NCS000423_IDDE Program Plan_20220107

NORTH CARO LINA
High Performance Living
■■11111
City of Concord, North Carolina
Illicit Discharge Detection and
Elimination (IDDE) Program
Revision Date: December 2021
1IPage

Table of Contents
Section1: Introduction..................................................................................................................................3
1.1 Background.........................................................................................................................................3
1.2 Summary of the IDDE Program..........................................................................................................
3
Section 2: Storm Sewer System Map............................................................................................................
4
2.1 Overview.............................................................................................................................................
4
2.2 Mapping Procedures...........................................................................................................................
4
Section 3: Dry Weather Flows Program.......................................................................................................
5
3.1 Prioritization Schedule........................................................................................................................5
3.2 Responsibility.....................................................................................................................................
5
3.3 Timing.................................................................................................................................................5
3.4 Equipment...........................................................................................................................................
5
3.5 Inspection Procedures.........................................................................................................................
6
3.6 Follow -Up Actions..............................................................................................................................
7
Section 4: IDDE Investigation and Source Tracing......................................................................................
8
4.1 Purpose................................................................................................................................................8
4.2 Procedures...........................................................................................................................................8
4.3 Source Tracing..................................................................................................................................10
4.4 Follow -Up Actions............................................................................................................................10
Section 5: Categories of Non-stormwater Discharges and Flows...............................................................12
5.1 What is an Illicit Discharge...............................................................................................................12
5.2 What is an Illicit Connection............................................................................................................12
5.3 IDDE Ordinance...............................................................................................................................12
Section6: Public Reporting........................................................................................................................16
6.1 Notification and Reporting Procedures.............................................................................................16
6.2 Spill and/or Dumping Response Procedures.....................................................................................16
Section 7: IDDE Training for Municipal Staff...........................................................................................17
7.1 Training Program..............................................................................................................................17
7.2 Frequency and Implementation Schedule.........................................................................................17
Section 8: Record Keeping of IDDE Activities..........................................................................................18
8.1 Data Sources.....................................................................................................................................18
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Section 1: Introduction
1.1 Background
In 1972, the Clean Water Act created programs such as the National Pollutant Discharge
Elimination System (NPDES) permit program. The NPDES permit program regulates point
sources that discharge pollutants to all waterways throughout the United States, in order to
address the issue of water pollution. The Stormwater section of the NPDES program regulates
stormwater discharges from municipal separate storm sewer systems (MS4s), construction
activities, and industrial activities. MS4s are, by definition, a system of stormwater
conveyances that does not connect to the sanitary sewer system and therefore discharge directly
to waters of the United States. The City of Concord is a Phase II MS4 and is thus required to
obtain and maintain an NPDES permit.
The North Carolina Department of Environmental Quality (NCDEQ) has been delegated by
the EPA to administer the NPDES program throughout the state. The City of Concord's Phase II
MS4 Permit No. NCS000423 was issued by the NCDEQ in 2006. As part of this permit, the City
is required to address the topic of illicit discharges through the Illicit Discharge Detection and
Elimination minimum control measure. The City of Concord is obligated to establish and
implement an IDDE Program in order to satisfy this permit requirement. Permits are valid for a
period of five (5) years, after which the permittee must submit a permit renewal application and
successfully complete an audit conducted by the State.
The purpose of this program is to assist City personnel in identifying and remediating
observed illicit discharges within municipal limits. The following document provides details
about the program's operation and implementation, including investigation procedures, public
reporting tools, municipal staff training outlines, and other necessary program components. The
City of Concord's IDDE program is managed by the Water Resources Department, which
handles potable water, wastewater, and stormwater operations. This document was created to
help City of Concord employees properly and consistently implement the IDDE program.
1.2 Summary of the IDDE Program
The permit requires the City of Concord to develop and maintain a written IDDE program
that includes and/or addresses the following items:
❖ Provisions for program assessment and evaluation, and integrating program.
❖ IDDE ordinances that provide the legal authority to prohibit illicit connections and
discharges with appropriate enforcement procedures and actions
❖ Current map showing major outfalls and receiving streams.
❖ Dry weather flows program with written procedures.
❖ Written procedures for conducting investigations of identified illicit discharges.
❖ Municipal staff training.
