed scale. Key factors include
water quality, land use, development age,
sewer infrastructure and outfall density.
Rapid screening techniques are presented
to define where to begin searching for illicit
discharge problems in your community.
needed to understand illicit discharges, why
they cause water quality problems and the Chapter 6. Developing Program
regulatory context for managing them. Goals and Implementation Strategies-
2 illicit Discharge Detection and Elimination; A Guidance Monual

Introduction
Communities are required to establish
and track measurable goals for their IDDE
program under the NPDES MSS} permit
program. This chapter recommends a series
of potential program goals that can guide
local efforts, as well as guidance on how
to measure and track progress toward their
achievement.
Chapter 7. Searching for Illicit Discharge
Problems in the Field-- This chapter
briefly summarizes the major monitoring
techniques to find illicit discharges, and
discusses how to select the right combination
of monitoring methods to incorporate into
your local program.
Chapter 8. Isolating and Fixing
Individual Illicit Discharges— The methods
used to find and remove illicit discharges are
briefly described in this chapter and include
citizen hotlines and techniques to trace,
locate and remove illicit discharge sources.
Chapter 9. Preventing Illicit Discharges —
Prevention is a cost effective way to reduce
pollution from illicit discharge. This chapter
highlights a series of carrot and stick
strategies to prevent illicit discharges.
Chapter 10. IDDE Program Evaluation —
IDDE programs must continually evolve
to changing local conditions. This chapter
describes how to review and revisit program
goals to determine if they are being met and
to make any needed adjustments.
Chapter 11. The Outfall Reconnaissance
Inventory (OR[)— The chapter presents
detailed protocols to conduct rapid field
screening of problem outfalls. The chapter
also outlines the staff and equipment costs
needed to conduct an QRI, and presents
methods to organize, manage and interpret
the data you collect_
Chapter 12. Chemical Monitoring— This
chapter presents detailed guidance on
the wide range of chemical monitoring
options that can be used to identify the
composition of illicit discharge paws. The
chapter begins by describing different
chemical indicators that have been used
to identify illicit discharges, and presents
guidance on how to collect samples for
analysis. The chapter recommends a flow
chart approach that utilizes four chemical
indicators to distinguish the flow type. The
chapter provides specific information on
other analytical methods that can be used, as
well as proper safety, handling, and disposal
procedures. Simple and more sophisticated
methods for interpreting monitoring data
are discussed, along with comparative cost
information.
Chapter 13. Tracking Discharges to Their
Source— This chapter describes how to
investigate storm drain systems to narrow
and remove individual illicit discharges.
These techniques include "trunk"
investigations (e.g., video surveillance,
damming, and infiltration and inflow
studies) and on -site investigations (e_g., dye
tests, smoke tests, and pollution prevention
surveys). The pros and cons of each
investigation technique are discussed, and
comparative cost estimates are given.
Chapter 14. Techniques to Fix
Discharges-- This chapter provides tips
on the best methods to repair or eliminate
discharges_ Specific advice is presented on
how to identify responsible parties, develop
pre -approved subcontractor lists, and
estimate unit costs for typical repairs.
Appendices-- Eleven technical appendices
are provided at the end of the manual.
Illicit Discharge Detection? and Elimination A Guidance Manual 3

For a complete copy of this manual, refer to the electronic copy.

