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Illicit Discharge and Elimination (IDDE) Program Plan
City of Monroe - Stormwater
Illicit Discharge Detection and Elimination Manual
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January 2022
Illicit Discharge and Elimination (IDDE) Program Plan
Section1: Introduction ……………………………………………………………………...………………….2
1.1 Purpose ………………………………………………………………………………………..2
1.2 NPDES Phase II Permit Requirements …………………………………………………….2
1.3 Goal and Objectives ……………………………………………………………………….3
Section 2: Identification of Illicit Discharges ………………………………………………………………4
2.1 Allowable Discharges of Non-Stormwater ……………………………………………..4
2.2 Service Requests …………………………………………………………………………….5
2.3 Emergency Response ……………………………………………………………………...5
2.4 Education and Outreach …………………………………………………………………6
2.5 Public Involvement …………………………………………………………………………6
2.6 Facility Inspections ………………………………………………………………………….7
Section 3: Stormwater System Map …………………….……………….………………………………….7
3.1 Major Outfall Inventory …………………………………………………………………….7
3.2 Personnel ……………………………………………………………………………………..8
Section 4: Dry Weather Flow Inspections ………………………………………………………………….8
4.1 Inspection Procedures ……………………………………………………………………..8
4.1.1 Before Inspection ……………………………………………………………………………8
4.1.2 During Inspection ……………………………………………………………………………8
4.1.2.1 Evaluation Guidance ………………………………………………………………………9
4.1.3 Post Inspection ………………………………………………………………………………13
Section 5: Tracking Illicit Discharge and Connections …………………………………………………13
5.1 Record keeping to a source ...……………………………………………………...……13
5.2 On-Site Inspections ……………………………………………………………………...….13
5.3 Illicit Connection Procedures ……………………………………………………………..14
5.4 Removing Illicit Discharge …………………………………………………………………14
Section 6: Eliminating Sources of Illicit Discharge and Connections ………………………………...15
6.1 Purposes ………………………………………………………………………………………15
6.2 Procedures & Conducting Investigations of Identified Illicit Discharge ………….15
6.3 Identify the Responsible Party …………………………………………………………….16
6.4 Unknown Spillers ……………………………………………………………………………..16
6.5 Issuing a Notice of Violation ………………………………………………………………16
6.6 Documentation Review and Mailing ……………………………………………………17
6.7 Follow up Investigations ……………………………………………………………………18
6.8 Enforcement Procedures ………………………………………………………………….18
Section 7: Program Evaluation ………………………………………………………………………………18
Appendix A: Sample Forms ………………………………………………………………………………….19
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Illicit Discharge and Elimination (IDDE) Program Plan
Section 1: Introduction
1.1 Purpose
This manual is designed to define illicit discharge, the areas of concern with the City of Monroe
corporate limits, the procedures to be followed during dry weather outfall evaluations and illicit
discharge investigations, and the enforcement procedures as laid out by the City of Stormwater
Management Ordinance. This manual is designed to define procedures to follow during dry
weather outfall evaluations, illicit discharge investigations and the enforcement procedures
stated in Part II, Section D of the Phase II NPDES Storm Water Permit (Permit No. NCS000482)
issued to the City of Monroe.
The City of Monroe Stormwater Management Ordinance became effective October 1, 2007.
This ordinance establishes the legal authority to prohibit illicit connections and discharges,
defines illicit discharges and connections, prohibited discharges, and allowable non-stormwater
discharges.
1.2 NPDES Phase II Permit Requirements
Illicit Discharge Detection and Elimination is one of the six minimum measures required by the
City of Monroe’s National Pollutant Discharge and Elimination System (NPDES) Phase II
Stormwater Permit as issued by the North Carolina Department of Environmental Quality
(NCDEQ). This minimum measure requires the City of Monroe to implement and enforce a
program to detect and eliminate illicit discharges into the MS4. To accomplish this objective, the
City of Monroe is to maintain a written Illicit Discharge Detection and Elimination Program.
Best Management Practices of the active permit.
BMP Measurable Goals
a. Maintain an Illicit Discharge Maintain a written Illicit Discharge Detection and
Detection and Elimination Elimination Program, including provisions for program
Program assessment and evaluation and integrating program.
b. Maintain adequate legal The permittee shall maintain an IDDE ordinances or
authorities other regulatory mechanisms that provides the legal
authority to prohibit illicit connections and discharges.
c. Maintain a Storm Sewer The permittee shall maintain a current a map showing
System Map of Major Outfalls. major outfalls and receiving streams.
d. Implement a program to The permittee shall maintain a program for conducting
detect dry weather flows dry weather flow field observations in accordance with
written procedures.
e. Investigate sources of 1 The permittee shall maintain written procedures for
identified illicit discharges. conducting investigations of identified illicit discharges.
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Illicit Discharge and Elimination (IDDE) Program Plan
BMP Measurable Goals
f. Track and document 2 For each case the permittee shall track and
investigations illicit discharges document 1) the date(s) the illicit discharge was
observed; 2) the results of the investigation; 3) any
follow-up of the investigation; and 4) the date the
investigation was closed.
3
g. Provide Employee Training The permittee shall implement and document a training
program for appropriate municipal staff, who as part of
their normal job responsibilities, may come into contact
with or otherwise observe an illicit discharge or illicit
connection.
h. Provide Public Education The permittee shall inform public employees, businesses,
and the general public of hazards associated with
illegal discharges and improper disposal of waste.
i. Provide a public reporting 4 The permittee shall promote, publicize, and
mechanism facilitate a reporting mechanism for the public and
staff to report illicit discharges and establish and
implement citizen request response procedures.