❖ Education for public employees, businesses, and the general public about hazards
associated with illegal discharges and improper disposal of waste.
❖ Reporting mechanism for the public and staff to report illicit discharges, including
establish and implement citizen request response procedures.
❖ Mechanism to track the issuance of notices of violation and enforcement actions as
administered by the permittee, with the ability to identify chronic violators.
3 1 P a g e

Section 2: Storm Sewer System Map
2.1 Overview
The City of Concord is required to maintain a map showing all major outfalls and
receiving streams within municipal limits. The City currently utilizes and updates a GIS-based
map of all storm sewer system components throughout the City, including: inlets, pipes, culverts,
ditches, junction boxes, and receiving waters. The Stormwater Division plans to update this map
to include a more accurate, updated depiction of the system, including major outfalls and flow
direction of all stormwater pipes. The MS4 map is available to the public via the following link:
https:Hcnc.maps.arcgis.com/gpps/webgppviewer/index.html?id=4cd53261 cb7842eeal5beed2477
b8633
2.2 Mapping Procedures
The Senior GIS Coordinator for the City's Water Resources Department has divided the
map of Concord into 13 zones. The two GIS Technicians are currently remapping each section
one at a time. Additionally, the technicians map all storm sewer components of new subdivisions
and developments. This is done by using the Trimble R2 device to document the location of all
storm sewer system components. The data is then added to the overall stormwater GIS map. To
map receiving streams, the department relies on data provide by the state. The Stormwater
Division also has a GIS map of all SCM locations, showing which have been accepted, are in the
as -built phase, and are under construction. Currently, the division plans to update the GIS map to
include more accurate information of system components, specifically all major outfalls and flow
direction.
4 1 P a g e

Section 3: Dry Weather Flows Program
As part of the Dry Weather Flows Program, the City's major outfalls are inspected during
periods without rain to determine if an undesired flow is present. Observed flows during dry
weather conditions indicate a potential illicit discharge upstream within the system. These
discharges may be a result of illegal dumping activity, broken or damaged system components,
or other items that need to be identified and addressed. The following section details the outfall
inspection procedures and follow-up actions taken, should a dry weather flow be detected.
3.1 Prioritization Schedule
In 2004, the City of Concord contracted HDR Engineering, Inc. to conduct stream
assessments of portions of Irish Buffalo Creek, Threemile Branch, and Cold Water Creek. The
information collected during the assessments included biological, chemical, and elemental data
for each stream. Concurrently, City staff completed stream walks to identify and map all existing
outfalls. A total of 44 outfalls were identified across all three streams. The City's Stormwater
Division is currently working to update major outfalls along Coddle Creek, Wolf Meadow
Branch, and the other three assessed streams.
3.2 ResponsibilitX
Designated stormwater crews are the primary outfall inspectors for the Dry Weather
Flows Program. If an immediate and/or hazardous concern is identified during outfall
inspections, inspectors are to alert the proper group for additional assistance. These groups
include, but are not limited to, the City of Concord Fire Department, HAZMAT, and/or the
City's Risk Management Coordinator.
3.3 Timing
The City of Concord shall inspect at least 20% of all major outfalls each fiscal year, so
that all major outfalls are inspected once per permit term. These inspections shall be conducted
no less than 72 hours following any rain event.
3.4 Equipment
Prior to conducting outfall inspections, crews should become familiar with the outfall
locations and gather necessary equipment, including:
• Tablet — Camera, MS4 Outfall Map (GIS), & Inspection Form (GIS)
• Boots
• Safety Vests
• Weed Cutters
• Tape Measure
5 1 P a g e

3.5 Inspection Procedures
1. Identify and travel to the major outfalls that are scheduled to be inspected.
2. Access the GIS MS4 Outfall map used to track dry weather flow inspections.
3. Select the appropriate outfall on the map.
4. Click the link to access and complete the associated outfall screening form, which
includes the following information:
a. Outfall ID
b. Inspector Name(s)
c. Date and Time
d. Outfall Pipe Material (Concrete, PVC, Other)
e. Outfall Pipe Diameter
f. Submerged in Water
g. Observed Flow - (Y/N); If no flow is observed, skip to step g.