Tab 5

Illicit Discharge Detection and Tracking Guide
Table of Contents
Introduction to Illicit Discharge Detection and Elimination ......
Definitions,....................................................................
Federal requirements ...........................
Illicit Discharge Detection and Tracking Procedures ..............................
Overview ................................................
..............p. 2
........................................ p. 2
.......................................................p. 4
....................................p. 6
Desktop assessment of illicit discharge potential...............................................................................p. 6
Fieldscreening of outfalls....................................................................................................................p. 10
Non -routine inspections...... ................................................................... . .. ... ..................................... p. 17
Drainage Area and Storm Drain Investigations.................................................................................P. 18
Post -Removal Confirmation.................................................................................................................p. 21
SafetyProcedures.................................................................................................................................p. 22
ReferencesCited.............................................................................................. ....................................p. 24
ATTACHM ENT A: OR[ Form .................................... ............................................................................................ p.25
ATTACHMENT B: Mapping the System.............................................................................................................p. 27
ATTACHMENT C: 0utfaII Reconnaissance Inventory/ Sample Collection Lab Sheet.................................p. 29
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Illicit Discharge Detection and Tracking Guide
Introduction to Illicit Discharge Detection & Elimination (IDDE)
An illicit discharge is "Any discharge to a municipal separate storm sewer that is not composed entirely
of storm water, except discharges pursuant to a National Pollutant Discharge Elimination System
(NPDES) permit and discharges resulting from fire -fighting activities." (NOTE: there are several types of
NPDES permits and their intent is to authorize discharges provided perm€t requirements, such as
effluent limits, are being met.)
These are two categories of illicit discharges, as follows:
■ TRANSIENT— Short in duration, lasting only a short time and then disappearing,
o Examples of Direct transient illicit discharges include:
■ A straight pipe from an unpermitted industrial facility that discharges wastewater or
process water, and
■ A floor drain that is connected to the storm sewer.
o Examples of Indirect transient illicit discharges include:
■ Materials that have been dumped into a storm drain inset or catch basin (Figure 1),
• An old or damaged sanitary sewer line that is leaking fluids into groundwater that
then seeps into a storm sewer line or drainage way, and
■ A failing septic system that is leaking into a cracked storm sewer line.
• CONTINL)0US — Continuing without changing, stopping, or being interrupted. Examples
include:
0 5anitary wastewater piping that is cross -connecter! from a building or sanitary sewer
line to the storm sewer,
❑ A broken sanitary line (figure 2), and
o An industrial operational discharge that doesn't meet permit requirements.
Illicit discharges are considered "illicit" because storm sewer systems, unlike sanitary sewer systems, are
not designed to accept, treat, or discharge non -storm water wastes.
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Illicit Discharge Detection and Tracking Guide
Figure 1. Indirect, transient discharge: concrete slurry discharges from storm drain outfall to stream.
Figure 2. Direct, continuous discharge: broken sanitary line.
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Illicit Discharge Detection and Tracking Guide
Federal requirements
Established in 1972 and amended in 1977 and 1987, the Clean Water Act (CWA) is the primary federal
law governing water pollution. The Act requires states to set clean water standards to protect uses such
as swimming, fishing, and drinking, and for the regulation of pollution discharges. The CWA initially
focused on addressing water quality issues caused by point sources of pollution (e.g., wastewater
treatment plants and industry) by making it unlawful to discharge any pollutant into navigable waters,
unless a permit was obtained under its provisions. These permits, known as National Pollutant
Discharge Elimination System (NPDES) permits, prevent the degradation of water quality by limiting
pollution discharges to what can be safely assimilated by the environment. I 1987, the CWA was
expanded to include non -point sources of urban poIIutian by requiring municipalities with separate
storm sewer systems (referred to as "MS4s") to be permitted. Phase I of these permits, issuer! in 1990,
requires medium and large cities or certain counties with populations of 100,000 or more to obtain
NPDES permit coverage for their stormwater discharges. Phase 11, issued in 1999, requires regulated
small MS4s in urban zed areas, as well as small MS4s outside the urbanized areas that are designated by
the permitting authority, to obtain NPDES permit coverage for their storm water discharges. Generally,
Phase I MS4s are covered by individual permits and Phase Ii MS4s are covered by a general permit. Each
regulated MS4 is required to develop and implement a stormwater management program to reduce the
contamination of stormwater runoff and prohibit illicit discharges.
What is required?
Recognizing the adverse effects illicit discharges can have on receiving waters, the Phase 11 Final Rule
requires an Operator of a regulated small M54 to develop, implement and enforce an illicit discharge
detection and elimination (IDDE) program, which is one of six minimum measures required under the
Phase II stormwater program. The IDDE program must include the following:
• A storm sewer system map, showing the location of all outfalls and the names and location
of all waters of the United States that receive discharges from those outfalls;
■ Through an ordinance, or other regulatory mechanism, a prohibition (to the extent
allowable under State, Tribal, or local law) on illicit discharges into the MS4, and appropriate
enforcement procedures and actions;
• A plan to detect and address illicit discharges, including illegal damping, into the MS4;
■ The education of public employees, businesses, and the general public about the hazards
associated with illegal discharges and improper disposal of waste; and
■ The determination of appropriate best management practices (BMPs) and measurable goals
for this minimum control measure.
This document provides guidance on procedures for detecting and tracking illicit discharges through a
desktop assessment of illicit discharge potential, field screening of outfalls to detect illicit discharges and
drainage area investigations to locate and remove the source of the discharge.
For more information...
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Illicit discharge Detection and Tracking Guide
EPA's Best Management Practices (BMPs) and Resources for iDDE;
littp:/lcfaub.epa.gov/npdeslstormwaterlmenuofbmpslindex.cfm?action=rein measure&rnin
maarim- id='A
■ Brown, E., Caraco, D., and Pitt, R. 2004. Illicit Discharge Detection and Elimination: A Guidance
Mon ual for Program Development and Technical Assessment. Center for Watershed Protection
and University of Alabama. EPA X-82907801-0.U.S. EPA Office of Wastewater Management,
Washington, D.C. Available at:
http:/Icfpub.ei)a.gov/npdes/docs.cfm?program_id _b&view=al_lprog&sort=name__#_iddemanual
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Illicit Discharge Detection and Tracking Guide
Illicit Discharge Detection and Tracking Procedures
Overview
This document outlines a common framework through which communities can develop a
comprehensive plan to identify and eliminate dry weather illicit discharges to their separate storm
sewer systems. The primary steps to identify illicit discharges and track their sources include: 1] conduct
a desktop assessment of illicit discharge potential to identify priority locations for screening, 2) conduct
field screening of outfalls in priority subwatersheds, and 3) conduct drainage area and storm drain
investigations to identify the source(s) of a I I confirmed illicit discharges. Protocols for each step are
described below. Further detail is provided in Brown et al. (2004).
Desktop assessment of illicit discharge potential
A desktop assessment of illicit discharge potential (ioP) uses mapping and other available data to
determine the potential severity of illicit discharges within a community, and identifies which
subwatersheds or generating land uses merit priority investigation. This assessment, recommended by
Brown et al_ (2004) provides insight on how to narrow your illicit discharge search, and is helpful when
designing a discharge tracking system to best suit your needs. The desktop assessment draws on existing
background data and anecdotal information to initially characterize IDP at the subwatershed level.
subwatersheds are then screened based on their composite score, and are designated as having a low,
medium or high risk:
Low — no known illicit discharge problems in the subwatershed_
Medium— problems are confined to a few stream reaches, outfalls or specific generating sites in
the subwatershed.
• High — Problems are suspected to be severe throughout the subwatershed.
The recommended scale for desktop assessments is the subwatershed or sewershed, which typically
range from two to 10 square miles in area. Next, mapping, monitoring and other data are analyzed to
identify subwatersheds with the greatest potential to contribute illicit discharges_ The analysis can
encompass up to 10 different screening factors. The desktop assessment consists of five basic Steps:
Step 1: Delineate subwatersheds —This step may already be corn pleted. If not, hydrologic,
infrastructure and topographic map layers are needed to delineate the boundaries,
Guidance on the techniques for accurately delineating subwatershed boundaries can be
found in United States Geological Survey 2009 Federal Guidelines, Requirements, and
Procedures for the National Watershed Boundary Dataset: fto,11ft1-
fc.sc.e ov.usda. av NCGC roducts 'watershed 11u-standards. df. The use of digital
elevation models (DEMs) and GIS can also make subwatershed delineation an easier and
faster, automated process.
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Illicit Discharge Detection and Tracking Guide
Step 2: Compile mapping layers and subwatershed data — This step is best accomplished with the
use of Geographic information System (GIS), If GIS is not available, consider the use of
Google Maps or other free mapping software. A list of suggested data can be found in Table
1 (from grown et al. 2004).
Table 1. Useful Data for the De5ktop Assessment of Illicit Discharge
Data
Potential
Likely Format
Aerial photos ororthophotos
Digital map
Subwatershed or catchment boundaries
Digital or hardcopy ma
Hydrology includingpiped streams
Di itaI or ha rdcopy ma
a
Land use or zoning
Digital or hardcopy ma
M
c
fu
NPDFS storm water permittees
Digital data or ma
E
Outfalls
Digital or hardcopy ma
aSewers
stem, 1" = 200' scale or better
Di itaI or ha rdwpy ma
W
Standard Industrial Classification codes for all industries
Digital or hardcapy data
Storm drains stem, 1" = 200' scale or better
Digital or hardcopy ma
Street map orequivalent GIS layers
Di ital or hardcopy ma
Topography (5 foot contours or better)
Di ital or hardcopy ma
Age of deveio ment
Narrative data
As -bunts or construction drawings
Hardcopy map
Condition of infrastructure
Narrative data
Field inspection records
Hardcopy or digital data
Depth to water table and groundwater quality
Digital data or maps
Historical industrial uses or landfills
Narrative data or hardcopy map
Known locations of illicit discharges (current and past)
Narrative data or digital map
Out -fall and stream monitoring data
Digital data
p
Parcel boundaries
Digital or hardcopy map
Pollution complaints
Narrative data
Pre -development hydrology
Narrative data or hardcopy map
Sanitary sewer Infiltration and Inflow (1/1) surveys
Hardcopy or digital data
Septic tank locations or area served by septic systems
Hardcopy or digital map
Sewer system evaluation surveys
Hardcopy or digital data
Thermal imaging data
Digital data
Step 3: Compute discharge screening factors — Potential discharge screening factors are illustrated
in Table 2.
Step 4: Screen for illicit discharge potential at the subwatershed and community level - Select the
group of screening factors that apply most to your community, and assign them a relative
weight. Next, points are assigned far each subwatershed based on defined scoring criteria
for each screening factor. The total subwatershed score for ail of the screening factors is
then used to designate whether it has a low, medium or high risk to produce illicit
discharges (Figure 3).
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illicit Discharge Detection and Tracking Guide
Lansdf la
Monlgo my Towishlp
lMr Gry 1 TdwnsMp
r
MW,j
o•• :•••T.lnn21"
•.v Run W ����
Sl ur1l ee
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lff-mw
Wissahickon Suhwatershed
Illicit Discharge Potential
CJurisdictions
IDP Rank
Law
Medium
- High A
N0 03 06 t2 18 '-iM1Td—
n Tnw ship
1;1
Figure 3. Illicit discharge potential analysis of the Wissahickon watershed in southeastern
Pennsylvania.
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Illicit Discharge Detection and Tracking Guide
Table 2: Defining Discharge
Discharge Screening
Defining and Deriving the Factor
Factors
1. Past Discharge
Frequency of past discharge complaints, hotline reports, and spill responses per
Complaints and Reports
subwatershed. Any subwatershed with a history of discharge complaints should
autornatically be designated as having high 0P.
2. Poor Dry Weather
Frequency that individual samples of dry weather water quality exceed
Water Quality
benchmark values far bacteria, nutrients. conductivity or other predetermined
indicators. High risk if two or more exceedances are found in any given year.
3. Density of Generating
Density of more than 10 generating sites or five industrial NPDES storm water
Sites or Industrial NPDES
sites per square mile indicates high IDP. Density determined by screening
Storm Water Permits
business or permit databases.
4, Storm Water Outfall
Density of mapped storm water ❑utfaIIs in the subwatershed, expressed as the
Density
average number per stream or channel mile. A density of more than 20 outfails
per stream mile indicates high IDP.
Defined as the average age of the majority of development in a subwatershed.
5. Age of Subwatershed
High IDP is often indicated for developments older than 50 years. Determined
Development
from tax maps and parcel data, or from other known information about
neighborhoods.
6. Sewer Conversion
Subwatersheds that had septic systems but have been connected to the sanitary
sewer system in the last 30 years have high IDP.
7. Historic Combined
Subwatersheds that were once served by combined sewer system but were
Sewer Systems
subsequently separated have a high IDP.
S. Presence of Older
Subwatersheds with more than 5% of its area 1n industrial sites that are more
Industrial Operations
than 40 years old are considered to have high IDP. Determined from historic
zoning, tax maps, and "old-timers."
Defined as the age and condition of the subwatershed sewer network. High IDP is
9. Aging or Failing Sewer
indicated when the sewer age exceeds design life of its construction materiais
Infrastructure
(e.g., 50 years) or when clusters of pipe breaks, spills, overflows or 1/1 are
reported by sewer authorities.
10. Density of Aging
Subwatersheds with a density of more than 100 older drain fields per square mile
Septic Systems
are considered to have high IDP. Determined from analysis of lot size outside of
sewer service boundaries.
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Illicit Discharge Detection and Tracking Guide
Discharge Screening
Factors
11. Thermal Anomalies
Defining and Deriving the Factor
Thermal imaging data records images of heat radiating from the Earth's surface
by aircraft equipped with an infrared video camera, which is similar to the
technology used in night vision aids. Ground and stream surfaces tend to have
Fairly constant temperatures, so lighter (warmer) areas are readily identified as
"thermal anomalies_ Some of these anomalies may represent problems with the
sewer system or sources of water pollution, but others may be caused by natural
conditions, such as groundwater discharge. Subwatersheds with thermal
anomalies can be considered to have higher IDP than those without them.
Step 5: Generate maps to support field investigations - Create relatively simple maps that show
streams, channels, streets, landmarks, property boundaries and known outfall locations.
Provide enough information so crews can find their way in the field without getting lost, but
otherwise keep them uncluttered. Low altitude aerial photos are also a handy resource
when available.
Consult Brown et al. (2004) for more detail on the desktop assessment.
Field screening of outfalls
Illicit discharges can be detected in several ways: citizen Complaints, during regular outfa11 screening and
during other routine activities conducted by staff. This section describes a protocol to be used during
regular outfall screening, although sampling procedures to be followed at the outfall do not differ
greatly based on the type of detection. Adapted from Brown et al. (2004), the protocol relies primarily
on visual observations and the use of field test kits and portable instrumentation during dry weather to
complete a thorough inspection of the communities' storm sewers in a prioritized manner. The protocol
is applicable to most typical storm sewer systems; however, modifications to materials and methods
may be required to address situations such as open channels, piped stream networks, systems impacted
by sanitary sewer overflows, or situations where groundwater, backwater or tidal conditions preclude or
confound adequate inspection. The primary focus of the protocol is sanitary waste, however, toxic and
nuisance discharges may also be identified. Implementation of the protocol would satisfy the relevant
conditions under Minimum Control Measure No. 3, illicit discharge detection & elimination (IDDE), of a
community's NPDES MS4 Permit.
Rapid field screening of storm water outfalls in priority subwatersheds is conducted during dry weather
to identify potential illicit discharges (i.e., flowing outfalls) and is followed by indicator monitoring to
characterize flow types to aid in finding sources. Table 3 lists the common indicator parameters used to
detect illicit discharges. The field screening can also be used to develop a systematic outfall inventory
and map of the MS4. Regular inspections of outfalls are a primary part of an effective IDDE program and
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Illicit Discharge Detection and Tracking Guide
a regular schedule of long-term inspections far ❑utfaIIs should be maintained. At a minimum, all outfaIIs
should be inspected during the first NPDES permit cycle by walking entire stream reaches. Further
inspections should be conducted during subsequent permit cycles.
RecommendedTable 3.
Indicator Parameters Used to Detect
Discharge Types it can Detect
Parameter
Laboratory/Analytical Challenges
or
TapIndustrial
Sewage
Washwater
Commercial
Water
Liquid Wastes
Can change into other nitrogen forms
Ammonia
•
O
�
O
as flow travels to the outfall
Detergents
i
•
a
O
Reagent is a hazardous waste
Surfactants
E. call,
Enterococci, or
D
0
Q
G
24-hour wait for results
Total Coliform
Exception for communities that do
Fluoride*
0
D
•
�
not fluoridate their tap water
Potassium
Q
©
0
•
• Can almost always (>80% of samples) distinguish this discharge from clean flow types (e.g., tap water or
natural water). For tap water, can distinguish from natural water.
CD Can sometimes (>50% of samples) distinguish this discharge from clean flow types depending on regional
characteristics, or Can be helpful ire combination with another parameter
D Poor indicator. Cannot reliably detect illicit discharges, or cannot detect tap water
Data sources, Brown et at. (2004)
*Fluoride is a poor indicator when used as a single parameter, but when combined with additional parameters
(such as detergents, ammonia and potassium), it can almost always distinguish between sewage and wastewater.
Field Preparation
While a complete overview of field Preparation for outfall screening can be found in Brown et al. (2004),
some basic checklists for field preparation are provided below for convenience.
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When to conduct an outfall survey?
■ During the dry season (in regions with a clearly defined dry season)
41 Late Fall/Early Spring- outfalls are easiest to spot during leaf -off conditions (especially in the
southeast where excessive vegetation can limit access to outfalls); however, if part of the IDDE
work is investigating swimming pool discharges it may require field work outside of the leaf -off
time frame.
a After a dry period of at least 49 hours (trace rainfall activity may be acceptable depending on
the size of the watershed).
• Early Morning/Late Afternoon- though not always possible, checking outfalls when people are
home may increase the chances of catching an illicit connection.
* Avoid conditions during snow melt and/or if salt has been applied to the road system draining to
the outfalls. Also note that some field tests (e.g. ammonia, chlorine) are affected by cold
temperatures or confounded by the presence of salt (detergents).
■ If outfall monitoring Is occurring along a tidal body of water-, data collection dates and times
should be selected to take advantage of the lowest possible tide, this will allow for the easiest,
safest and most accurate and complete assessment of outfalls.
The first step to successful field work is to have a map with the necessary information. Some data can be
considered extremely helpful, but optional, while other data is required (Table 4). Maps should be
provided in the field binders on 8.5 X 11 paper at a scale ranging from 1:1000 to 1:10000 (Figure 4).
Table 4. Map Preparation
Desired Data Layers
Dptio r?a! Data Layers
Roads
Aerial Photography
Streams
Sewer infrastructure
Watershed Boundaries
Critical/ Resource Protection Areas
Outfall locations
land Cover
Manhole Locations
Topography
Stormwater infrastructure
Current / former combined sewer
I pipes/outfalls
Jurisdictional Boundaries
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Illicit Discharge Detection and Tracking Guide
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x
#MMJIPw_w.
p.. +.i eMLR"
'+'KfErCS11
PRQiECiIa
Figure 4. Example field reap at 1:6.0U0 scale.
A field and lab supply list is provided in Table 5.
Table•. Supply
Field
Lob
Field Binder with maps
Detergent test kits
Camera
Fluoride meter+ reagents
GP5 Unit
Potassium meter+ standards
Measuring tape
Bacteria plates
❑utfall marker
Incubator
Field Tape (50' min)
Sterile 1-ml pipettes
Stopwatch
Alconox or other cleaning solution
Ping -pang ball
Deionized water
Flashlight
Stopwatch
Graduated milk jug (marked at 1 Q
Gloves
Gloves
Filter
Center for Watershed Protection p. 13 of 29
12/2/2011

