06_NCS000564_Wendell IDDE Plan_20220729

NWENDELL
DRAFT
ILLICIT DISCHARGE DETECTION
AND ELIMINATION PROGRAM PLAN
Town of Wendell
Prepared by
Town of Wendell
15 East Fourth Street
2021

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Table of Contents
Page
1.0
Introduction.............................................................................................................. 1
1.1
Detection of Illicit Discharges.............................................................................. 2
1.2
Correction of Illicit Discharges............................................................................ 2
2.0
Legal Authorities..................................................................................................... 2
3.0 Dry
Weather Screening Protocols................................................................................. 3
4.1
Background.......................................................................................................... 3
3.1
Schedule of Field Screening Activities................................................................ 3
3.2
Dry Weather Screening Procedure....................................................................... 4
5.0 Illicit Discharge Source Investigations.................................................................... 6
4.0 Timeframe to Conduct Source Investigations...................................................... 6
4.1 Methodologies to Determine the Source of Illicit Discharge ............................... 6
4.2 Follow-up Investigations for Continuous Illicit Discharges ................................ 7
4.3 Documentation and Tracking Illicit Discharge Investigations ............................. 7
5.0 Annual Reporting..................................................................................................... 8
List of Appendices
APPENDIX A: Dry Weather Outfall Screening Field Equipment Checklist .................... 9
APPENDIX B: Data Sheets for Dry Weather Outfall Screening .................................... 13
APPENDIX C: Log of Illicit Discharge Source Investigations ....................................... 17
List of Tables
Table 3-1. MS4 Outfalls Required for Annual Dry Weather Screening ............................ 4
Table 3-2. Dry Weather Screening Parameters and Equipment ......................................... 5
Table 4-1. Parameters Action Criteria and Effluent Type .................................................. 7
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1.0 Introduction
The Town of Wendell is regulated by the MS4 Permit under Permit Number NCS000564.
This is the Town's plan Implement, a plan and address non-stormwater discharges, including
illegal dumping. An illicit discharge is defined as any discharge to an MS4 that is not composed
entirely of stormwater, except discharges allowed pursuant to a separate permit. These
discharges can be hazardous to public health, harmful to aquatic life in receiving waters, and
detrimental to overall water quality.
This IDDE Program Plan meets the requirements of the abovementioned written procedures and
has been revised to comply with requirements of the Town of Wendell MS4 Permit.
Specifically, the MS4 Permit requires the written procedures to include (a) Maintain adequate
legal authorities, (b) maintain a storm sewer system base map of major outfalls, (c) detect dry
weather flows (d) investigate sources of identified illicit discharges € track and document
investigations of illicit discharges (0 Employee training (g )provide public education (h) public
reporting mechanism timeframe and methodologies to conduct illicit discharge source
investigations, and (d) a mechanism to track all illicit discharge investigations.
Illicit discharges in storm drains consist of measurable flow and contain high concentrations of
pollutants and/or pathogens. Dry weather discharges can include the following illicit types:
• sewage and septic flows;
• public drinking water supply breach;
• washwater flows, such as residential gray water (laundry) discharges, water from
commercial car washes, fleet washing, equipment washdown activity, commercial
laundries, and floor washing to shop drains; and
• liquid wastes such as oil, paint, and industrial process water that enter the storm drain
system.
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1.1 Detection of Illicit Discharges
IDDE programs frequently include systematic or targeted screening of storm drain outfalls in
priority areas. IDDE programs may include both dry weather screening ofstorm drain outfalls
and investigations of upland sources of pollution as it enters the storm drain system.
This plan establishes the protocol for identifying and screening outfalls within the Town of
Wendell permitted area, including all Town owned or controlled facilities and properties
which have a potential to have discharges do to town business. Town facilities are screened
on a quarterly basis for presence of illicit discharge. as is required by the MS4 Permit. This
Plan also contains the field operations, data management, and response protocols for the
IDDE program.
1.2 Correction of Illicit Discharges
Outfalls that have been found to be discharging and that have one or more screening parameters
that are outside of acceptable ranges will be investigated further to determine the source or cause
of the illicit discharge. Any suspected illicit will have investigation and possible enforcement.
2.0 Legal Authorities
Thew Town of Wendell maintains the authority to enforce and eliminate illicit discharges into
the MS4 the Town Ordinance.
3.0 Dry Weather Screening Protocols
Background
For the purposes of this IDDE Program Plan, dry weather conditions are identified as less than a
cumulative 0.10 inches of rainfall in 72 hours. Dry weather MS4 screening programs involve
monitoring both physical and chemical characteristics of dry weather flows. If flowing water is
present at an outfall during dry weather, the quality of the flowing water is assessed in the field.