5
j. Enforcement of the IDDE The permittee shall implement a mechanism to track
ordinance the issuance of notices of violation and enforcement
actions as administered by the permittee. This
mechanism shall include the ability to identify chronic
violators for initiation of actions to reduce
noncompliance.
1.3 Goals and Objectives
The goal of the City of Monroe’s Illicit Discharge Detection and Elimination (IDDE) Program is to
find and eliminate illicit discharges of pollution and restore the quality and usability of the City of
Monroe surface water resources.
The objectives to meet this goal are:
• Detect and eliminate illicit discharges, including preventable spills and illegal
dumping to the Municipal Separate Storm Sewer Systems (MS4s) within the City of
Monroe.
• Address significant contributors of pollutants to the MS4s.
• Implement appropriate enforcement procedures and actions.
• Develop and maintain a map showing the major MS4 outfalls to the Waters of the US
receiving discharges.
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Illicit Discharge and Elimination (IDDE) Program Plan
• Inform employees, businesses, and the general public of hazards associated with
illegal discharges and improper disposal of waste.
Section 2: Identification of Illicit Discharges & Illicit Connections
Phase II of the Stormwater Management Ordinance states that any liquid, solid, gas, or other
substance, other than stormwater that is permitted to go into a stormwater conveyance or
waster of the US is considered an illicit discharge.
2.1 Allowable Discharges of Non-Stormwater
Stormwater is the only discharge permitted in the Stormwater System of the Waters of the State
with exception of the following allowable incidental non-stormwater discharges: provided that
said discharges do not negatively impact surface water quality. Allowable incidental non-
stormwater discharges include:
1. Water line flushing and fire hydrant flushing
2. Landscape irrigation;
3. Diverted stream flows;
4. Uncontaminated groundwater infiltration;
5. Uncontaminated pumped groundwater;
6. Rising ground waters;
7. Discharges from Uncontaminated Potable Water sources;
8. Foundation drains;
9. Air conditioning condensate (residential/commercial);
10. Irrigation water;
11. Springs;
12. Crawl space pumps;
13. Footing drains;
14. Lawn watering;
15. Residential and charity car washing;
16. Flows from riparian habitats and wetlands;
17. De-chlorinated swimming pool discharges;
18. Street wash water;
19. Flows from firefighting activities
2.2 Service Requests
Most illicit discharges and connections are identified through Citizen’s calling or emailing. The
general public indicates potential stormwater pollution that needs investigation. City of
Monroe response to these requests is extremely important not only from a customer service
standpoint, but also from a Health, Safety and Environmental standpoint. All staff members
receive on the job training regarding responses to service requests and providing proper
customer service.
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Illicit Discharge and Elimination (IDDE) Program Plan
2.3 Emergency Response
City of Monroe receives and average of three reports annually that require staff to respond to
spills emergencies that threaten surface water quality. The purpose of the Emergency
Operation Plan is to ensure that detailed response procedures are in place and that staff are
properly trained and prepared to effectively and efficiently respond to emergencies so that
pollution sources can be quickly eliminated and negative water quality impacts minimized.
Emergency Contacts
Agency to Notify Contact Information
Union Co. Emergency Management 704-289-1591
Union County Emergency Management Coordinator 704-283-3575
Union Co. Environmental Health 704-283-3553
NC Department of Environmental Quality,
Mooresville Regional Office 704-663-1699
North Carolina Division of Water Quality 919- 807-6308 Monday –Friday
Raleigh, NC Emergency Management 8 AM- 5 PM
800- 858-0368 24 hr. Hotline
National Response Center 800-424-8802 24 hr.
EPA Region 4 Emergency Response Spill Report 404-562-8700
Hotline, Atlanta, GA
EPA Region 4 Emergency Response and Removal 800-564-7577
Branch
North Carolina Hazardous Waste Section 919 -508-8400 For guidance on
disposal
Poison Control, if applicable 800-222-1222
Stormwater Compliance Coordinator 704-282-4535
Stormwater Engineer 704-282-4537
2.4 Education and Outreach
The Stormwater ongoing public education campaign targets business and residents in the City
of Monroe. For residents, the campaign seeks to increase public awareness of illicit discharges
and connections, the negative impact on quality of life, and how to report suspected
stormwater pollution problems. A broad range of education activities and media outlets are
utilized in this campaign, including printed advertisements, social media, newsletters, postcards,
brochures and flyers, utility bill inserts, in-person presentations for schools and community
organizations, and attendance at special events. . In addition, TV and radio ads are utilized
through the Regional Stormwater Partnership of the Carolinas, which the City of Monroe is a
member of. For more detailed procedures related to the public education programs please see
Public Education SOP (Appendix Eng 3341 and Eng 3342 )
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Illicit Discharge and Elimination (IDDE) Program Plan
The public education program not only targets specific identified primary pollutants such as
sediment and bacteria, but it is also equipped to provide education on numerous pollution
issues common to various land uses and specific times of year. For example, during the fall, the
social media campaign highlights how to properly dispose of leaves without impacting the storm
drain system. There are also numerous education materials available to staff and the public on
the City of Monroe website regarding best management practices for a variety of topics such as
swimming pool maintenance, lawn debris disposal, car washing, etc.
Each year, City of Monroe conducts training, education and outreach targeting internal
municipal employees of the City. Education includes information about common illicit
discharges and how to report them. This outreach is performed via in-person presentations,
online training, and internal campaigns. For more detailed procedures related to City of
Monroe’s Employee Training, see ????.