Flow Characterization:
i. Flow Velocity Description (trickle, moderate, substantial)
ii. Color and Clarity (e.g., clear, cloudy)
iii. Surfactants (e.g., suds, oil, grease)
iv. Abnormal Deposits (e.g., concrete runoff, dried paint)
v. Odor (e.g., sewage, gas)
vi. Confirmed Treated Water Leak
h. Surrounding Stream Conditions:
i. Color and Clarity (e.g., clear, cloudy)
ii. Surfactants (e.g., suds, oil, grease)
iii. Abnormal Deposits (e.g., concrete runoff, dried paint)
iv. Odor (e.g., sewage, gas)
i. Physical Indicators for Both Flowing and Non -Flowing Outfalls
i. Outfall Damage (e.g., cracks, corrosion, peeling paint)
ii. Deposits/Stains (e.g., oily, flow line, paint)
j. Attach Minimum of One (1) Picture
k. Additional Comments
5. Submit completed inspection form. If a dry weather flow is detected, or other outstanding
issues are observed, follow the procedures in the next section.
Note: If an illicit discharge is deemed unlikely to be discovered at the outfall (e.g., outfall is
submerged), investigators shall identify all storm drains near the reported discharge. He or she
will then utilize the Storm Sewer System GIS Map to analyze the storm drain network to identify
all nearby, connected drains. All upstream drains will be identified and subsequently inspected
for evidence of discharge.
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3.6 Follow-Un Actions
If an illicit discharge is identified during an outfall inspection, inspectors should inform
the System Protection Superintendent as soon as possible. The System Protection Superintendent
will then conduct an illicit discharge investigation, according to the procedures in Section 4.
If another issue is discovered during an inspection, such as a structural issue with the
outfall, the inspectors should note this on the inspection form and notify the Stormwater
Superintendent upon returning from the field.
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Section 4: IDDE Investigation and Source Tracing
4.1 Purpose
Illicit discharges are identified and reported by both citizens and municipal staff who
observe a non-stormwater substance entering and/or being dumped into the City's storm sewer
system. Discharges are also identified during MS4 inspection and screening activities. The City
provides the following methods to report such discharges, via phone or email:
• the 24/7 Call Center (704-920-5555);
• Stormwater Division (704-920-5360);
• System Protection Superintendent (704-920-5352)
In the event that another municipal employee receives an illicit discharge concern, he or
she is instructed to immediately notify the System Protection Superintendent with all relevant
details. Once a report is received, an investigation is conducted to identify the source of and
begin remediating the illicit discharge. This section describes procedures for conducting
investigations and tracing the source of illicit discharges to provide a uniform method for all City
investigators.
4.2 Procedures
The System Protection Superintendent is the primary investigator of illicit discharges.
The Water Resources Department Director is also contacted when an illicit discharge is reported,
and has the authority to investigate such reports. These positions and other City staff tasked with
investigating reported illicit discharges are to follow the procedures described below.
Investigation Procedures:
1. Once on -site, access the established internal IDDE tracking webpage
(hM2://water.coc/idpages/idhome) and login.
2. Fill out the associated form by clicking the "+" button in the table. This will open a new
investigation form.
Illicit Discharge Detection and Elimination
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3. Select the investigation location on the map and click "Load Selected Point" to autofill
the location information into the form.
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b. Initial Description: describe the reported illicit discharge
c. Suspected Source: if applicable
d. Date Reported
5. Click "Create" after filling in the initial information.
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6. Under the "Inspections" heading, click the "+" button in the table. Fill in the remaining
information:
a. Date and time of inspection
b. Inspector Name
c. Description of Discharge Observed/Site Conditions
d. Have clean-up and containment operations started? (Yes/No)
e. Did you communicate with site owner? (Yes/No)
f. Describe communication with owner, if applicable
9 1 P a g e

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8. Attach a minimum of two (2) photos of observed discharge/surrounding area by clicking
the "+" button under the "Photos and Documents" heading.
9. Click "Save"
10. Repeat steps 6 through 9 for any follow-up investigations.
4.3 Source Tracing
When a suspected illicit discharge is investigated or observed during an outfall
assessment, the investigator/inspectors are tasked with tracing the source of the issue. In some
cases, the source is not immediately evident or identifiable. The City of Concord primarily
utilizes storm sewer system tracing in order to find the source of illicit discharges in these
instances. All information collected should be logged through the City's online IDDE reporting
webpage.