Illicit Discharge Detection and Tracking Guide
TableSupply
Field
Lob
Dipper and/or telescoping rod
Filter paper
Pencils/Pens
Material Data Safety Sheets
Sharpies
First Aid Kit
Deionized Water
Sterile sample bottles*
Cooler and ice packs
Nalgene bottles*
Ammonia meter+ reagents
Chemwipes
ziploc Bags
Waders
*1 bottle each/site plus extra for duplicates
A checklist of items to include in the Field Binders is provided below:
❑ Contact Numbers for Field Crews (i.e. cell phone number)
❑ Meeting Location/Address
❑ Safety Procedures and Emergency Numbers
❑ Location of Nearest Hospital
❑ Field Maps
❑ Chain -of Custody Form
❑ Outfall Reconnaissance Inventory Forms (see Appendix A)
Center for Watershed Protection p. 14 of 29
12/2/2011

Illicit discharge Detection and Tracking Guide
Preparation of supplies should include the following:
❑ Ensure batteries in cameras, GP5 units, meters, etc. are charged.
❑ Ensure all sample bottles are cieaned with Alcanox or similar cleaning product.
❑ Remove old labels from sample Mottles and replace with new labels, if necessary_
❑ Ensure you have one bottle for each anticipated outtall as well as extra Mottles for randomly
selected replicates, if needed.
❑ Freeze all ice packs.
❑ Set temperature of incubator to that specified by manufacturer for bacterium of interest.
Outfoll screening procedures
The primary field screening toot is the 0utfaII Reconnaissance Inventory (0RI) form, which is
provided in Appendix A and described fully in Brown et al. (2004). The basic procedure at each
outfall is to take a picture of the outfall and, if the outfall is not already in the jurisdiction's mapping
system, collect GP5 coordinates and label the outfall with spray paint or waterproof marking stick in
a prominent Location such as the outfall headwall (see Appendix 6 for more information on mapping
a stormwater drainage system). Next, an GRI form is completed, which includes recording a
description of the outfall (e.g., pipe material, diameter), a description of physical indicators of
potential illicit discharges for Moth flowing and non -flowing outfalls and the results of flow and water
quality measurements taken at flowing outfalls. A description of the flow measurement and
sampling procedures is provided below.
If the outfall has dry weather flow, three samples should be collected: one for on -site analysis of
ammonia; one for bacteria, fluoride, potassium and detergents; and one for total nitrogen and total
phosphorus. The procedure for collecting a water sample is as follows:
1. Put on gloves;
2. When possible, sample the flow directly in a clean, glass bottle or sterilized plastic bottle
or bag;
3. Be sure to rinse the bottle once with flow from the sample water far conditioning;
4. if a dipper, hailer, bucket or other device is used to collect a sample, be sure that they
are conditioned with the flow prior to final collection as well;
5. Sample bottles are to be labeled with the appropriate outfall ID, date of collection, and
sampte collector initials using a water -proof marker;
5. Collect replicates as specified for local program, if needed; and
7. Put samples for lab in cooler with ice.
Center for Watershed Protection p. 15 of 29