Water quality testing for indicator pollutants such as detergents and fluoride, and characteristics
such as pH and temperature, provides on -the -spot information to help distinguish between
improper discharges and other possible sources of dry weather flow, such as groundwater
infiltration. Physical indicators in flowing water include odor, color, turbidity, and the presence
of floating material such as oil, sewage, or suds. Physical indicators of a potentially improper
discharge are often evident when flow is not present; such indicators include outfall damage,
deposits or stains, unfavorable colors or odors in plunge pools, deposits of material in receiving
channels, and algal growth in pipes.
Field procedures for dry weather screening are described in Sections and .
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4.0 Schedule of Field Screening Activities
An outfall is a point where the MS4 discharges from a pipe or other conveyance (e.g. a ditch) directly into
surface ivaters. Major outfalls are required to be mapped to meet permit requirements. A major outfall is a 36-
inch diameter pipe or discharge from a drainage area > 50-acres; and for industrial zoned areas a 12-inch
diameter pipe or a drainage area > 2-acres.
4.1 Dry Weather Screening Procedure
Initial dry weather screening activities include assessing the physical characteristics of the outfall
and any discharge. Field screening will not proceed unless less than 0.10 inches of rainfall has
fallen in the preceding 72 hours. Field crews will verify that this dry -time criterion has been met
before beginning field operations. The field staff will obtain and gather the materials listed in
Appendix A prior to field work. The outfall screening will commence on the set schedule for
each outfall. The dry weather screening will be documented on the "dry weather inspection
form" and stored in digital form for regulatory review.
For the APS dry weather field effort, screening of outfalls consists of the following:
4.1.1 Locate outfalls using GPS and infrastructure maps in the target areas.
4.1.2 Inspect the selected outfalls for physical evidence of illicit discharge.
4.1.3 If flowing water is present, perform water chemistry tests in the field.
4.1.4 Record data on field data sheets.
4.1.5 If the presence of suspected illicit discharge is detected, ACG responsible
personnel will be notified within 24 hours.
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Data gathered during the dry weather screening field effort will be recorded on pre-printed field
data sheets (Appendix B). Datasheets developed by the Center for Watershed Protection (Brown
et al. 2004) were used as the basis for these field data sheets. The following screening
information will be entered onto field data sheets:
1. Background Data: Record current date, physical location, GPS location(if available),
investigators, and other background data.
2. Outfall Description: Enter information describing the outfall, including outfall ID (if
provided by County), whether closed pipe or open channel, whether subsurface or
open to daylight, physical dimensions, shape, orientation, material type, etc. Indicate
if water is flowing from the outfall and describe (e.g., yes, no, intermittent, stagnant).
3. Quantitative Characterization: If flowing water is observed, perform water chemistry
tests as described in the equipment -specific methodology records provided by the
manufacturer.
4. Physical Indicators for Flowing Outfalls Only: Collect information on physical
features of flowing outfalls (e.g., odor, color, turbidity, sheens, floating materials).
5. Physical Indicators for Flowing and Dry Outfalls: Collect information on physical
features of both flowing and dry outfalls. Examine outfall for presence and type of
algae, abnormal vegetation (if applicable), damage, stains, sheens, and condition of
plunge pool (if applicable). Structural problems (e.g., cracking, holes in corrugated
metal pipes, dissolved concrete) should also be noted.
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Table 5-1 identifies the dry weather screening parameters and the equipment and materials used
to screen for those parameters.
Annual Report. The dry weather screening technical memoranda include the following
information required for tracking by the MS4 Permit:
• Unique outfall identifier;
• Time since the last precipitation event;
• The estimated quantity of the last precipitation event;
• Site descriptions (e.g., conveyance type and dominant watershed land uses);
• Whether or not a discharge was observed; and
• If a discharge was observed, the estimated discharge rate (e.g., width and depth ofdischarge
flow rate) and visual characteristics of the discharge (e.g., odor, color, clarity, floatables,
deposits or stains, vegetation condition, structural condition, and biology).
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5.0 Illicit Discharge Source Investigations
The MS4 Permit requires that permittees conduct an investigation to identify and locate the
source of any observed unauthorized non-stormwater discharge. Permittees must identify (1) a
timeframe to conduct investigations; (2) methodologies to determine the source of all illicit
discharges; (3) methodologies for conducting follow-up investigations for illicit discharges that
are continuous or occur more frequently than a one-time discharge; and (4) a mechanism to track
and document all illicit discharge investigations.