The storm sewer system tracing method is the first process used when the source is not
apparent or immediately identifiable. This method involves analyzing the City's storm sewer
system GIS map. When a suspected discharge is discovered during an outfall assessment, the
inspector should note the outfall of concern and alert the System Protection Superintendent as
soon as possible. The System Protection Superintendent will then open an investigation and
identify, using the GIS map, all storm drains upstream of the outfall. He or she will then visit the
site of each storm drain identified, in order of proximity to the outfall. At each location, the
investigator will inspect the area for the potential source of the observed discharge. If no
discharge is identified, the next drain upstream will be inspected. The inspector or field crew
should work progressively upstream from the outfall, inspecting all manholes and storm drains
until it is found that either the discharge is no longer present, or the cause of the discharge is
discovered.
4.4 Follow -Up Actions
If the initial investigation does not result in the immediate remediation of the illicit
discharge, responsible parties will be required to communicate a plan of action to the System
Protection Superintendent within 10 days of the investigation date. Once a plan is submitted,
parties have 30 days to complete the corrective actions. The City shall be notified when clean-up
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has concluded so that a follow-up investigation may be done. Follow-up investigations are
completed via the same form as the initial investigation. If the illicit discharge is not properly
remediated within that time frame, an NOV will be issued and civil penalties will follow. All
NOVs will be documented within the IDDE investigation tracking site and copies saved to the
appropriate illicit discharge folder on the City's server. Alternatively, the City's Fire Department
and/or Code Enforcement officials will be contacted to assist in removal of the illicit discharge
and ensuring proper procedures are followed.
11 I Page

Section 5: Categories of Non-stormwater Discharges and Flows
5.1 What is an Illicit Discharge
An illicit discharge is defined by the City of Concord as anything not composed entirely
of stormwater that enters the storm drainage system. Examples of illicit discharges, listed in
Section 60.47 of the City Code of Ordinances, include:
• Oil and grease of petroleum or synthetic hydrocarbon origin
• Fats, oils, and grease of plant or animal origin
• Anti -freeze, parts cleaner, and other motor equipment fluids
• Chemicals, paints, pesticides, and other household hazardous wastes
• Animal waste, gray water and waste water from RV's and travel trailers
• Washdown water from concrete trucks, and floor mop water
• Garbage, litter, yard waste, and any other solid waste materials
• Contaminated washdown or drainage from dumpster drains
5.2 What is an Illicit Connection
An illicit connection is defined as any unapproved drain or conveyance which allows an
illicit discharge to enter the storm sewer system.' Examples of illicit connections, listed in
Section 60.47 of the City Code of Ordinances, include:
• Floor drains
• Wastewater from washing machines
• Wastewater from sanitary sewers
• Wash water from commercial vehicle washing or steam cleaning
• Wastewater from septic systems.
5.3 IDDE Ordinance
Specific text in sections from Chapter 6, Article IV (Stormwater Quality Control and
Management) of the City Code of Ordinances is shown below:
Sec. 60-47. Non-stormwater discharge controls.
(a) Illicit discharges. No person shall cause the commencement, conduct, or continuance of any
nonstormwater discharge to the stormwater conveyance system except as provided below.
(1) Nonstormwater discharges associated with the following activities are allowed:
a. Filter backwash and draining associated with raw water intake screening and
filtering devices;
b. Potable water line flushing and hydrostatic testing water associated with utility
operations;
c. Flushing and cleaning of stormwater conveyances with unmodified potable water;
' Adapted from the EPA's definition of an illicit discharge found in the agency's Model Illicit Discharge and
Connection Stormwater Ordinance document.