Illicit Discharge Detection and Tracking Guide
Next, conduct the ammonia test following the instructions provided by the manufacture; of the test
kit. Record the results on the QRI from. Be sure to rinse probes/cuvets with distilled water after
sample analysis.
Lastly, measure the 'flow rate at all flowing outfalls. Flow measurements can be difficult to accurately
collect in certain situations, for example, when the flow is too large or too little to collect with the
chosen container. As such, three methods are presented and are listed in priority preference:
Method I: Utilizing a graduated milk jug marked at 1 Liter and a stopwatch record the amount of
time required to fill the jug to 1 Liter. Ensure you are capturing the entire flow, When the flow is
only a trickle, use a smaller volume container and follow the same method. The following equation
is used to calculate flow: Discharge = Volume filled (cu. ft.) x Time (sec). For pipes that are
discharging larger volumes where it is not be possible to capture the volume in a graduated
container, see Method 2.
Method 2: This method should only be used with a free -flowing outfall (i.e. water drops out of the
pipe and falls to the stream channel) and when the depth of flow is relatively uniform. Utilizing a
tape measure, record the flow depth in the pipe at the deepest point (thalweg) and the totat flow
width. Then use the following equation: Discharge= 3.1 x wetted width (ft) x flow depth (ft) ^1.5
Method3: Using a tape measure record the width of the flow. Next measure and record the depth of
the flow. Using a measuring tape, ping pang ball, and stop watch, record the length of time it takes
to travel a known distance and. Repeat velocity measurement 3-5 times and average the results.
Then use the following equations to calculate the flow rate and record the results on the 0RI form:
Area= Wetted width (ft) x flow depth (ft)
Velocity= Length of ping pong ball run (ft) I Time (sec)
Discharge= Area x Velocity
All samples collected for external lab analysis should be preserved as specified by the lab for the
parameter of interest. See Standard Methods for the Fxamination of Water and Wastewater for
more information about sample collection and sample preservation:
htto:llwww.standardmethods org/- Bacteria samples are to be processed within 6 hours of
collection and incubated at the appropriate temperature and for the necessary length of time as
indicated by the bacteria plate manufacturer. Results of additional field and/or lab analysis can be
recorded on the outfall Reconnaissance Inventory/ Sample Collection Lab Sheet (Appendix C).
Follow up
All outfails with a confirmed illicit discharge will require a drainage area investigation as described in
the next section. If the outfall is determined to have a potential illicit discharge based on physical
indicators, but samples do not exceed established water quality thresholds, the outfal€ should be re-
visited two additional times during the permit cycle to determine if an intermittent discharge may be
present. Ideally, one re -visit will occur on a different day of the week than the original visit and/or at
a different time of day.
Center for Watershed Protection p. 16 of 29

Illicit Discharge Detection and Tracking Guide
Nitrogen, phosphorus and bacteria pollutant loads can be estimated far each outfaII screened
through an illicit discharge program. By doing so, the quantitative benefit of removing the illicit
discharge can be tracked internally and reported to regulating authorities and the public. Pollutant
reductions can be accounted for in MS4 program reports as well as far Total Maximum Daily Load
(TMDL) implementation and tracking. By conducting routine ❑utfall screening on a watershed scale
in concert with instream monitoring for the same parameters, inferences can be made regarding the
illicit discharge pollution load proportionaf to baseflow conditions_
A pollutant load accounting spreadsheet is provided at www.cwu.crkj. for use in estimating loads
from illicit discharges. Total nitrogen and total phosphorus concentrations are required inputs, along
with an accurate flow measurement. Standard conversions are used to report results in pounds of
nutrients per year and gallons per year. Similar calculations can be computed for bacteria, although
these are not included in the spreadsheet.
New outfalls and unmapped stormwater infrastructure should be updated in the jurisdiction's
master GIS system as soon as possible at the office after identification. Stormwater pipe mapping
should note the direction of flow in addition to pipe location. Any illegal dumping or needed
infrastructure repairs found in the 'field should be reported immediately to the appropriate agency.
Non -routine inspections
If an employee observes evidence of an illicit discharge during an informal or non -routine inspection,
he/she should collect as much information about the potential illicit discharge as possible then
contact his/her supervisor or dispatch office so that appropriate action can be taken. A tracking sheet
or spreadsheet (Table b) can be used to collect the information observed. While it may not be
reasonable to expect all public works employees to have copies of the form at ail times, there are
other ways to collect the information:
The person observing the discharge can provide the information verbally to dispatch
or the supervisor, who can then complete the Illicit Discharge Tracking Sheet;
The person can log as much information as they can retail onto the form upon
returning to the office; or
A third party (such as a code enforcement officer) dedicated to inspecting and
tracing illicit discharges can be sent to the location as soon as possible where the
potential illicit discharge was observed to collect the necessary information directly
on the form.
It is important to collect as much information as possible at the time of initial observation because of
the likelihood that a discharge may be transitory or intermittent. Initial identification of the likely or
potential sources of the discharge is also very important_
Center for Watershed Protection p. 17 of 29

Illicit Discharge Detection and Tracking Guide
6. Illicit
DischargeTable
Date
Report
Location of
Description
Actions to be
Description of
Date
Reported:
Initiated by:
Discharge: If
of Discharge:
Taken: Who
Resolution.,
Resolved:
Phone, drop-
known —
E.g. —
What, When
Outcome of
In, contact
tat/long, stream
dumping,
and
Actions taken
information,
addressor
wash water
Now ... (what
and any
etc.
outfall #, nearby
suds, oil, etc.
should be
necessary
landmark, etc.
done)
follow-up (what
was done)
Drainage Area and Storm Drain Investigations
An illicit discharge source investigation should be conducted far all outfaIIs where any of the
following apply:
The overall outfaII characterization as determined by the 0Ri is determined to be
"suspect" or "obvious" as indicated in Section 6 of the DRL
On -site or lab analysis results in values that exceed established thresholds indicated
in Table 2. Thresholds can be adjusted as needed to reflect local conditions.
A "weight -of -evidence" approach is recommended, that is, using more than one
indicator to determine the presence of an illicit discharge.
Table.. levels
Parameter
for screening parameters
Threshold
used in illicit discharge surveys
Source
Ammonia
>0.1 mg/L
Brown et al (2004)
E. tali
>235 CFUj100 ml
(grab sample)
EPA (1986)
Totat coliform
>10,000 CFU/100
ml (grab sample)
California state standard (Dorfman and
Rosselot, 2011)
Fluoride
>0.2.5 mg/L
Brown et al (2004)
Detergents
>0.25 mg1L
Brown et ai (2004)
Potassium
>6 ppm
Guidance extrapolated from Lilly and Sturm
(2010)
Center for Watershed Protection p. 18 of 29

Illicit Discharge Detection and Tracking Guide
Table.. levels
for screening parameters
used in illicit discharge surveys
Parameter
Threshold
Source
Ammonia:
Determine locally
>0.3 based on CWP field studies in the Mid -
potassium ratio
Atlantic but the ratio varies regionally.
Guidance extrapolated from Lilly and Sturm
(2010)
An illicit discharge source investigation is conducted to isolate the source of the pollution. There are
two types of source investigations: ❑rainage Area Investigations and Storm Drain Investigations. An
illicit discharge that is determined to be likely transient in frequency, entering the storm drain system
directly through durnping or spills from the landscape will follow the procedure for a Drainage Area
Investigation. A continuous or intermittent discharge that likely occurs from direct or indirect entry
into the storm drain system from the interaction of pipes underground will follow the procedure for
a Storm Drain Investigation. Either investigation should be conducted during dry weather.
Public notification may be required in either type of investigation. If right of entry onto private
property is required, the jurisdiction will provide a letter/mailer to residents and building owners
located within subject drainage basin and/or sewershed notifying them of the scope and schedule of
investigative work, and the potential need to gain access to their property to inspect plumbing
fixtures. Assessor's records will provide property owner identification.
Drainage Area Investigation
A rapid windshield survey of the drainage area may be used to find the potential discharger or
generating sites if the discharge observed at an outfall has distinct or unique characteristics that
allow crews to quickly ascertain the probable operation or business that is generating it (Brown et al.
2004). Discharges with a unique color, smell, or off -the -chart indicator sample reading may point to a
specific industrial or commercial source.
A rapid drive -by survey works well in small drainage areas, particularly if field crews are already
familiar with its business operations. Field crews can match the characteristics of the discharge to the
most likely type of generating site, and then inspect ail of the sites of the same type within the
drainage area until the culprit is found. For example, if fuel is observed at an outfall, crews might
quickly check every business operation in the catchment that stores or dispenses fuel,
In larger or mare complex drainage areas, GIS data can be analyzed to pinpoint the source of a
discharge. If only general land use data exist, maps can at least highlight suspected industrial areas. If
more detailed Standard industrial Classification (SIC) code data are available digitally, GIS can be used
to pull up specific hotspot operations or generating sites that could be potential dischargers.
Storm Drain Investigation
Center for Watershed Protection p. 19 of 29