2.5 Public Involvement
The Public Involvement Program engages individuals, families, organized groups, schools,
businesses and industries in the City of Monroe in activities that help protect and restore surface
water resources, including the identification of illicit discharges and connections and how to
report them. These include the following three (3) volunteer programs.
• Adopt-A-Stream
• Storm Drain Marking
• Water Monitoring
A detailed description of these programs can be found in the Public Involvement SOP ENG 3350
Public Involvement
The Adopt-A-Stream Program engages volunteers to “Adopt” stream sections that are typically
quarter of a mile in length. Each volunteer group is responsible for walking their adopted stream
section at minimum of two (2) times a year during which time volunteers remove trash and
debris from the stream and look for illicit discharges.
The Storm Drain Marking Program engages volunteers to apply decals on storm drain hoods that
read “Do Not Dump-Drains To Creek” in both English and Spanish. When applying these decals,
volunteers check the storm drain for dry weather flow or evidence of illicit discharge or
connection. Observations are reported to Stormwater Staff for follow up and the initiation of the
necessary corrective actions.
2.6 Facility Inspections
City of Monroe inspects and conducts monitoring of stormwater discharges locations at
municipal facilities in the City of Monroe to evaluate operations, identify pollution problems
and/or illicit discharges, to assist with pollution prevention and to ensure compliance with Phase
II Storm Water Permit requirements. Facilities are selected for inspection and monitoring based
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Illicit Discharge and Elimination (IDDE) Program Plan
on their potential to cause negative water quality impacts and NPDES industrial stormwater
permit monitoring requirements. Facility inspections include a detailed records review, and on-
site inspection, evaluation of discharge locations and completion of comprehensive inspection
reports. For more detailed procedures related to these inspections, please see the Phase II
Pollution Prevention and Good Housekeeping Inspection Program SOPs (Appendix
Eng 3372)
The Stormwater drainage system with the City of Monroe corporate limits, including major outfall,
are mapped using ArcGIS. ArcGIS shows approximately 110 miles of storm drainage pipe,
approximately 2,076 Drainage structures and approximately ______ Outfalls (______of which are
considered major outfalls). This map is maintained and updated periodically by City employees
and can be used in tracking illicit discharges.
Section 3: Mapping
3.1 Major Outfall Inventory
Major outfalls are tracked via ArcGIS in the Stormwater Database on the City Arc GIS server.
Outfalls are tracked under the Stormwater_Outfalls feature layer. A separate feature layer has
been created to Outfall Reconnaissance Inventory. If new Major Outfalls are added or updated
by field personnel in either of these feature layers, it is the responsibility of the Stormwater
Engineering Technician to make sure they are both updated and accurate.
3.2 Personnel
The Stormwater Engineering Technician and the City GIS personnel are responsible for
maintaining Stormwater infrastructure GIS database and maps. Properly trained personnel with
ArcGIS Collector app access frequently update inventory from the field and track infrastructure
conditions.
Section 4: Dry Weather Flow Inspections
Major outfalls (outfalls that are 36 inches or greater, or serve a drainage area of more than 50
acres for residential area and 12 inches or greater, or serve a drainage area of more than 2
acres for non-residential area) are to be inspected at least once during the 3-year permit cycle
(one watershed per year). Major outfalls are to be evaluated ideally during a period of at least
72 hours without rainfall. The objective of these inspections is to identify discharges from a
stormwater outfall during a period without rainfall and to characterize observed discharges and
facilitate the detection of illicit discharges.
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Illicit Discharge and Elimination (IDDE) Program Plan
4.1 Inspection Procedures
The City’s watersheds are placed on a 3-year cycle. Due to their size within the City, East Fork –
Twelve Mile Creek watershed and South Fork-Crooked Creek watershed are inspected during
the Richardson Creek watershed stream inspection. The City’s watersheds are inspection by
private engineering consultant. The Engineering consultant shall inspect the outfalls within each
watershed in accordance with Center for Watershed Protection IIDE Manual.
The Stormwater Engineering Technician staff shall preform random inspection of outfalls based
on land use and information received from the Stormwater Hotline.
4.1.1 Before Inspections
Outfall inspections shall be conducted by teams of at least two (2) employees. If the
outfall is on private property, notify the property owner either in writing, by phone, or in-
person before entering the property. When conducting a dry weather flow outfall
inspection, employees performing the inspection should ensure they have the following
materials before they leave to conduct inspections:
• I pad or Mobile device equipped with ArcGIS Collector App
• Flashlight
• Measuring Tape
• Water Sampling Kit
• High Visibility Vest
• Protective footwear
• Proper ID
4.1.2 During Inspections
Inspections are to be completed digitally via Survey123 following the below steps (a
sample of the inspection form can be found in Appendix Eng 3366.
1. Open the Web Map for Stormwater: Major Outfalls in the Arc Collector App on a
mobile device
a. If the device does not have the Collector App, navigate to the internet browser
and open the Web Map from ArcGIS Online
2. Select the facility/operation you would like to inspect to activate the Pop-Up
Window
3. Within the Pop-Up Window, follow the link ‘Go to Facility Inspection Form in
Survey123 App’
a. If the device does not have the Survey123 app downloaded, follow the link ‘Go
to Facility Inspection Form on Survey123 Website’ to open in a browser
4. Digitally Complete Form Fields
5. Have paper inspection form in case if issues develop with GIS system while in the
field.