5.1 Timeframe to Conduct Source Investigations
After receiving a report of a suspected illicit discharge, the Town of Wendell will investigate the
issue immediately. Utilizing the illicit discharge investigation from the Town will document all
the information which can be gathered on the form Any suspected illicit discharge, including
spills entering the MS4 and outfalls that fail physical or chemical parameter screening, will be
reported to Town of Wendell immediately if, during field investigations, any active pollution
discharge (elevated flow, discoloration, and abnormal odor) is evident. The Town designates
responsible personnel to investigate and remediate illicit discharges within Town of Wendell. If
the source of the discharge is located within the Town of Wendell system, then Town works to
investigate and resolve the discharge. Town of Wendell will begin source investigations for
suspected illicit discharges within two (2) weeks of the discharge being identified or reported.
5.2 Methodologies to Determine the Source of Illicit Discharge
The Town of Wendell's Stormwater Manager will designate responsible personnel to investigate
and remediate illicit discharges. if the source of the discharge is located on Town of Wendell
property, The Town will investigate and resolve the discharge.
The Town will compare the results of documented dry weather to assist in identifying the
possible source of a suspected improper discharge or illicit connection. Results will be
documented and reported in the MS4 Annual Report. Table 6-1 identifies the dry weather
screening parameters and their ability to aid in detecting the type of illicit discharge.
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Table 5-1. Parameters Action Criteria and Effluent Type
Recommended
w ` -
Recommended Action
Analyte
Effluent Type Indicated
Criterion
Industrial;
total chlorine
drinking water;
> 0.4 mg/l
sewage
fluoride
tap water
> 0.25 mg/1
Sewage;
ammonia
washwater;
> 1 mg/l
industrial
surfactants (detergents)
Sewage;
> 0.125 mg/1
washwater
Industrial;
pH
washwater
< 5
5.3 Follow-up Investigations for Continuous Illicit Discharges
If the Town is able to identify the source of an illicit discharge within six (6) months of
beginning the investigation, then the Town will document that the source remains unidentified. If
the observed discharge is intermittent, the Town will document that attempts to observe the
discharge flowing were unsuccessful.
5.4 Documentation and Tracking Illicit Discharge Investigations
The Town will maintain documentation to track the status of source investigations conducted
for illicit discharges on Town of Wendell property. Appendix C includes a log for this purpose
and allows space to document the following:
• The dates that the illicit discharge was initially observed, reported, or both;
• The results of the investigation, including the source, if identified;
• Any follow-up to the investigation;
• Resolution of the investigation; and
• The date that the investigation was closed.
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6.0 Annual Reporting
As required in the MS4 Permit, The Town of Wendell will submit the following information
on the IDDE Program in its MS4 Annual Report:
• A list of any written notifications of physical interconnection given by the Town to
other MS4 jurisdictions;
• The total number of outfalls screened during the reporting period, the screening
results, and number and nature of follow up actions; and
• A summary of each investigation conducted by The Town of any suspected illicit
discharge. Each summary must include: (i) the date that the suspected discharge was
observed, reported, or both, (ii) the results of the investigation, including the source,
if identified, (iii) how the investigation was resolved, including any follow-up, and
(iv) resolution of the investigation and the date the investigation was closed. All data will
be for each inspection will be entered into the Town's workorder system.
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APPENDIX A: Dry Weather Outfall Screening Field Equipment Checklist
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Dry Weather Outfall Screening Field Equipment Checklist
Item
Check?
Field maps
Field data sheets
Clipboard
Pencils/Permanent Marker
Measuring tape
Flashlight
Insect repellent
Steel -toed Boots
Reflective Safety Vest
First -aid kit
Outfall water quality screening kit(s) and procedure manuals
Backpack
Work gloves
Nitrile gloves
Safety glasses
Goggles
Digital camera or phone for photos
Polypropylene bottles for sharps/waste
Collection cups/bottles
500-mL wash bottle containing distilled water
Gallon containing distilled water
Paper Towels
Trash bag for non -sharps waste
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APPENDIX B: Data Sheets for Dry Weather Outfall Screening
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Dry Weather Screening P,= I ,f2
SECTION 1: BACKGROUND DATA
Watenhed:
Oulfall m:
Dote (hIFI/DD/ YY): _ _/ _ _/ 2g
Tinte (Mill o,):
Inwsllga:ors:
Porq�fompleled by.
Rainfall: LastVhmns: 0<0.1inches 0>0.I inches Lesttthours: 0<0.linches ❑>0.1 inches
Intimde(dd.dddd):_________^N Longimde(dd.dddd):_
... ______ I I OPSUnil:
Co...:
Photo Ns:
NoteVCon:mcros(eS.., origin oroulFnll, fknonn):
SECTION 2: OUTFALL DESCRIPTION
Locution
Alntirial
-4_'��e "''Is '3``rr
e1' Dlm{fious pn.)
