HomeMy WebLinkAbout04_NCS000544_IDDE Manual_20220922TOWN OF BUTNER
ILLICIT DISCHARGE DETECTION AND
ELIMINATION MANUAL
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TABLE OF CONTENTS
1.0
INTRODUCTION AND PURPOSE........................................................................................................... 1
2.0
PROGRAM ADMINISTRATION/DOCUMENTATION............................................................................... 2
2.1
Annual Reporting to DEQ............................................................................................................... 3
2.2
Updates and Modifications............................................................................................................3
3.0
IDENTIFICATION OF AN ILLICIT DISCHARGE......................................................................................... 4
3.1
Defining an Illicit Discharge............................................................................................................ 4
3.2
Outfall Map and Inventory.............................................................................................................5
3.3
Awareness During Daily Activities and Operations.......................................................................... 6
3.4
Special Local Water Quality Concerns............................................................................................. 6
3.5
Reporting Procedures.................................................................................................................... 7
4.0
OUTFALL SCREENING ..........................................................................................................................8
4.1
Dry -Weather Outfall Screening...................................................................................................... 8
4.2
Wet -Weather Screening...............................................................................................................
10
5.0
INVESTIGATING ILLICIT DISCHARGEs.................................................................................................
11
5.1
Investigation Triggers and Prioritization.......................................................................................
11
5.2
Investigation Protocol..................................................................................................................
11
5.3
Timeframes for Performing Investigations....................................................................................
13
6.0
ELIMINATING VERIFIED ILLICIT DISCHARGES.....................................................................................
14
6.1
Source Elimination.......................................................................................................................
14
6.2
Follow-up on Source Elimination..................................................................................................
15
6.3
Administrative Action, Enforcement, and Penalties......................................................................
15
6.4
Reportable Spills..........................................................................................................................
16
APPENDICES
Appendix A: Outfall Inspection Form
Appendix B: IDDE Tracking Form
Appendix C: Reportable Discharge Form
Appendix D: IDDE Response Procedures
1.0 INTRODUCTION AND PURPOSE
This manual presents the standard protocol which Town of Butner will utilize to implement its Illicit Discharge
Detection and Elimination (IDDE) Program. The manual provides written procedures to detect, identify, and
address unauthorized non-stormwater discharges, including illegal dumping, to the Town of Butner's small
municipal separate storm sewer system (MS4). The written procedures are required to be developed,
implemented, and updated by the Town of Butner as a condition of the MS4 General Permit (General Permit).
The General Permit authorizes stormwater discharges from MS4s to surface waters in urbanized areas of the
State of North Carolina. The General Permitting mechanism is designed to prevent pollutants from entering
water bodies through stormwater runoff.
The MS4 Program is part of the Federal National Pollutant Discharge Elimination System (NPDES), which is
authorized through the Clean Water Act. With delegation from the Environmental Protection Agency (EPA),
MS4 General Permits in North Carolina are issued through the North Carolina Pollution Discharge Elimination
System and administered by the North Carolina Department of Environmental Quality (NCDEQ). This manual
was developed in general accordance with the EPA's, "Illicit Discharge Detection and Elimination: A Guidance
Manual for Program Development and Technical Assessments. "To ensure compliance with IDDE requirements
of the General Permit, the Town of Butner is required to perform the procedures outlined in this manual.
The Town of Butner's IDDE Program Manual includes five distinct components:
• Training — Procedures to train applicable operations and maintenance staff are discussed in Section 2.0
of this manual.
• Administration/Documentation — For the Town of Butnerto demonstrate compliance to the conditions of
the General Permit, documentation of IDDE activities performed is paramount. This is discussed in Section
2.0 of this Manual from field through administrative responsibilities.
• Identification of an Illicit Discharge — Procedures to screen, identify, and report questionable illicit
discharges are outlined in Sections 3.0 and 4.0 of this manual.
• Investigating the source of an Illicit Discharge— Procedures to investigate potential illicit discharges that
have been identified or reported are outlined in Section 5.0 of this manual.