Illicit Discharge Detection and Tracking Guide
In a Storm ❑rain investigation, field crews strategically inspect manholes within the storm drain
network system to measure chemical or physical indicators that can isolate discharges to a specific
segment of the network. Once the pipe segment has been identified, on -site investigations are used
to find the specific discharge or improper connection. This method involves progressive sampling at
manholes in the storm drain network to narrow the discharge to an isolated pipe segment between
two manholes. Field crews need to make two key decisions when conducting a storm drain network
investigation —where to start sampling in the network and what indicators will be used to determine
whether a manhole is considered clean or dirty.
The field crew can sample the pipe network in one of three ways:
Crews can work progressively up the trunk from the outfall and test manholes along the way.
Crews can split the trunk into equal segments and test manholes at strategic junctions in the
storm drain system.
• Crews can work progressively down from the upper parts of the storm drain network toward
the problem outfall.
During a manhole inspection, manholes are opened and inspected for visual evidence of
contamination. Where flow is observed, and determined to be contaminated through visual
indicators or field monitoring, the upstream tributary storm sewer system is isolated for investigation
(e.g. further flow inspection, dye testing, CCTV). No additional downstream manhole inspections are
performed unless the observed flow is determined to be uncontaminated or until a I I upstream illicit
connections are identified and removed. Where flow is not observed but an intermittent discharge
is suspected in a }unction manhole, all inlets to the structure are partially dammed for the next 48
hours when no precipitation is forecasted. Inlets are damned by blocking a minimal percentage of
the pipe diameter at the invert using sandbags, caulking, weirs/plates, or other temporary harriers.
The manholes are thereafter re -inspected (prior to any precipitation ❑r snow melts for the capture of
periodic or intermittent flows behind any of the inlet dams. The same visual observations and field
testing is completed on any captured flow, and where contamination is identified, abatement is
completed prior to inspecting downstream manholes. In addition to documenting investigative
efforts in written and photographic forni, it is recommended that information and observations
regarding the construction, condition, and operation of the structures also be compiled.
Where flow is observed and does not demonstrate obvious indicators of contamination, samples are
collected and analyzed and then compared with established benchmark values to determine the
likely prominent source of the flow. This information facilitates the investigation of the upstream
storm sewer system. Benchmark values may be refined over the course of investigations when
compared with the actual incidences of observed flow sources. In those manholes where periodic or
intermittent flow is captured through damming inlets, additional la be rato ry testing (e.g. toxicity,
metals, etc.) should be considered where an industrial discharge is suspected.
Adequate storm and sanitary sewer mapping is a prerequisite to properly execute a storm drain
investigation. As necessary and to the extent possible, infrastructure mapping should be verified in
the field and corrected prior to investigations. This effort affords an opportunity to collect additional
Center for Watershed Protection ❑. 20 of 29

Illicit Discharge Detection and Tracking Guide
information such as latitude and longitude coordinates using a global position system (GPS) unit if so
desired. To facilitate subsequent investigations, tributary area delineations should be confirmed and
junction manholes should be identified during this process.
To facilitate investigations, storm drain infrastructure should be evaluated for the need to be cleaned
to remove debris or blockages that could compromise investigations. Such material should be
removed to the extent possible prior to investigations, however, some cleaning may occur
concurrently as problems manifest themselves.
Where field monitoring has identified storm sewer systems to be influenced by sanitary flows or
washwaters, the tributary area is isolated for implementation of more detailed investigations.
Additional manholes along the tributary are inspected to refine the longitudinal location of potential
contamination sources (e.g. individual or blocks of homes). Targeted internal plumbing inspections,
dye testing, smoke testing or CCTV inspections are then employed to more efficiently confirm
discrete flow sources. More information on these techniques can be found in Brown et of (2004).
Post -Removal Confirmation
As the sources of illicit discharges are confirmed, measures to correct them must be taken, working
with the property owner or other responsible party. The exact type of repair needed will depend on
the type of discharge and mode of transmission. Additional guidance on eliminating illicit discharges
is provided in Brown et al. (2004).
After completing the removal of illicit discharges from a subdrainage area, the suInd rainage area is re-
inspected to verify corrections. Depending on the extent and timing of corrections, verification
ronitoring can be done at the initial }Unction manhole or the closest downstream manhole to each
correction. Verification is accomplished by using the same visual inspection, field monitoring, and
damming techniques as described above.
In addition to verifying removal of individual illicit discharges, the progress of the IDDE program
should be evaluated by tracking metrics such as.
Number or % of manholes/structures inspected
Number or % of outfalls screened
Number or %of illicit discharges identified through:
a visual inspections
o field testing results
0 temporary damming
Number or % of homes inspected/dye tested
Footage or % of pipe inspected by CCTV
Center for Watershed Protection p. 21 of 29

Illicit Discharge Detection and Tracking Guide
Number or % of illicit discharges removed
Estimated flow/volume of illicit discharges removed
■ Footage and location of infrastructure jetting/cleaning required
■ Infrastructure defects identified and repaired
• Water main breaks identified and repaired
• Cost: of illicit discharge removals (total, average unit costs)
Safety Procedures
The field activities described in this guide involve sampling of potentially contaminated water and, as
such, have some associated risk. As with any field procedures, appropriate precautions should be
taken to ensure the safety of field crews. Generai and specific suggested safety procedures are
provided below.
General suggestroas
While performing field work activities, use appropriate caution, make an effort to
recognize potentially dangerous situations while performing field work, and take the
proper steps to avoid or minimize them.
• Field work activities should not be performed alone.
• A list of team member and emergency contact numbers should be kept with each
field team.
■ Long pants and close -toed shoes are strongly recommended.
■ Carry adequate water, sunscreen, and bug repellent if needed.
• Employees should use their judgment to ensure their safety while working during
inclement weather. It may be necessary to suspend and/or reschedule field work if
the weather will not permit safe and effective completion of the activities.
Recommended precautions include:
o Severe heat or cold: Dress appropriately, take breaks as needed to warm up
or cool down, and stay hydrated.
o Thunderstorms: Stop working, get out of the water, if applicable, and take
shelter if there is a threat of lightning strikes.
o Snowstorms, flooding, tornadoes, and other dangerous weather: Field work
should be stopped or canceled if dangerous weather arises or is predicted.
Center for Watershed protection p. 22 of 29

Illicit Discharge Detection and Tracking Guide
• Each field work team should have a functioning mobile phone and a fully -stocked
first aid kit.
Public roadways
■ Whenever work will be performed in or near a public roadway, wear a high -visibility
safety vest.
Monholes and similar structures
if a manhole cover or similar structure must be removed (in order to determine sewer line
configuration, for example);
■ Safety -toe footwear {steel -toed shoes} should be worn.
+ Lifting manhole covers should be done with the proper tools and technique so as to
avoid injury.
■ The open cover should only remain open as long as necessary to gather the required
information, and should never be left unattended.
+ Due to the potential dangers of confined spaces, do not enter a manhole or put your
head below the rim of the opening.
Stream walks and illicit discharges
■ Properly fitting waders with high -traction soles should be worn when walking in a
strea m.
Rubber gloves should be worn if contact with polluted water is expected.
■ Skin contact with suspected illicit discharges should be avoided.
■ Hand sanitizer and/or careful hand washing should be employed after potential
contact with polluted water.
• High -visibility orange or yellow vests should be worn during hunting season.
• Wear safety goggles when performing any chemical tests.
■ Reagents and other chemicals should be used and disposed of properly by following
the guidance on the MSOS safety sheets.
Center for Watershed Protection p. 23 of 29

Illicit Discharge Detection and Tracking Guide
References Cited
Boston Water & Sewer Commission. 2004. A systematic Methodology for the identification and
Remediation of illegal Connections. 2003 Stormwater Management Report, chap. 2.1.
Brown, E., D. Caraco and R. Pitt, 2004. Illicit Discharge Detection and Elimination: a guidance manual
for program development and technical assessments. Center for Watershed Protection and
University of Alabama. EPA X-82907801-0.U.S. EPA Office of Wastewater Management, Washington,
D.C.
Dorfman, Mark & Kirsten Sinclair Rosselot. 2011. Testing the Waters: A Guide to Water Quality at
Vacation Beaches. Natural Resources Defense Council.
htto' //tivww. n rdc.orglwaterJocpa nsLttwjtitinx.aso
Environmental Protection Agency. 1986. Ambient Water Quality Criteria for Bacteria. EPA440/5-84-
002,
Lilly, Lori and Paul Sturm. 2010. Technical Memorandum: !!licit Discharge Monitoring in Baltimore
Watersheds. Center for Watershed Protection. Ellicott City, MD.
Center for Watershed Protection p. 24 of 29