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Illicit Discharge and Elimination (IDDE) Program Plan
4.1.2.1 Evaluation Guide
Before beginning the evaluation, complete the background information
section of the “Outfall Inspection” form then work through the below
inspection fields.
1. Outfall ID
This is the OBJECTID in the City of Monroe ArcGIS map. This field will
automatically populate when the Survey is opened through the ArcGIS
Collector pop-up window.
If the outfall was just created, it will not have an Outfall ID. A unique identifier
should be assigned to it using the following naming convention. The first two
digits will be the watershed abbreviation name. The next three or four digits
will refer to the city grid system. The next three digits will be the outfall number
series. The last digit will identify if the outfall is either a closed pipe (P) or open
ditch (D) Outfall ID=BC14D016P
Example of outfall ID number: BC14D016P
BC – Bearskin Creek watershed
14D – City grid system
016 – Outfall number series
P – closed pipe
O – Open Drainage
2. Today’s Date
The date of the outfall evaluation.
3. Form Completed By
Name of the employee completing the evaluation. If the evaluation is being
completed by a team, use the name of the team leader.
4. Time
The time the employee or team leader arrived at the outfall.
5. How long since last rainfall
Check the box that corresponds with approximately how many days it has
been since the last rainfall event. Outfall evaluations are ideally completed 3
days after the last rainfall event and should not be completed when it is
actively raining.
6. Location notes
Note: what drains to the outfall or what the outfall is located near such as
neighborhoods, communities, business parks, commercial areas, businesses,
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Illicit Discharge and Elimination (IDDE) Program Plan
construction activities, etc. that may have an impact on the outfall or that
you believe is applicable to the evaluation.
Once you have arrived at the outfall’s location and have completed the
background information section, complete the section of the Outfall
Evaluation Form, “Outfall Description”.
1. Pipe material
Check the box that corresponds with the material of the pipe outfall. RCP =
Reinforced Concrete Pipe, CMP = Corrugated Metal Pipe, HDPE = High-
density Polyethylene (appearance of black corrugated plastic pipe), PVC,
Steel, or choose other if none of the available options match the actual
outfall pipe material.
2. Pipe Diameter
Measure the diameter of the pipe from one side to the direct opposite side of
the pipe and record the number in inches. If the pipe diameter information is
available on the ArcGIS system you can record that number on the form and
verify it during the evaluation.
3. End of Pipe Flows Into
Mark the box that corresponds with the feature that the pipe outfall
discharges into (roadside or open ditch, stream, lake, wetland, or other.
Other may include SCM such as a wet detention pond or bioretention area).
4. End of Pipe Condition
Mark the box that corresponds with the apparent condition of the pipe
outfall. If the pipe is clear of debris and is in good structural condition so that
water can run freely through the outfall, mark “Open”. If the pipe is clogged
with debris or sediment so the flow of water through the pipe is impeded,
mark “Closed/Clogged”. If the pipe is crushed or damaged, mark “Crushed”.
If you marked either “Closed/Clogged” or “Crushed”, estimate the fraction
that the pipe is crushed or closed (i.e. if the pipe is 2/3 full of debris, note 2/3
for fraction closed/clogged/crushed).
After completing the Outfall Description section, complete the section
“Physical Indicators”. In this part of the outfall evaluation, determine if any
physical indicators of an illicit discharge are present. Check the outfall
structure for any evidence of stains, deposits, changes in vegetation around
the outfall structure, and structural damage. If there is water flowing from the
outfall structure, check the water coming from the outfall structure for signs of
an illicit discharge (color, odor, turbidity, floatable matter, grease, oil, etc.).
Use the questions in this section to determine if an illicit discharge is present. If
at any point during the investigation Stormwater Engineering Technician(s)
believe there is an illicit discharge present, and there is water actively
discharging from the outfall, use the Water Sampling Kit at your disposal to
determine if the water flowing from the pipe falls within acceptable levels for
the tests being performed.
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Illicit Discharge and Elimination (IDDE) Program Plan
Table 1: Allowable Range/Limits for select chemical parameters
Chemical Allowable
Parameter Range/Limit
pH ≤5
Temperature
Dissolved Oxygen
Ammonia ≥50 mg/L
Conductivity ≥2,000 µS/cm
Follow the directions in the handbooks equipped in the water sampling kit for
the Hach Pocket Pro pH & temperature tester to conduct relevant tests.
1. Water flowing from the end of the pipe
Check the box for “Yes” if there is water coming from the end of the pipe and
“No” if there is not. If there is water coming from the end of the pipe,
determine if the water is clear, muddy or colored (and describe the color of
the water in the space provided) and check the appropriate box. If the
water is colored or muddy, also mark the box under results for “Evidence of
Illicit Discharge”.
2. Evidence of petroleum products
If there is evidence of petroleum products in the water coming from the end
of the pipe or in the area surrounding the outfall, it may be evident by a
sheen on the water. If Stormwater Engineering Technician(s) believe there is
evidence of petroleum products in the water or area around the outfall,
describe what you see in the space provided. If there is evidence of
petroleum products, also mark the box under results for “Evidence of Illicit
Discharge”.
3. Is there an odor present?
Determine if there is an odor present around the outfall structure or if there is
water actively flowing from the outfall, if the water has an odor and check
the applicable box. If there is an odor present, describe the odor. Examples
of an odor include: decaying products, rotten eggs, spoiled milk, yeast, a
burning odor, sweet or flowery, gas or petroleum. If an odor is present, also
mark the box under results for “Evidence of Illicit Discharge”.