• Elimination of an Illicit Discharge — Procedures to eliminate illicit discharges that have been confirmed
through the investigation effort are outlined in Section 6.0 of this manual.
1
June 2019
2.0 PROGRAM ADMINISTRATION/DOCUMENTATION
The General Permit requires the Town of Butner to provide training once every 24 months to applicable
operations and maintenance staff in recognition and reporting of illicit discharges. This manual serves as the
training material to meet the General Permit requirement.
The written procedures herein serve as the foundation of a successful IDDE Program and help to achieve
General Permit compliance. However, implementation of the procedures is critical for achieving the IDDE
Program goal to eliminate non-stormwater discharges to the Town of Butner's storm sewer system and
ultimately receiving waters. As referenced throughout this manual, the IDDE Program relies on supplemental
materials to assist with implementation and documentation. Documentation that procedures have been
implemented is critical to demonstrate permit compliance in the case of a regulatory audit. Operations and
maintenance staff who are identified for IDDE training should be familiar with each Section of this Manual, ,
and the supplemental materials provided in the Appendices of this Manual, which include:
• Outfall Inspection Form —This form is used for outfall screening to assist in determining the potential
of an illicit discharge. The form is located in Appendix A.
• IDDE Tracking Form — A form to assist with ensuring documentation required by the General Permit
for each investigation regarding any suspected illicit discharge. To be completed by the Town of Butner
Public Works Director; but required information may be needed from operations and maintenance
staff to assist with the completion of the form. The form is located in Appendix B.
• Reportable Discharge Form — This form is used for reporting an illicit discharge to DEQ. The form is
located in Appendix C.
In addition to the documentation above, the Town of Butner incorporates by reference the following:
• IDDE and Post -Construction Stormwater Facility Map — Identifies the locations of all outfalls that are
required to be screened. This map is intended to be used when conducting the annual inspection and
tracking illicit discharges.
• Outfall Inventory — Provides a list of outfalls and attributes required by the General Permit.
As highlighted throughout this Manual, documentation of illicit discharge reports, investigations, and
elimination actions is critical for demonstrating compliance to the General Permit. In the case of an illicit
discharge, the Town of Butner's General Permit requires, at a minimum, the following information:
✓ The date or dates that the illicit discharge was observed and reported;
✓ The results of the investigation, including the source, if identified;
✓ Any follow-up of the investigation;
✓ Resolution of the investigation; and
✓ The date that the investigation was closed.
2
June 2022
A discharge may require reporting to DEQ and any interconnected MS4s; therefore, the discharge must be
properly documented by the Town of Butner on the IDDE Tracking Form. This will enable the Town of Butner
to access this information if future requests are received concerning the discharge in question. The information
will also be included in annual reporting described in the following section.
2.1 Annual Reporting to DEQ
The Town of Butner must annually report to DEQ information pertaining to its IDDE efforts. The information is
included in the Town of Butner's MS4 Annual Report due October 315Y of each year. Information required for
reporting includes:
1) A confirmation statement that the Outfall & Post Construction Stormwater Facility maps and Outfall
Inventory have been updated to reflect any changes to the MS4 occurring on or before June 30t" of the
reporting year;
2) The total number of outfalls screened during the reporting period as part of the dry -weather screening
program; and
3) A list of illicit discharges to the MS4 including spills reaching the MS4 with information asfollows:
(a) The source of illicit discharge.
(b) The dates that the discharge was observed, reported, or both.
(c) Whether the discharge was discovered by the permittee during dry -weather screening, reported by
the public, or other method (describe); and
(d) How the investigation was resolved.
2.2 Updates and Modifications
Modifications to the may occur as part of an iterative process to protect water quality. Updates and
modifications to this Manual shall be consistent with the conditions of the General Permit and documented in
the annual report.