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d. Uncontaminated pumped groundwater and other discharges from potable water
sources such as water line leaks, draining for pipes for repairs, and emptying of
potable water storage tanks;
e. Landscape irrigation and lawn watering water;
f. Diverted stream flows;
g. Uncontaminated rising groundwater;
h. Groundwater infiltration to the storm drain system;
i. Uncontaminated groundwater from foundation and footing drains;
j. Uncontaminated groundwater from crawl space pumps;
k. Residential or commercial air conditioning condensation;
1. Uncontaminated water from roof drains;
in. Wash water from the cleaning of the exterior of buildings, including gutters,
provided that the discharge does not pose an environmental or health threat;
n. Uncontaminated groundwater from springs;
o. Individual residential and occasional non-commercial car washing;
p. Water from riparian habitats and wetlands;
q. Discharges from the pumping or draining of natural watercourses or waterbodies;
r. Filter backwash and draining associated with swimming pools provided that water
quality is not significantly impacted:;
s. Street wash water;
t. Flows from fire fighting;
u. Discharges associated with emergency removal and treatment activities, for
hazardous materials, authorized by the federal, state, or local government on -
scene coordinator; and
v. Other non-stormwater discharges for which a valid NPDES discharge permit,
waiver, or waste discharge order has been approved and issued by the State of
North Carolina under the authority of the Federal Environmental Protection
Agency, provided that:
1. The discharger is in full compliance with all requirements of the permit,
waiver, or order and other applicable laws and regulations;
2. Written notification of such permitted discharge has been filed with the
stormwater administrator, in a form acceptable to the stormwater
administrator; and
3. Discharges to the municipal separate storm sewer system have been
authorized by the stormwater administrator.
(2) Prohibited substances include, but are not limited to:
a. Oil and grease of petroleum or synthetic hydrocarbon origin;
b. Fats, oils, and grease of plant or animal origin;
c. Anti -freeze, parts cleaner, and other motor equipment fluids;
d. Chemicals, paints, pesticides, and other household hazardous wastes;
e. Animal waste, gray water and waste water from RV's and travel trailers;
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f. Washdown water from concrete trucks, and floor mop water;,
g. Garbage, litter, yard waste, and any other solid waste materials; and
h. Contaminated washdown or drainage from dumpster drains.
(3) With written concurrence of the North Carolina Department of Environmental Quality,
the city may exempt in writing other non-stormwater discharges, which are not a
source of pollutants to the storm water conveyance system or waters of the state.
(b) Illicit connections. Note: This regulation first became effective on December 13, 2007.
(1) The construction, use, maintenance, or continued existence of illicit connections to the
storm drain system is prohibited. Prohibited connections include, but are not limited to:
a. Floor drains,
b. Wastewater from washing machines,
c. Wastewater from sanitary sewers,
d. Wash water from commercial vehicle washing or steam cleaning, and
e. Wastewater from septic systems.
(2) This prohibition expressly includes, without limitation, illicit connections made prior
to the adoption of this provision or any other ordinance prohibiting such connections,
regardless of whether the connection was permissible under law or practices applicable
or prevailing at the time of connection. The property owner or the person using said
connection shall remove the connection within one year following the effective date of
this regulation; provided that the grace period shall not apply to connections which
may result in the discharge of hazardous materials or other discharges which pose an
immediate threat to health and safety, or are likely to result in immediate injury and
harm to real or personal property, natural resources, wildlife, or habitat.
(3) Where it is determined that said connection may result in the discharge of hazardous
materials or may pose an immediate threat to health and safety, or is likely to result in
immediate injury and harm to real or personal property, natural resources, wildlife, or
habitat; or was made in violation of any applicable regulation or ordinance, the city
manager or his designee shall designate the time within which the connection shall be
removed. In setting the time limit for compliance, the city shall take into consideration:
a. The quantity and complexity of the work;
b. The consequences of delay;
c. The potential harm to the environment, to the public health, and to public and
private property; and
d. The cost of remedying the damage.
(c) Waste disposal. No person shall throw, deposit, leave, maintain, keep, or permit to be
thrown, deposited, left, or maintained, in or upon any public or private property, driveway,
parking area, street, alley, sidewalk, component of the storm drain system, or waters of the
state, any refuse, rubbish, garbage, litter, or other discarded or abandoned objects, articles,
and accumulations, so that the same may cause or contribute to pollution. Wastes deposited
in streets in proper waste receptacles for the purposes of collection are exempted from this
prohibition.
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(d) Discharges in violation of industrial or construction activity NPDES stormwater discharge
permit. Any person subject to an industrial or construction activity NPDES stormwater
discharge permit shall comply with all provisions of such permit. Proof of compliance with
said permit may be required in a form acceptable to the city prior to or as a condition of a
subdivision map, site plan, building permit, or development or improvement plan; upon
inspection of the facility; during any enforcement proceeding or action; or for any other
reasonable cause.