4. Floatables present
Examine the end of the pipe, the outfall structure and the area the pipe
discharges into for any floatables. Floatables include: paper, grease, suds,
oils, grease, etc. If you note the presence of toilet paper in or around the
outfall, immediately contact the Water Sewer Maintenance Supervisor. If
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there are floatables present, also mark the box under results for “Evidence of
Illicit Discharge”.
5. Sediment and/or debris in the end of the pipe
Note if there is any sediment or debris (branches, leaves, trash, etc.) in the
pipe outfall or surrounding area. If there is, check the box for “Yes” and then
describe what is in the pipe (trash, sediment, leaves, etc.) and the fraction of
the pipe that is full of sediment or debris (i.e. if the bottom third of the pipe is
full, note in 1/3 in this section).
6. Staining or growths on the pipe
Examine the outfall structure and look for any staining, deposits or growths on
or around the outfall. This may include: colored crystals, salt crystals, brown or
black stains, powders, etc. If there are any stains, growths or deposits on the
outfall pipe or structure, check the box for “Yes” and then describe what is
present. If there is evidence of stains or growths, also mark the box under
results for “Evidence of Illicit Discharge”.
7. If the pipe flows into a ditch or a ditch is nearby
Check the box that corresponds to the condition of the ditch regarding
sediment and debris. If there are sediment deposits or trash within the ditch,
depending on the amount of sediment and debris may either need to be
monitored or need maintenance. Check the box that corresponds to the
state of the vegetation within the ditch. If the vegetation is dying or appears
unhealthy (keep in mind that winter months may cause vegetation to appear
as though it is dying when it may be dormant), check the box that
corresponds with “yes, needs maintenance”. Also, some ditches are not
designed to have vegetation (i.e. concrete ditches or riprap lined ditches)
and so in this instance, check the box that corresponds with “No”.
8. Erosion occurring at the end of the pipe
If there is erosion occurring under and/or around the end of the pipe or in the
ditch or waterbody that the pipe discharges into, mark the box that
corresponds with “Yes” and describe the location and extent of the erosion
present. If there is erosion occurring at the end of the ditch, also mark “Yes”
under Results and Maintenance Needed. If no erosion is visibly present, mark
“No”.
9. Description of any other visible issues
Describe any other visible issues Stormwater Engineering Technician(s) may
see in the outfall or in the surrounding area. This may include any other
information you believe will give a clearer picture of the outfall or the
surrounding area that may contribute to the state of the outfall. Include
description of the state or the riprap (if riprap is present at the outfall) and
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Illicit Discharge and Elimination (IDDE) Program Plan
note if the riprap has been displaced or needs to be replaced, and if there is
any structural damage to the outfall.
10. Take photos of the outfall and surrounding area.
If Stormwater Engineering Technician(s) have marked the box “Yes” for any
category, make sure to take photographs that clearly show the physical
indicator. Photos may be taken directly from the Survey123 app or selected
from the camera roll on the device.
Complete the results section by checking the box for either “No” or “Yes”
under evidence of an illicit discharge. If Stormwater Engineering
Technician(s) check the box for “Yes”, immediately begin investigating the
illicit discharge using the Illicit Discharge Report Form and/or Illicit Discharge
Tracking Form available in Survey123. If the employee requires additional
assistance to conduct the illicit discharge investigation, the employee should
contact the Stormwater Compliance Coordinator. Stormwater Engineering
Technician(s) should not leave the site of an active illicit discharge.
If the outfall or outfall area requires maintenance (read back over the survey
before submitting and if you have marked any box that corresponds with
needs maintenance), check the box for yes here and submit the survey to the
Stormwater Engineer.
4.1.3 Post Inspections
1. If edits need to be done after the inspection form has been submitted, this can be
done on the Survey123 website.
a. My SurveysSelect SurveyDataSelect inspection record from table Edit This
RecordMake necessary changesSubmit
2. Export Inspection to Template Form
a. Select RecordReportCheck box for ‘Selected Records Only’Choose Template
from DropdownChange report name accordinglyGenerate
3. Save PDF of Outfall Evaluation Form
a. Completed evaluation form should be saved on the appropriate file in the I: drive
under the Inspection year subfolder within the Dry Weather Flow Observations folder.
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Section 5: Tracking Illicit Discharges and Connections to a Source
When an Illicit discharge, connection, or pollution problem has been detected, actions must be
taken to determine the source. This section describes the various techniques used by City of
Monroe to track illicit discharges to a source.
5.1 Records Keeping
To confirm the source of an illicit discharge or connection, a review must be conducted. This
includes identifying the search area and any obvious pollution sources that are immediately
upstream of the discharge.
Staff first starts the review by locating the storm drainage system and assessing aerial photos of
properties upstream of the illicit discharge or connection. This information is accessed primarily
through the City’s Geographic Information System (GIS) tool.
5.2 On-Site Inspections
Once the review process is complete, staff inspects the area around and upstream of the
discharge, connection or pollution problem to narrow the search area and locate the sources.
On-site inspection requires the use of various equipment that may include but not limited to:
• Collector for data entry and taking photographs;
• Visual inspection of the water
• (Device name?) to collect field measurements for dissolved oxygen, temperature,
pH, turbidity, and conductivity;
• Bottles for collection of laboratory samples;
• Safety equipment includes waders, boots, gloves, hard hat, safety vest, etc.;
• Tape measures to measure pipe sizes and estimate flow rates
The following general procedures are followed during On-site Inspections:
1. Identify the search area upstream of the illicit discharge or connection.
2. Travel to the location of the discharge or connection and determine if an active
discharge is occurring.