3.0 IDENTIFICATION OF AN ILLICIT DISCHARGE
Municipal separate stormwater sewer system (MS4) means a conveyance, or system of conveyances, that
ultimately discharge into surface waters or wetlands. That is, any system of drainage from roads, parking lots,
catch basins, curbs, gutters, ditches, man-made channels, or storm drains that convey stormwater is part of
the MS4. These conveyance systems are vulnerable to contamination. Substances other than stormwater that
enter receiving waters may be considered an illicit discharge and elimination of those discharges is the focus
of this Manual. An illicit discharge can:
1. Bea measurable flow from a storm drain during dry weather that contains pollutants or pathogens;
2. Have a unique frequency, composition, and mode of entry in the storm drainsystem;
3. Be caused when the sewage disposal system interacts with the storm drain system; or
4. Be discharges from pollutants from specific source areas
3.1 Defining an Illicit Discharge
For the purpose of the Town of Butner's IDDE Program, an illicit discharge is defined as:
Illicit Discharge - Any discharge to an MS4 that is not composed entirely of stormwater, except
discharges specifically and determined not to be a significant contributor of pollutants to the MS4.
Most sources of an illicit discharge for the Town of Butner's are likely to originate from a generating site or
activity, such as a washing area or vehicle maintenance area. These could result from daily practices or from a
specific spill incident. Table 1 provides source pollutants that could be generated.
Table 1. Examples of source pollutants of an illicit discharge.
• Automotive fluids (oil, fuel, antifreeze)
• Cooking oil and grease
• Solvents
• Paints
• Chemical cleansers (detergents, soaps)
• Improperly applied pesticides/herbicides
• Improperly managed salts
• Landscape waste (grass clippings, etc.)
• Improperly applied fertilizer
• Sediment
• Vehicle wash water
• Sanitary sewer wastewaters
• Dumpster leachate
• Trash
The regulations do have exemptions for some non-stormwater discharges that would not be considered an
illicit discharge if not a significant contributor of pollutants to the MS4. Table 2 includes some of the discharges
relevant to the Town of Butner that are not a significant contributor of pollutants; and therefore, are not
considered illicit discharges. If there is uncertainty of the source or constituents within an observed discharge,
the Town of Butner Public Works Director should be contacted immediately so a determination can be made.
Table 2. Examples of sources that are not considered illicit discharges.
•
Fire -fighting activities*
•
Air conditioning condensate
•
Water line flushing
•
Footing or foundation drains
•
Landscape/lawn irrigation
•
Springs
•
Diverted stream flows
•
Water from crawl space pumps
•
Rising groundwater
•
Dechlorinated swimming pool wastewater
•
Uncontaminated groundwater infiltration
•
Discharges from potable water sources
•
Uncontaminated pumped groundwater
•
Flows from riparian habitats and wetlands
•
Individual residential carwashing
•
Street wash water
•
Noncommercial fundraising car washes if
•
Other activities generating discharges identified
the washing uses only biodegradable,
by the department as not requiring VPDES
phosphate -free, water -based cleaners
authorization
* Discharges or flows from fire -fighting activities need only be addressed where they are identified as
significant sources of pollutants to surface waters.
3.2 Outfall Map and Inventory
An outfall is a point where the Town of Butner's MS4 discharges concentrated flow to surface waters or
wetlands, such as at the end of a pipe or open drainage channel. Generally, these are the locations that drain
stormwater and can be evaluated routinely to identify potential pollutants. Action can then be taken to prevent
these pollutants from traveling downstream. The General Permit requires the Town of Butnerto maintain storm
sewer maps and an outfall information table. The Town of Butner may elect to map the known point of
discharge location closest to the actual outfall when the outfall is located outside of the Town of Butner's legal
responsibility.
The Town of Butner's outfall map illustrates the locations of the outfalls from the storm sewer system and the
receiving waterway. The outfall map is a critical component of the outfall inspection and serves as a tool to
identify potential pollutant generating sites, the storm sewer layout adjacent to the sites, and the locations
where the storm sewer discharges to a waterway or the point of discharge off the MS4.