(e) Spills. Spills or leaks of polluting substances discharged to, or having the potential to be
indirectly transported to the stormwater conveyance system, shall be contained, controlled,
collected, and removed promptly. All affected areas shall be restored to their preexisting
condition. Persons associated with the spill or leak shall immediately notify the City of
Concord Fire Chief or his designee of all spills or leaks of polluting substances. Notification
shall not relieve any person of any expenses related to the restoration, loss, damage, or any
other liability which may be incurred as a result of said spill or leak, nor shall such
notification relieve any person from other liability which may be imposed by state or other
law.
(Ord. No. 07-108, § 1, 12-13-2007; Ord. No. 21-19, § 2, 3-11-2021)
The remainder of the IDDE ordinance can be found at:
.municode.com/nc/concord/codes/code of ordinances?nodeId=PTIICOOR CH60
STUTCOMA ARTIVSTQUCOMA
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Section 6: Public Reporting
6.1 Notification and Reporting Procedures
Observed or suspected illicit discharges, illicit connections, and illegal dumping activities
are reported to the Stormwater Division in a variety of ways. The City operates a 24/7 call center
where citizens may report these issues. Once reported via the call center, the appropriate
stormwater staff are alerted. Staff and citizen's may also submit reports through the Stormwater
webpage, email, and/or direct phone calls to the Stormwater Division. All reports are
subsequently investigated by one or more of the following staff members: System Protection
Superintendent, Water Resources Director, Emergency Management Coordinator. Any
significant community impacts as a result of these investigated discharges will be communicated
to the public through various medias.
6.2 Spill and/or Dumping Response Procedures
In 2021, the City updated its general Spill Response Procedures as part of the Hazardous
Materials Annex. These procedures detail how staff are to respond to various types of spills,
including proper precautions and the appropriate personnel to contact in each situation. For illicit
discharges specifically reported to the Stormwater Division, the System Protection
Superintendent and/or Water Resources Director will determine if other agencies/departments
need to be involved. The table below provides contact information for departments that may
need to be contacted.
Agency
Contact Number
Police, Fire, EMS
911
Non -Emergency
Police
704-786-9155
Fire
704-782-2121
EMS
704-920-3000
Emergency Management
Office
704-920-5211
Direct
704-619-5833
Risk Management
704-920-5111
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Section 7: IDDE Training for Municipal Staff
7.1 Training Program
The City of Concord's Stormwater Division along with the Environmental Educator have
created a training video which discusses illicit discharges, illicit connections, and illegal
dumping. Topics covered are meant to inform municipal staff on how to identify an illicit
discharge and steps to report and/or correct the issue. This training video is made available to all
City of Concord coworkers via the City's Intranet website. After watching the full video, staff
are prompted to complete a digital form so that the division may track the number of trained
personnel.
7.2 Frequency and Implementation Schedule
City staff are required to be view this training video annually. All new employees will
also be required to view the training. The number of employees who view the video are recorded,
along with their name, department, and date of completion.
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Section 8: Record Keeping of IDDE Activities
The City of Concord's NPDES Phase II Permit requires comprehensive record keeping of all
stormwater program activities. Adequate records are key to maintaining a successful and
effective IDDE program. To improve the record system,
Digital records of the following information are managed and maintained by the City's
Stormwater Division:
• Outfall Inspections — maintain outfall inspection forms including photographs
• IDDE Investigations — retain investigation forms including photographs and
correspondence
• Actions Taken — information collected during investigations, copies of compliance
letters, correspondence with property owners and those at fault
• Training Documentation — training materials and list of participants
8.1 Data Sources
Outfall Inspections: Outfall inspections are tracked and recorded through the outfall
inspection form via Survey123. These inspections are automatically filed and saved digitally
through this application.
Investigations: All files associated with illicit discharge investigations are recorded and
saved using the City's internal investigation tracking program, available at
http://water.coc/idpages/idhome. This website shows inputs for all initial and follow-up
investigation reports. Additionally, a map of all reported and investigated illicit discharges is
available on this page. All other related files, such as NOVs and other correspondence, are saved
to the City's server under the appropriate IDDE folder.
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