3. Conduct a site visit to search the area via driving or walking the area. Make note of all
businesses, industries and other activities that may be a potential pollution source.
Check the storm drains of discoloration and the presence of dry weather flow. Make
note of anything suspicious such as an accumulation of drums, stained soil, and unusual
odors. If a pollution source is confirmed during the site visit, immediately undertake
corrective measures.
4. If the site visit fails to confirm a pollution source, but a potential source was identified
during investigation, initiate an on-site inspection at this potential source.
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5. If the site visit and investigation failed to confirm or identify a pollution source, then on-
site inspection activities should begin at the most downstream location where the
pollution problem(s) was identified which will usually be in a stream or lake. Staff use field
observations or short-term monitoring measurements to work their way upstream until the
source is confirmed. By starting at the most downstream end, stormwater engineering
technician(s) avoid contaminating samples or instructing visual observations caused by
the sediment disturbance and plum from walking in stream.
6. If the pollution source is confirmed as a result of this inspection, immediately undertake
corrective measures.
Visual field observations are often a very effective tool for identifying pollution sources when a
continuous discharge is occurring. If field observations are unsuccessful, short-term monitoring
with the Hach Pocket Pro pH & temperature tester to measure pH, temperature, dissolved
oxygen and conductivity. Staff begins as the confirmed discharge point or connection and
record field measurements at regular intervals (typically every 100 feet) while moving upstream.
5.3 Illicit Connections Procedures
An illicit connection is a connection to the stormwater drainage system that are not approved
by the City of Monroe or that discharge non-stormwater to the stormwater drainage system.
Connections to a stormwater conveyance or stormwater conveyance system that allow the
discharge of non-stormwater are not permitted per the Stormwater Management Ordinance. If
an illicit connection is discovered, the Stormwater Compliance Coordinator or their
representative will track the connection back to its source.
Once the illicit connection is determined, the Stormwater Compliance Coordinator will follow
the procedures detailed in the Phase II Stormwater Management Ordinance to determine the
action required by the owner of the illicit connection.
5.4 Removing Illicit Discharges
Spills or leaks of polluting substances released, discharged to or having the potential to be
released or discharged to the stormwater conveyance system, are to be collected, contained,
collected and properly disposed. All areas affected by spill or leak are to be returned to their
pre-existing condition. The person in control of the polluting substance is to contact the City of
Stormwater Compliance Coordinator of the release or discharge as well as making any
notifications required by State or Federal Law. Per the Phase II Stormwater Management
Ordinance, illicit discharges or illicit connections are determined to be dangerous to public
health or Public safety, and are detailed to be public nuisances. These public nuisances are to
be abated in accordance with the procedures detail in the City Code of Ordinances.
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Section 6: Eliminating Sources of Illicit Discharges and Connections
When a suspected illicit discharge is reported, an investigation of the suspected illicit discharge
will be conducted within two (2) business days of the report by the Stormwater Compliance
Coordinator or their designee. The individual who received the illicit discharge report will
provide background information for the creation of the Illicit Incident Tracking Form.
6.1 Purpose
The purpose of eliminating the source of illicit discharge and/or connection is to remove a
source of pollution and restore water quality conditions. This section contains the procedures for
conducting investigation of identified discharges to eliminate the pollution source.
6.2 Procedures of Conducting Investigations of Identified Illicit Discharges
The below procedures are followed when investigating illicit discharges for elimination as
described in more detail in the following sections.
1. Identifying the responsible party.
2. Issue initial letter followed by Notice of Violation (NOV).
3. Conduct follow up investigation to ensure compliance.
4. Initiate enforcement actions in accordance with established criteria or standing
operating procedure.
5. Completed all documentation.
6.3 Identify the Responsible Party
The first step to eliminate the source of a pollution problem, illicit discharge and/or connection is
to identify the responsible person and provide them with initial notice letter to address the illicit
discharge. The initial notice letter shall include a timeframe to the party responsibly to address
the illicit discharge. If person responsible does not address the ililicit discharge within the time
frame in the letter, the City of Monroe will provide them with a “Notice of Violation” or NOV. The
responsible person is required by State and local laws to immediately cease the discharge, illicit
connection and/or illegal dumping and take whatever steps that are necessary to restore the
affected area and prevent future discharges from occurring. Local and State regulations
specify that the responsible person is to one who caused the discharge or connection to occur.
A “person” is defined as any individual, partnership, co-partnership, firm, company, corporation,
association, commission, institution, utility, Joint Stock Company, trust estate, governmental
entity or other legal entity, or their legal representative, agents or assigns.
In most cases, the property owner is the responsible person, but not in all cases. For example, in
a situation where an illicit discharge originates from rental property, the renter, not the owner of
that property, is responsible if the renter caused the discharge to occur. It is extremely important
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to collect as much information as possible regarding the responsible person during the field
investigation. For example, be sure to interview witnesses and obtain license tag numbers,
names, addresses, etc. If the property owner is the responsible party, confirm the name and
address using Union County Deed Look up and / or North Carolina Secretary of State
Corporation webpage.
6.4 Unknown Spillers
Investigating staff is responsible for interviewing other agency representatives at the scene of an
illicit discharge, as well as by-standers, neighbors or other parties that are possible witnesses to
the incident in order to obtain as much information as possible regarding the responsible party.