An illicit discharge identified in Town may originate from an upstream interconnected MS4. Contacts to
interconnected MS4s are included on the map for reporting a potential off -site pollutant source. The upstream
MS4 should be notified immediately to identify and eliminate the pollutant source.
The General Permit also requires the Town of Butner to maintain an Outfall Information Table that includes
permit -required attributes for each outfall. The Public Works Director should maintain a copy of both the IDDE
maps and the Outfall Information Table for review upon request by the public or DEQ. The documents should
be updated when changes to existing outfalls are found, or new outfalls are added with new construction.
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June 2022
3.3 Awareness During Daily Activities and Operations
Potential illicit discharges can be identified and removed prior to entering the storm sewer system with
effective inspections and appropriate follow-up when pollutants have the potential to be exposed to
precipitation, and subsequently, stormwater runoff. The Town of Butner's Public Works staff are in the best
position to identify these pollutants such as those identified in Table 1. Figure 1 provides several examples of
the observations and actions that could prevent an illicit discharge. If the observer is not qualified or
appropriately trained to take the appropriate action, or if illegal dumping is observed, notifythe Town of Butner
Public Works Director or designee.
Observation
Uncovered dumpster
Uncovered container
Oil/hydraulic fuel on ground
Action
> Cover dumpster
Store container indoors
> Clean & dispose of properly
3.4 Reporting Procedures
The Town of Butner Public Works staff are the first line of defense for preventing generating sites from
contributing to an illicit discharge. If Public Works staff detects an Illicit discharge as defined in Section 3.0,
report the illicit discharge immediately to the Public Works Director who shall report the discharge to DEQ
within 24 hours.
NCDOT and the counties and municipalities which have interconnected MS4s with the Town of Butner,
meaning there is stormwater being conveyed to and from the Town of Butner property via a point source
discharge. Any report from an interconnected MS4 of an illicit discharge originating from the Town of Butner
should be immediately reported to the Public Works Director for investigation and documentation.
Actions that are taken to prevent an illicit discharge are designated as good housekeeping practices and do not
need to be reported to DEQ. Public Works staff shall report a good housekeeping issue within 24 hours to the
Public Works Director. A Findings & Follow-up Form shall be used to document good housekeeping issues..
An illicit discharge may also be reported by other individuals that are not trained or authorized to perform
necessary actions. These individuals may recognize an illicit discharge after learning about pollution in
stormwater runoff through the Town of Butner's public education and outreach efforts. The Town of Butner
stormwater webpage directs these individuals to contact the Public Works Director, who will subsequently
perform the appropriate follow-up action and complete the documentation. If Public Works staff is notified of
an illicit discharge, the appropriate action should be taken, and the Public Works Director shall be notified.
Figure 2 summarizes this procedure.
1. 2. 3. 4.
Reportedor Observed Call 9-1-1, if pertinent Assess, select PPE, stop Complete Forms and
Illicit Discharge. & notify Public source, confine spill, Report to DEQ within 24
Works Director cleanup &dispose hours
imrliafil��
Figure 2. IDDE Reporting procedures for the Town of Butner Public Works staff.
If an illicit discharge has occurred, the Public Works Director will then document the report with the IDDE
Tracking Form provided in Appendix B. The Public Works Director shall also complete the Reportable Discharge
Form in Appendix C for documentation purposes. Public Works staff should be familiar with these forms to
assist with providing the necessary information required to complete the forms. Refer to the guidance in
Appendix D for more in-depth procedures to follow if an illicit discharge isdetected.
4.0 OUTFALL SCREENING
In an effort to detect, identify, and eliminate illicit discharges to the Town of Butner, an annual outfall
inspection is reauired by the Proeram Plan under the General Permit for all of the outfalls in the Town. In the
case that illicit discharges are observed at specific outfalls and the source is not identified or eliminated,
subsequent screening at a higher frequency may be necessary.