Illicit Discharge Detection and Tracking Guide
APPENDIX A. OUTFALL RECONAISSANCE INVENTORY (ORI) FORM
0 mmx RECO\13issA-iCEL� ERTORY / SAADLE COLLECTION FEELD SHEET
¢aru��, i • R,�t•e,...,,Ra nor.
Suharatershe
UutfaO ID -
Today 's date.
Time
bwestigatars:
Foam completed by
Tampernrme ('F)- Ramfa2 Chi): 1. t 11 hour: Last 48 Luaus:
Iaetnde: Lwsgtode:
GPS Uait GPS L�1F
Camera:
Ph= #s:
LanA Uw mDminage elan (Cheek all that 2pph•):
❑ Indtrst-iil 0 Ultm-Urban Residential ❑ Commerciil
Other-
Noses (r.g_, ongm of outfilL itknown):
0 Qpm Space ❑ Suburban Rcsdenual [E Instittmonal
RmR•ra inda rues:
�eennn s: vnnauitescrt wort
LOCATION MATERYAL
[I RCP ❑Cie
❑ Cloud Pipe ❑ FVC ❑ NDPE
❑ Seed
❑ Ocher.
SHAPE
❑ Circular
❑ Sin -le
❑ EWphcal
❑ Double
❑ $ox
❑ Triple
Cl other
❑ t7tluu
DIN EfiS ONS (IN.)
SUBMERGED
DI ;a citrafar ,
La Water
❑ No
Box: k - _is - T
❑ Pisdally
❑Fdy
Elliptical:
WIttth Semmeur
h--w--
❑-To
❑ Ptorixll�
❑ Folly
❑ Coocre6e ❑ rap -rap ❑ Earthen ❑ Trapezoid ❑ Other DeOL _ Bottum [ -Ift7
Cl Open drsieag"
❑ ❑Other PxrabaLe Top, ll'idth
❑ Is -Stream Compkre Stream Disclarge form
Flow Present" ❑ Yes ❑No Flea Description ❑ TdckL- ❑ Sladerate ❑ Sub tanfw
- Tidal" © yet ❑ _tie Ifyes_ stair ❑ Flood [:]Ebb Time:
%&Minn A- C}uzinlit atira C harariws•i7stinn
FIELD DATA FOR FLOV nNG OUTFALLS
PARAMETER RESULT UNIT EQUIPMENT
{]Flaw rl
vatume
Leer
$attic
Trine to fill
Sec
Stopwash
❑Flow *'_
Flow depth
It,
Tape mea Rue
ioniy fer km-
Eo'r'ng
atafxllsl
Wetted width
!t
Tape am nut
Flaw width
Ft 1a
Tape m gue
❑Flow t3
new depth
In
Tape meaRue
Tare of trat el (use)
i. _' 3.
Sec
Stop rruch
,�&anffed Seukrh
Ft Ta
Trpe measure
Am+ n+ a
mgl
Specific ion probe T}pe:
Illicit Discharge Defecilon Qnd Elimination
Center for Watershed Protection P. 25 of 29

Illicit Discharge Detecfion and Tracking Guide
Outfall Reconnaissance Inventory Field Sheet
Section d: Pby-sical Indicators for Flossing Ontfalls dais -
Are _anv Ph«itat Indarnlam Prr:ent m the itnw7 ❑ Vec M Nn W.Vn Cain lr5 Corneae is
INDICATOR
CPHECK ai
rese❑
DESCRIPTION
RELATIVE SEVERITY INDEX (1-3)
Odor
❑
Sewage ❑ Renci&wur [:IPetroledm+gas
❑ l - Fnittt
❑ 3 - Easif►' detected
C] 3--Katiceabfe from a
[] Sulfide ❑ Other
distance
Cl❑
Clear ❑ limn ❑ Gray © Ye➢lme
❑ 1- Fwnr colors is
❑ ? - Cie arly risible in
❑ 3 - Clearly mible inColor
❑ GreeII ❑ OranEe ❑filed ❑Other
swWle bottle
sample bottle
outfail flow
Tutbidity
❑
See su-erm
❑ l - Slight cloudiness
❑ -' - Cloud}•
❑ 3 - Opaque
Flwtablrs
❑ Senage (Toilet Paper. etr.) Suds (Toileti]
❑ k -Few slight: aaigin
❑ 2 - Some. uldicaliaos
of origin (r.€..
Q 3 - Some; arum clear
(e.g obvious oil
-Does Not lacludr
T awi
❑
❑ Petroleum (oil sheen} El Other
not obvious
passsble suds a oil
.
sheen suds. ar flwtiot
sheen)
sanitary• materieks}
Section S. Physical Indicators for Both Flosing and Non -Flossing Outfalls
Are tali—it,1 .tart i r, rare rh.f ire Y tar rat gyred rn Areu• nr!•srn0 n S-rc n Vd a lr%'n CI-sa fr, Cortina Ka
INDICATOR
CHECK if Present
DESCRIPTION
COMMENTS
Oorfall I}amage
❑ 5pauing. Cracking or Chipping ❑ peefing Parnt
❑ Cnrrosinn
Drpasitsisf.Bms
❑
❑ Oily ❑ Flaw LMC ❑ Paint ❑ Other:
Abnormal Vegeutiou
❑
❑ Excessive ❑ Inhrbited
Poor pool quality
❑
❑ Odors ❑ Colors ❑ Fleatables ❑ Oil Sheen
❑ Suds ❑ Excessive Aleae ❑ Other
pipe benrhlC gra15TL
©
❑ Rrotivo ❑ Drarsge ❑ C:reeII ©{]f]yQ
❑ Ua4tly ❑ Potential (presence of two or more indicators) ❑ Suspect (one or more indicators with a seventy of 3) ❑ Obvious
Section ': Data C ollectlon
L Sample foz external lab? ❑ Yes ❑ No ?. Sample for MY-) ❑ Yes ❑ No 3. Sterile sample for bacteria analysis? ❑ Yes ❑ No
4. Sarnple(s) collected front ❑ Flow ❑ Pool
5. Duplicate collected? ❑ Yes ❑ No tf3•es, check aappmpdare., ❑ External lab ❑ C WP ❑ Sterite
Section s: Any Non -Illicit Discharge Concerns (e.g., trash or needed infrastructure repau'i) or other dotes?
Centerf
Illicit Discharge Defection and Elimination

Illicit Discharge Detection and Tracking Guide
APPENDIX B. MAPPING THE SYSTEM
This section was modified from the New Hampshire Estuaries Project, November, 2006 "Guidelines and
Standard Operating Procedures: Illicit Discharge Detection & Elimination and Pollution: Prevention / Good
Housekeeping." Pp. 17-1&
Completing a map of the storm drain system is best accomplished
through the use of geographic information systems (GIS).
A sample strategy for mapping an MS4 community is as follows:
I. Rewew/Office Preparation:
a. Check existing available mapping data in high priority areas
first, then in medium priority areas, then low priority
areas (planning board submittals or as -guilts are a good
resource for locations).
b. Decide on and document a numbering or naming system
for outfalls and other structures. Establishment of a
simple unique numbering system (SWO-0001, SWO-0002,
etc.) will facilitate future inspections and documentation
of maintenance.
c. Select a method to mark outfalls in the field (using spray
paint, paint pen, or signs or markers), and place an order
for necessary materials. (Marking the ❑utfalls ensures
they can he consistently identified in the field, but is not
required.)
d. Obtain equipment for mapping (see Equipment List).
Equipment List for mapping:
1. Existing paper maps
2. Field sheets
3. Camera
4. GPS unit
5. Spray paint
5. Cell phone or handheld
radio
7. Clip hoards and pencils
& First aid kit
9. Flashlight
10. Protective gloves
11_ Tape measure
12. Waders
13. Temperature probe
14. Sop watch
15. Sample bottles
16. Dry erase board {for
photos)
17. Hand sanitizer
18. Sampling pole
19. Mirror (for fight)
20. Safety vests
e. Develop a schedule for completing (use town or city parcel grid or watershed areas).
f. Conduct preliminary reconnaissance to evaluate if watercraft are necessary to view the banks of the
waterbody.
2. Field check:
a. Using existing paper maps as a basis for locations, field personnel should start a mapping program
by walking all named waterbodies within a given area of the community and collecting outfall
location and design information using global positioning system (GPS) equipment capable of sub -
meter (approximately 3-foot) accuracy. Use of a data logger and data collection software, such as
Pathfinder", will allow the generation of GIS files that will be useful for many years. Utilize the
0utfaII Reconnaissance Inventory (OR1) form for outfaII characterization.
Center for Watershed Protection p. 27 of 29