This task is second in priority only to efforts to ensure that the discharge has been ceased and all
spilled materials properly contained. If the responsible person cannot be identified after all
reasonable efforts have been undertaken, a contractor can be contacted to perform the
necessary cleanup. The Stormwater Engineer must approve the contractor prior to issuance of
authorization to proceed. Investigating staff must remain on-scene and supervise all cleanup
activities.
When a responsible party cannot be identified, the investigating staff is also responsible for
immediately notifying the Risk Management. This may allow for the reimbursement of cleanup
costs.
6.5 Issuing a Notice of Violation (NOV)
Once the responsible person has been identified, an initial letter is issued to address the illicit
discharge and/or connection for corrective actions within timeframe given. An NOV is issued
and approved by the Director of Engineering along with a Notary Affidavit for the issuance of
violation. The NOV identifies the nature of the violation, sets forth the measures necessary to
comply with the Ordinance and provides a specific time period of compliance.
Stormwater Staff creates a NOV letter and records in ACCESS file which is linked to City’s GIS
system. All attachments relating to the NOV, including the signed NOV and affidavit must be
attached to the NOV. The Stormwater Compliance Coordinator shall carefully review all
documentation for spelling and punctuation before forwarding to the Stormwater Engineer and
Director of Engineering to review.
If the person committing the offense is different from the property owner, a copy of the written
Notice of Violations will be sent to the property owner. In some situations, both the person
committing the offense and the property owner should be held responsible for the violations.
Consult with the Stormwater Engineer to make the determination.
All NOVs are signed by the Stormwater Compliance Coordinator. NOVs are sent “Certified Mail
Return Receipt Requested.” In addition, a Notary Affidavit is signed and notarized for legal
purposes. Stormwater Compliance Coordinator is responsible for retaining this receipt and
scanning it for the files.
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(PIC OF CERTIFIED RECEIPT)
Affidavit
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In most cases, written NOVs are issued to ensure compliance when there has been a
documented impact to surface waters or to the ground (i.e. oil or chemicals dumped on the
ground or in the storm drain). The Stormwater Engineer must approve all written NOVs prior to
issuance. Always review records for documentation of previous violations prior to the issuance of
an NOV. If there is a history of noncompliance within the past three (3) years, enforcement
action is typically recommended. Civil penalties are the most commonly used enforcement
remedy; however, City of Monroe’s ordinances include other compliance mechanisms that may
be warranted depending on circumstances, including a compliance agreement, compliance
order, cease and desist order, and withholding inspections, permits or other approvals. The
determination for recommending enforcement is made after consulting with the Stormwater
Engineer.
6.6 Documentation, Review and Mailing
When a suspected illicit discharge is reported, an investigation of the suspected illicit discharge
will be conducted within two (2) business days of the report. The Stormwater Engineering
Technician will investigate and complete the Illicit Discharge Incident Form, which includes:
1. Date and Time of the report
2. The name and contact information of the individual reporting the illicit discharge.
3. Location of the incident.
4. Narrative Description of Problem Findings
5. Owner Information
6. Watershed
7. How was incident reported
8. Ranking: High, Medium or Low
High = Immediate attention required to address an active discharge situation
Medium = Requires attention, but problem is not currently occurring
Low = Low Priority, (education needed)
9. GIS information: Location ID and Parcel number
Once the Stormwater Engineering Technician has completed the form and has determined that
an illicit discharge is present, the completed form and all related documentation and pictures
are to be submitted to the Stormwater Compliance Coordinator within one (1) business day.
The Stormwater Compliance Coordinator will then determine the enforcement action to be
taken, if necessary.
If there is evidence of an illicit discharge and the entity responsible for that discharge has been
contacted, complete the follow-up portion of the Illicit Discharge Incident Form with 3 days
following the date that the illicit discharge needed to be corrected by. If the illicit discharge has
been corrected, the Stormwater Compliance Coordinator will close the investigation and note
the date the investigation was closed on the form.
If there is more than one suspected illicit discharge to be investigated, the Stormwater
Compliance Coordinator will prioritize investigations based on the possible impacts to public
health and safety that the suspected illicit discharge could have. If there is more than one
possible illicit discharge that could have a negative impact on public health and safety,
prioritize the investigation of obvious illicit discharges over suspected illicit discharges.
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6.7 Follow Up Investigations
It is extremely important to conduct a timely and effective follow up investigation to ensure
compliance with a Notice of Violation. Investigations must be conducted on the compliance
date specified in the field or written notice (typically 10 working days) to ensure that all violations
have been addressed and the prescribed remedial actions have occurred.
Follow up inspections are required for field and written NOVs to confirm that the violations has
been corrected. The completed corrective actions and inspections results are documented in
the ACCESS file which is linked to City’s GIS system.
6.8 Enforcement Procedures
Any person who violates local or state water quality ordinance is subject to a civil penalty, which
can be assessed from the date the violation first occurs. No penalty is assessed until the person
alleged to be in violation has been notified of the violation.
The maximum civil penalty is $500.00 per violation per calendar day until repairs are completed
and functioning properly.
Once the penalty amount is set, the Person responsible for the violation is notified of the penalty
and the reason it is being assessed. The notice of penalty is issued in writing and sent via
certified mail. The notice directs the violator to either pay the assessment within thirty (30) days
after notice of the violation is issued by the Stormwater Compliance Coordinator. If the violator
does not pay a civil penalty or file an appeal with 30 days after it is due, the case is turned over
to the City’s Attorney Office for initiation of collection actions.