❑Close) Pyligbl Pipe
❑Close) Subsurface Pipe
❑RC'P ❑Chip
PVC ❑ HDPC
Steel ❑Tennamm
❑ Other.
❑Cimulnr ❑Box ❑Single
❑ Oth, iral ❑ Aab ❑Double
❑Other._
❑Tdle
p
❑ OJmc
Dinsensions:
Heigh::
Width:
[I Open DmInnge
❑Concrete ❑Rip Rap
Earthen
8 Other: _
❑Tnpoodd
❑Parabolic
❑Other._
Depth:_
Tap Width: _
Bmmns Width:
0u11e11 ElarnMan:
SmpendM llelgM(ft /
Subnmrged Depth: In Wma(0):
In Sediment(ft):
0u1611 Cmsr:
❑Steel Gu:e ❑ Cage ❑ None
❑ Oder. _
Oulrall Proetttlon:
❑RippRep ❑Gabion Basket ❑Concmte ❑None ❑Other._
Outlel Erosion:
❑Nana ❑Mininul Erasion ❑Modmle Emsian ❑Henry Erosion DSilled
Erosion Saarte:
1krann11 Confillon:
❑No Headaoll ❑Good ❑Fair []Pm
Flow Preset'?
❑ Va ❑ No
❑ hun,wBml ❑ Sugmnl
If No, Skip to Section 5
Flme Depth(In.):
SECTION 3: QUANTITATIVE CHARACTERIZATION
FIELD DATA FORFLOWINOOU7FALLS
PARAMETER
RESULT
UNITS
PARAMETER
RESULT
UNITS
Chlorine
_ _
mg/I.
Dctngems
mp/L
Fluonde
_
mp/L
pH
-- ��
PH Units
Anmouin
mgR.
(Form adaptad front Dronn, e10.. 2004)
I oe n al' 1Yd11dell I DDE III op mill
15
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Dry Weather Screening Page 2 of
Omrhil to Today', deco:
SECTION 4: PHYSICAL INDICATORS FOR FLOWING OUTFALLS ONLY
INDICATOR
CHECK If
Present
DESCRIPTION
❑
❑Somge ❑Rancid/sour ©Pabolean✓gas [I Sulfide ❑Chcnsical ❑Other:_
Odor
Relative Seventy
01-Fain, ❑2-Easily detwmd ❑3- Noticeable Ronu dinanoe
❑
[]Cie., ❑ Bravo ❑ Gray ❑ Yellow ❑ Gran ❑ Orange ❑ Red ❑Other.
Color
ReldrNe $ePV*
❑I -Faint colors in sample bottle ❑2-CharlyvisLleiosamplebonle ❑3-Clearly risible inourall Row
❑
See severity
Tubidiry,
Re/arA'e Ses'a/i[y
❑I-Slignl cloudiness ❑2-Cloudy ❑7-Opaque
❑
❑ Sewage (Toils Paper,ewJ ❑ Seds ❑ Peboleunl (oil sheen) Cl Od¢r.
Floatables
Re/dtY2 Seventy
❑I - Fesvfsligbt 02-Sosnc ❑3-Widespread
SECTION 5: PHYSICAL INDICATORS FOR BOTH FLOWING AND NON -FLOWING OUTFALLS
INDICATOR
CHECK
If Present
DESCRIPTION
COMMENTS
❑
❑ Spelling, Cracking or Chipping
❑ Pealing Paint
❑ Carmeion
0u1fa11 Damage
Commas
❑
❑Oily
[I Flow Line
[I paint ❑Other:_
Depositssugis
Commenb
Cl
❑ E.c,,i,e
❑ Partially Inhibited
❑ Tololly Wsibiled
Abnormal Vegetation
Conunems
❑
❑ Odors ❑ Colors ❑ Flwlabla
❑ Oil Shan ❑ Suds
❑ Excessive Algae ❑ Other.
Poor pool quality
Cowlxnrs
❑
❑ Brawn
❑ Orange ❑ Green ❑ 011mr. _
Pipe algae growth
Conerm s
❑
❑ Almuinsna
❑ Glass bottles
❑ Plastic bottles ❑ Paper
❑ Sbxofoam ❑ Other.
ne,h
Cbmnsenss
SECTION 5: OVERALL OUTFALL CHARACTERIZATION OF ILLICIT DISCHARGE POTENTIAL
❑ Unlikely ❑ Suspect (>_I Section 4 indicator wish a severity of3)
❑ Potential (presence or >-2 Section 5 indicators) ❑ Obvious (>_I WQ indicator)
SECTION 7: NON -ILLICIT DISCHARGE CONCERNS
rusut nl'%%endelI 11)1)k Program
Ira
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APPENDIX C: Log of Illicit Discharge Source Investigations
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