4.1 Dry -Weather Outfall Screening
Outfall screening shall be performed during dry weather using the Outfall Inspection Form provided in
Appendix A. Completion of the form serves as the appropriate documentation that the required outfall
screening has been performed and should be retained on file for a minimum of 3 years. Outfalls that are flowing
during dry weather may indicate an active pollution issue, depending on if rain has occurred during the last 24
to 48 hours. Special attention should be paid to outfalls that are flowing especially when no rain has occurred
within the last 48 hours. When the screening of an outfall indicates an illicit discharge, the Town of Butner
Public Works Director shall be notified within 24 hours so an investigation, as described in Section 5.0, can be
performed and an IDDE Tracking Form completed.
The Outfall Inspection Form includes the following sections, which are to be completed for each outfall during
outfall screening:
• Section 1: Background Data— Requires general information regarding when and where the screening was
performed, weather conditions at the time of the screening, and references to any photos taken. Tips for
completing Section 1 include:
0 The Outfall ID can be found on the IDDE map. Update map to reflect new outfalls.
0 Take at least 1 photo of the outfall for documentation purposes, especially if there is question
regarding an illicit discharge; and
• Section 2: Outfall Description — Requires a description of the outfall and determination if flow is present
during dry weather. Tips for completing Section 2 include:
0 If submerged with sediment, measure the depth of sediment.
0 The identification of flow is important since flow during dry weather would indicate a non-
stormwater discharge. If a pipe is partially submerged, and it is difficult to identify dry -weather
flow, a nearby leaf or blade of grass can be dropped onto the water surface near the outfall. The
travel of the object on the surface can help indicate if flow is discharging from the outfall.
0 Upon completion of this section, if no flow is present, skip to Section 5 of theform.
• Section 3: Quantitative Characterization for Flowing Outfalls — Requires quantitative information of the
flow present at the outfall, including information to determine an estimate of the flow rate. The purpose
of this information is to help identify the source of the discharge. Tips for completing Section 3 include:
M Flow rate can be estimated with the following equations. Measured data from the form is shown
in bold below.
Flow #1 (for pipes):
_'liters_ 1 gallon 60 seconds
x =Flow in gpm
,X'se�s X 3.7� minute
✓ For the Flow #1 calculation, time in seconds is the time to fill the bottle to 'X' liters.
Flow #2 (for open channels):
P (bot. width (ft)+ top width (ft) Length (ft)
x depth (ft) I x
2 travel time (seconds)
x7.48:�f,94eii.-x
1 cubic ft minute Flow in gpm
✓ For the Flow #2 calculation, travel time is estimated by the time it takes a floating object to travel
the defined length.
• Section 4: Physical Indicators for Flowing Outfalls Only — Requires the observance of physical indicators
in the flow, such as odor and color, to assist with identifying the source of the discharge. A tip for
completing Section 4 includes:
0 Take photos of visible indicators.
• Section 5: General Physical Indicators for All Outfalls — Requires physical indicators be noted that are not
related to flow, such as abnormal vegetation and staining, which can indicate that an intermittent
discharge has occurred in the past, even if not currently flowing. Tips for completing Section 5 include:
0 Take photos of visible indicators.
0 Note benthic growth, such as algae or slime on channel surfaces, which can be an indicator of
nutrients in the stormwater runoff (See Figure3).
iry
Figure 3. Example Photo showing algae growth.
• Section 6: Outfall Severity Index— Requires the assignment of a severity score for prioritizing outfall follow-
up investigation, if necessary. A tip for completing Section 6includes:
0 The severity of concern at an outfall is best judged by the outfall inspector. The rating system
provided on the form is intended to provide consistency and guidance; but the intuition of the
inspector overrides the scoring rules.
• Section 7: Any Non -illicit Discharge Concerns — The inspector performing the outfall screening should
identify any other concerns such as trash, overgrowth prohibiting flow, or structural concerns of the outfall
(e.g., collapsed pipe).
4.2 Wet -Weather Screening
While dry -weather screening events can identify illicit discharges that are continuous, wet -weather screening
events may identify pollutant discharges that are temporary. Wet -weather screening may be appropriate if
dry -weather screening identifies physical indicators.