Illicit Discharge Detection and Tracking Guide
b. Collect dry weather inspection information whenever possible. Dry weather discharge information
can either be collected an the paper forms for manual entry into a separate database at a later
time, or can be directly entered into a database on a laptop or the data logger on -site.
c. Mark the outfalI with its identifier for future location and easy reference using spray paint, paint
markers, or pre -manufactured signs.
3. Develop Initial G15 Maps: tf the storm drain system is being mapped as part of a larger GIS database for
the municipality, the data collected can be displayed with any of lire existing data sets. If the storm drain
system is not part of a larger data set, the Program Manager must determine what background the maps
should be displayed on, such as an aerial photograph, United States Geological Survey (USGS)
quadrangles, a a set of roads, political boundaries, waterbodies, and watershed information.
4. Review and field check other structures (catch basins, culverts, pipes, ditches, drain manholes, etc.) -
a. Scan and digitize any paper maps of the system into GIS-compatible files or use aerial photographs
to identify paint structures. An efficient way to do this is to send field staff along with catch basin
cleaning crews to confirm catch basin locat"sans, to observe the interior of structures, to determine
which pipes enter and leave the structure, and to obtain design information on the pipes and
structures. A GP5 unit with a data logger can be used to record the location and design information
related to the structures.
b. Field check digitized data.
c. Assign unique identifiers to remaining structures (CS-0DXfor catch basins, DMH-QOX for drain
manholes, etc.), and a set of attributes and allowable fields to describe the structure.
5. Incorporate field data into G I S and revise as necessary: Gnce the GPS data files have been converted
into GIS layers, and revised maps have been produced, these maps should be proofed to assess their
accuracy and completeness. The reviewer should document any additional data requirements, and
correct any errors in the information collected. A relational database can help illustrate connections
between pipes, outfalls, and other structures.
It should be noted that there are many possible mapping strategies far a given municipality depending an
the amount and format of available storm drain system data and the resources that are available. The
strategy described above is presented as one way to complete mapping. For a small to medium sire
community (5,000 to 10,000 people), this process could take approximately two years to complete,
depending upon availability of resources and land use.
Center far Watershed Protection p. 28 of 29

Illicit Discharge Detection and Tracking Guide
APPENDIX C. Clutfail Reconnaissance Inventory/ Sample Collection Lab Sheet
Subwatershed:
Outfall ID:
Today's date:
Duplicate? (yeslno):
Analysis Technician:
Form completed by:
LAB DATA FOR FLOWING OUTFALLS
PARAMETER
RESULT
UNIT
EQUIPMENT
Ammonia QC check (10% of
samples)
mg/L
Colorimeter
Fluoride
mglL
Specific ion probe
Potassium
ppm
Compact Ion Meter
Conductivity
µs
Conductivity Meter
Bacteria
Count
Di'Iition (1:1 or
1:100)
Red wl gas
CFUs
Petrifilm plate
Blue wl gas
CFUs
Petrifiim plate
Center for Watershed Protection p. 29 of 29

Tab 6

Illicit Discharge Detection and Elimination Ordinance
Ordinance No. 061206A
This is an Ordinance amending the Code of Ordinances for the City of Mount Holly, by
adding Chapter titled "Illicit Discharge to the Storm Sewer System".
Section 1. The Code of Ordinances for the City of Mount Holly is hereby amended to
add Chapter , titles "Illicit Discharge to the Storm Sewer System" in the form
attached hereto.
Section 2. Repealer Cause. All Ordinances or parts of Ordinances in conflict herewith are
hereby repealed.
Section 3. Severability Clause. If any section, provision or part of this Ordinance shall be
adjudged invalid or unconstitutional, such adjudication shall not affect the validity of the
Ordinance as a whole or any section, provision, or part thereof not adjudged invalid or
Unconstitutional,
Section 4. Effective Date. This Ordinance shall be effective from and after the final
passage, approval and publication as provided by law.
PASSED AND APPROVED this day of , 2006 by vote of the City Council.
Mayor
ATTEST:
City Clerk
City Attorney

1, , City Clerk of the City of Mount Holly, North
Carolina do hereby certify that the foregoing Ordinance was passed and approved by the
city council of the City of Mount Holly, North Carolina on the day of
2006; and was published in the , a newspaper
of general circulation in said City of Mount Holly on the day of ,
2006.
Dated this day of , 2006,
City Clerk

Chapter _ Illicit Discharge to the Sewer System
Section 1. Findings:
1.1 The US EPA's National Pollutant Discharge and Elimination System (NPDES)
permit program, which is administered by the North Carolina Department of
Environment and Natural Resources (NC DENR), requires that cities and colonies that
meet certain demographic and environmental impact criteria obtain from the NC DENR
and NPDES permit for the discharge of storm water from a Municipal Separate Storm
Sewer System (MS4). This is called the MS4 permit. The City of Mount Holly is subject
to the program and is required to obtain, and has obtained, an MS4 permit. A copy of this
permit is on file at the City Clerk's office and is available for public inspection during
regular office hours.
1.2 As a condition of the MS4 permit, the City is obliged to adopt and enforce and Illicit
Discharge to the Storm Sewer System Ordinance.
1.3 No state or federal fiends have been made available to assist the City in administering
and enforcing the program. And/or other sources of funding established by a separate
Ordinance.
1.4 Terms used in this Ordinance shall have the meanings specified in the program.
Section 2. Illicit Discharges Prohibited.
2.1 For the purposes of this Ordinance, a "responsible party" is one or more persons that
control or are in possession of or own property. Responsible parties shall be jointly and
severally responsible for compliance with this Ordinance and jointly and severally liable
for any illicit discharge form the property controlled, possessed, or owned. For purposes
of this Ordinance, "property" includes, but is not limited to real estate, fixtures, facilities
and premises of any kind located upon, under or above the real estate.
2.2 Nothing in this Ordinance shall be deemed to relieve a responsible party subject to an
NC DENR-issued industrial discharge permit or any other federal, state or city permit,
statue, ordinance or rule from any obligation imposed by such permit, statute, ordinance
or rule if any such obligation is greater than any obligation imposed by this Ordinance.
2.3 Any discharge into the City of Mount Holly storm sewer system prohibited by the
MS4 permit, the terms of which are hereby incorporated by reference, shall be deemed an
"illicit discharge" in violation of this Ordinance.

2.4 Sediment pollution originating from excessive erosion rates on a construction site not
otherwise subject to either the city or Gaston County soil and erosion control ordinances,
or sediment pollution entering a municipal storm sewer that causes a water quality
violation as determined by NC DENR shall be deemed an illicit discharge in violation of
this Ordinance.
Section 111-11cit Connections Prohibited.
3.1 For the purposes of this Ordinance, and "illicit connection" to the City of Mount
Holly storm sewer system is any physical connection or other topographical or other
condition, natural or artificial, which is not specifically authorized by ordinance or
written rule of the City, which causes or facilitates, directly or indirectly, an illicit
discharge.
3.2 The construction, use maintenance or continued existence of any illicit connection
shall constitute a violation of this Ordinance.
3.3 This prohibition expressly includes, without limitation, illicit connections made in the
past, regardless of whether the connection was permissible under law or practices
applicable at the time of connection.
Section 4. industrial Discharges.
4.1 Any responsible party subject to an industrial NPDES discharge permit issued by NC
DENR shall comply with all of the provisions of that permit.
4.2 Proof of compliance with said permit may be required by the enforcement officer
prior to discharges to the storm sewer authorized by said permit,
Section 5. Illicit Discharge Detection and Reporting: Cost Recovery.
5.1 All detection activities permitted under this Ordinance shall be conducted by the
officially designated City of Mount Holly Stormwater Coordinator, or his or her
designee.
5.2 The City shall not be responsible for the direct or indirect consequences to persons or
property of an illicit discharge, or circumstances which cause an illicit discharge which
has gone undetected by the City.
5.3 Every responsible party has an absolute duty to monitor conditions on property
owned or controlled by them, to prevent all illicit connections and discharges, and to
report to the Stormwater Coordinator any illicit discharges which the responsible party
knows or should have known to have occurred. Failure to comply with any provision of
this Ordinance is a violation of this Ordinance.