Section 7: Program Evaluation
The program will be evaluated annually to determine the progress towards the measureable
goals detailed in the Stormwater Management Plan. Program evaluation will be completed
using the spreadsheet used to track illicit discharge investigations, the database used to track
outfall inspections, and the information regarding the frequency of “hotline” used and the
associated number of confirmed reported illicit discharges. This evaluation of the program can
help to improve the program by identifying the areas that have the most sever illicit discharges
problems so that resources may be allocated to these areas.
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Appendix A: Sample Forms
Outfall Reconnaissance Inventory/ Sample Collection Field Sheet
S ECTION 1: B ACKGROUND D ATA
Subwatershed: Bearskin Creek Outfall ID:
Today’s date: Time (Military):
Investigators: Form completed by:
Rainfall (in.): Last 24 hours: 0 Last 48 hours: 0
Temperature (F):
Latitutde: Longitude: GPS Unit: GPS LMK #:
Camera: Photo #s:
Land Use in Drainage Area (Check all that apply):
Industrial Open Space
Ultra-Urban Residential Institutional
Suburban Residential Other:
Commercial Known Industries:
Notes (e.g.., origin of outfall, if known):
Section 2: Outfall Description
SHAPE DIMENSIONS (IN.)
LOCATION
MATERIAL SUBMERGED
RCP Circular Single Diameter/Dimensions: In Water:
CMP No
Eliptical Double Partially
PVC Fully
HDPE Box Triple
Closed Pipe
With Sediment:
Steel Other: Other: No
Partially
Other: Fully
Concrete
Trapezoid Depth:
Earthen
Open drainage Parabolic Top Width:
rip-rap
Other: Bottom Width:
Other:
In-Stream (applicable when collecting samples)
Yes No If No, Skip to Section 5
Flow Present?
Flow Description
Trickle Moderate Substantial
(If present)
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S ECTION 3: Q UANTITATIVE C HARACTERIZATION
FIELD DATA FOR FLOWING OUTFALLS
PARAMETER UNIT EQUIPMENT
RESULT
Volume Liter Bottle
Flow #1
Time to fill Sec
Flow depth In Tape measure
Flow width ’ ” Ft, In Tape measure
Flow #2
Measured length ’ ” Ft, In Tape measure
Time of travel S Stop watch
Temperature Thermometer
F
pH pH Units Probe
Ammonia mg/L Test kit/DPD
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Outfall Reconnaissance Inventory Field Sheet
SECTION 4: PHYSICAL INDICATORS FOR FLOWING OUTFALLS ONLY
Are Any Physical Indicators Present in the flow? Yes No (If No, Skip to Section 5)
CHECK if
Present
DESCRIPTION RELATIVE SEVERITY INDEX (1-3)
INDICATOR
Sewage Rancid/sour Petroleum/gas
3 – Noticeable from a
1 – Faint 2 – Easily detected
distance
Odor
Sulfide Other:
Clear Brown Gray
Yellow
1 – Faint colors in 2 – Clearly visible in 3 – Clearly visible in
Color
sample bottle sample bottle outfall flow
Green Orange Red
Other:
Turbidity See severity 1 – Slight cloudiness 2 – Cloudy 3 – Opaque
2 – Some; indications 3 - Some; origin clear
Floatables
Sewage (Toilet Paper, etc.) Suds
1 – Few/slight; origin of origin (e.g., (e.g., obvious oil
-Does Not Include
not obvious possible suds or oil sheen, suds, or floating
Petroleum (oil sheen) Other:
Trash!!
sheen) sanitary materials)
Section 5: Physical Indicators for Both Flowing and Non-Flowing Outfalls
Are physical indicators that are not related to flow present? Yes No (If No, Skip to Section 6)
DESCRIPTION COMMENTS
INDICATOR CHECK if Present
Spalling, Cracking or Chipping Peeling Paint
Corrosion
Outfall Damage
Oily Flow Line Paint Other:
Deposits/Stains
Abnormal Vegetation Excessive Inhibited
Odors Colors Floatables Oil Sheen
Poor pool quality Suds Excessive Algae Other:
Pipe benthic growth Brown Orange Green Other:
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Section 6: 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 8: Any Non-Illicit Discharge Concerns (e.g., trash or needed infrastructure repairs)?
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Illicit Discharge Incident Form
Date/Time Report Received:
Report Inspected By:
Purpose
Immediately report all incidents to the Stormwater Compliance Coordinator.
Use this sheet to record conversation and inspection details during inspections.
These may be spills, leaks, sediment, sewage, leaves, plumbing connections, dumping, or other releases.
Provide detailed information, photos and contacts made on inspections.
Follow up documentation will be recorded in the City’s GIS for tracking system.
Location
Street Address
City State Zip Code
Business Name
Narrative Description of Problem Findings:
Commercial/Industrial Residential
Descriptive Field Notes:
Site Investigation Details
Spill Grass/Leaves Leak Sediment Sewage Dump
SS Overflow Washwater
Pollution Information
Was there a release to the City’s MS4? Yes No
Was there a release to the City’s Waterbody? Yes No
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For Office Entry:
Incident ID:
Reporting Party’s Name:
Compliant Address: Phone:
Owner Information
Name: Company:
Address:
Owner information same as “Location” information.
Watershed:
How was Report Received
Office Phone Cell Phone Email Verbal
Exchange
Observed in Field Hotline Other:
Priority Rank: High Medium
Low
High = Immediate attention required to address an active discharge situation.
Medium = Requires attention, but problem is not currently occurring.
Low = Low priority, (education needed)
LID: Parcel:
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