5.3.1 Not withstanding other requirements of law, as soon as any responsible party has
information of any known or suspected illicit discharge, the responsible party shall
immediately take any and all necessary steps to ensure the discovery, containment, and
clean up of such discharge at the responsible party's sole cost.
5.3.2 If the illicit discharge consists of hazardous materials, the responsible party shall
also immediately notify emergency response agencies of the occurrence via emergency
response dispatch services.
5.3.3 If the illicit discharge emanates from a commercial establishment, the owner or
operator of such establishment shall also retain an on -site written record of the discharge
and the actions taken to prevent its recurrence. Such records shall be retained for at least
three (3) years.
5.3.4 A report of an illicit discharge shall be made in person or by phone or facsimile or
email to the Stormwater Coordinator immediately but in any event within twenty-four
(24) hours of the illicit discharge; notifications in person or by phone shall be confirmed
by written notice and mailed or emailed to the Stormwater Coordinator within twenty-
four (24) hours of the personal or phone notice.
5.4 Any person or entity may also report to the City (Stormwater Coordinator) any illicit
discharge or circumstances which such person or entity reasonable believes poses a risk
for an illicit discharge.
5.5 Upon receiving a report pursuant to above subsections, or otherwise coming into
possession of information indicating an actual or imminent illicit discharge, the
Stormwater Coordinator shall conduct an inspection of the site as soon as reasonably
possible and thereafter shall provide the responsible party, and any third party reporter, a
written report of the conditions which may cause or which have already caused an illicit
discharge. The responsible party shall immediately commence corrective action or
remediation and shall complete such corrective action or remediation within a short
period of time as could be reasonably expected_
5.6 The Stormwater Coordinator shall be permitted to enter and inspect property subject
to regulation under this section as often as is necessary to determine compliance with this
section. if a responsible part has security measures that require identification and
clearance before entry to its property or premises, the responsible party shall make the
necessary arrangements to allow access by the Stormwater Coordinator or his or her
designee. By way of specification, but not limitation:
5.6.1 A responsible part shall allow the Stormwater Coordinator ready access to all parts
of the property for the purposes of inspection, sampling examination and copying of
records related to a suspected, actual or imminent illicit discharge, and for the
performance of any additional duties as defined by state and federal law.

5.6.2 The Stormwater Coordinator shall have the right to set up on any property such
devices as are necessary in the opinion of the Stormwater Coordinator to conduct
monitoring and/or sampling related to a suspected, actual or imminent illicit discharge.
5.6.3 The Stormwater Coordinator shall have the right to require any responsible party at
responsible party's sate expense to install monitoring equipment and deliver monitoring
data or reports to the Stormwater Coordinator as directed. The sampling and monitoring
equipment shall be maintained at all times in a safe and proper operating condition by the
responsible party at responsible party's sole expense, All devices shall be calibrated to
ensure accuracy.
5.6.4 Any temporary or permanent obstruction to safe and easy access to property to be
inspected and/or monitored/sampled shall be promptly removed by the responsible party
at the written or oral order of the Stormwater Coordinator and shall not be replaced. Alt
costs of clearing said obstruction shall be borne solely by the responsible party.
5.6.5 An unreasonable delay in allowing access of the Stormwater Coordinator to the
property is a violation of this Ordinance.
5.6.6 If the Stormwater Coordinator has been refused access to any part of the property
from which an illicit connection and/or illicit discharge to a municipal storm sewer is
occurring, suspected, or imminent, and is able to demonstrate probable cause to believe
that there may be a violation of this Ordinance, or that there is a need to inspect and/or
sample as part of a routine inspection and sampling program designed to verify
compliance with this Ordinance or any order issued hereunder, or to protect the overall
public health, safety and welfare of the community, then the Stormwater Coordinator
may see issuance of a search warrant from any court of competent jurisdiction.
5.7 If it is determined that there has been an illicit connection, or that an illicit discharge
is imminent or has occurred, the actual administrative costs incurred by the City in the
enforcement of this Ordinance shall be recovered from the responsible party. The
Stormwater Coordinator shall submit an invoice to the responsible party reflection the
actual costs, wages and expenses incurred by the City for the enforcement activities
undertaken. Failure to pay such charges invoiced under this Ordinance within thirty (30)
days shall constitute a violation of this Ordinance.
Section 6. Suspension of Access to the City Storm Sewer System.
6.1 Emergency suspension. The Stormwater Coordinator may, without prior notice,
suspend storm sewer system access to a property when such emergency suspension is
necessary to stop an ongoing or imminent illicit discharge. If the responsible party fails to
immediately comply with an emergency suspension order, the Stormwater Coordinator
shall take such steps as are deemed necessary to prevent or minimize the illicit discharge.
All costs of such actions shall be recovered from the responsible party for the property
identified as the source of the illicit discharge.

6.2 Non -emergency suspension. If the Stormwater Coordinator detects or is informed of
circumstances which could cause an illicit discharge but such illicit discharge is not
ongoing or imminent, and if the suspension of storm sewer system access would
reasonably be expected to prevent or reduce the potential illicit discharge, the Stormwater
Coordinator shall notify the responsible party of the proposed suspension. Notice to one
responsible party for the property shall be deemed sufficient notice to all property
owners. Remediation of the circumstances shall avoid a violation of this Ordinance
provided that no illicit discharge occurs. In the alternative, the responsible party may
request a meeting with the Stormwater Coordinator for the purpose of presenting
information which the responsible party believes will show that remediation is
unnecessary, and if the Stormwater Coordinator finds such information satisfactory, the
Stormwater Coordinator may rescind or modify the notice of suspension. If the
Stormwater Coordinator finds such information unsatisfactory, the Stormwater
Coordinator shall issue a final written order of suspension, including the date and time of
suspension. Such order may be appealed as provided hereinafter. Any physical action to
reinstate storm sewer access to property subject to such order prior to obtaining a court
order of relief shall be deemed a violation of this Ordinance. An order of suspension shall
not preclude charging the responsible party with a municipal infraction as provided
hereinafter or taking any other enforcement action permitted by statute, regulation, or
ordinance.
Section 7. Watercourse Protection. Every person or entity owning property through
which a watercourse passes, or such person's or entitles lessee, shall keep and maintain
that part of the watercourse within the property boundaries below the elevation of the 100
year flood free of trash, debris, grass clippings or other organic wastes and other
obstacles that would pollute, contaminate, or significantly alter the quality of the water
flowing through the watercourse. In addition, the owner or lessee shall maintain existing
privately owned structures within or adjacent to a watercourse, so that such structures
will not become a hazard to the use, function, or physical integrity of the watercourse.
Section 8. Enforcement.
8.1 Violation of any provision of this Ordinance may be enforced by civil action
including an action for injunctive relief. If there is any civil enforcement action,
administrative or judicial, the City shall be entitled to recover its attorneys fees and costs
from the person or entity who is determined by a court of competent jurisdiction to have
violated this Ordinance.
8.2 Violation of any provision of this Ordinance may also be enforced as a municipal
infraction within the meaning of the City's municipal infraction ordinance.
8.3 Enforcement pursuant to this section shall be undertaken by the Stormwater
Coordinator upon the advice and consent of the City Attorney.

Section 9. Appeals.
9.1 Administrative decisions by city staff and enforcement actions of the Stormwater
Coordinator may be appealed by the applicant to the city council according to the
following rules:
9.1.1 The appeal must be filed in writing with the City Clerk within five (5) business days
of the decision or enforcement action.
9.1.2 The written appeal shall specify in detail the action from which relief is desired, the
errors allegedly made by the Stormwater Coordinator giving rise to the appeal, a written
summary of all written and oral testimony the applicant intends to introduce at the
hearing, including the names and addresses of all witnesses the applicant intends to call,
copies of all documents the applicant intends to introduce at the hearing, and relief
requested.
9.1.3 The Stormwater Coordinator shall specify in writing the reasons for the
enforcement action, a written summary of all oral and written testimony the Stormwater
Coordinator intends to introduce at the hearing, including the names and addresses of all
witnesses he plans to call, and copies of all documents he intends to introduce at the
hearing.
9.1.4 The City Clerk shall notify the applicant and the Stormwater Coordinator by
ordinary mail., and shall give public in accordance with the rules of the State of North
Carolina of the date, time and location for the regular or special meeting of the city
council at which the hearing on the appeal shall occur. The hearing shall be scheduled for
a date not less than four (4) days, nor more than twenty (20) days after the filing of the
appeal. The rules of evidence and procedure, and the standard of proof to be applied shall
all be according to the State of North Carolina Administrative Code. The applicant may
be represented by counsel at applicant's expense. The Stormwater Coordinator may be
represented by the City Attorney or by another attorney designated by the City Manager,
and shall be at City's expense.
9.2 The decision of the city council shall be rendered in writing and may be appealed to a
higher court_