5.0 INVESTIGATING ILLICIT DISCHARGES
In the case of the identification of an illicit discharge, it is necessary to conduct an investigation to identify and
eliminate the source of the discharge. An investigation may resultfrom:
• A staff observation;
• A report to the Town of Butner Public Works staff from the general public;
• A report from an interconnected MS4; or
• The results of outfall screening.
The determination if an illicit discharge has occurred will be made by the Town of Butner Public Works Director.
In all cases of an illicit discharge, the IDDE Tracking Form must be completed as documentation for General
Permit annual reporting.
The following sections outline the methodologies that shall be followed in the investigation of an illicit
discharge.
5.1 Investigation Triggers and Prioritization
Upon the identification of an illicit discharge, the reporting date, location, and description must be reported in
the IDDE Tracking Form. Note that Section 6 of the Inspection Form should be referenced to estimate a severity
Index classification. The following shall trigger an investigation:
• The determination of the occurrence of an illicit discharge by the Public Works Director based on an
observed illicit discharge by the Town of Butner Public Works staff, such as during daily activities, or a
follow-up from a reported observation.
• A severity index classification of either potential, suspect, or obvious. If more than one outfall
screening produces one of these classifications, investigation efforts shall be prioritized as:
o Obvious — Illicit discharge(s) suspected of being sanitary sewer discharges or significantly
contaminated would have this classification.
o Suspect— Numerous physical indicators result in this classification.
o Potential — Discharges should not be expected to be hazardous to human health and safety.
The start and close date of the investigation is also required to be provided on the IDDE Tracking Form.
5.2 Investigation Protocol
An investigation of an illicit discharge may result in the source being easily identified or may be complex and
may require referencing this manual, IDDE map, and coordination with interconnected MS4s.
An initial field evaluation may easily identify the source of an illicit discharge.. Once found, the source should
be eliminated, and efforts documented on the
IDDE Tracking Form. It is critical that documentation on the IDDE tracking Form is complete to demonstrate
illicit discharges have been addressed in accordance with the General Permit.
If the source of an illicit discharge is not easily identified, further investigation is necessary and should be
guided by the following procedures:
1) Track the illicit discharge to its point of entry into the storm sewer. Tracking can be supplemented with
review of the Town of Butner IDDE/Post-Construction Stormwater Management Facility map to identify
flow directions and the drainage area.
2) Conduct a field inspection of the drainage area near the point of entry to identify the potential
pollutant source. Document potential sources with photos, ensuring the photos give the appropriate
context to the location of the source.
The Town of Butner Public Works staff will primarily rely upon visual inspections of the areas in the storm
sewer system upstream of the outfall at which an illicit discharge is detected. However, sampling and analysis
can be performed as necessary to determine the characteristics of the illicit discharge and to help identify the
most likely source. Improper connections and unpermitted cross -connections to the storm sewer system can
be detected by utilizing a combination of methods to investigate non-stormwater discharges, such as
visual/video inspections, and dye or smoke tracer testing. Additional dry -weather testing at a discharge point
assists in identification of abnormal conditions such as sporadic or continuous discharge, which can facilitate
tracing of the source. Tracking techniques also include visual inspections of drainage structures and lines, and
indicator monitoring.
Other more elaborate approaches include using remote sensing tools to identify soil moisture, water
temperature, and vegetation anomalies associated with illegal dumping activities. Due to the size of the Town
of Butner and the activities that typically occur, it is not anticipated these types of tracking strategies will be
necessary and further discussion is outside of the scope of this Manual.
If an illicit discharge is determined to originate outside of the Town of Butner, then the appropriate locality
and/or MS4 Program authority should be contacted immediately by the Town of Butner staff and the request
made to eliminate the discharge. The interconnected MS4 should initiate corrective action per their prescribed
process. The Town of Butner staff will follow up with the responsible entity to verify the corrective action has
been successfully implemented, and the final action will be documented and tracked on the IDDE Tracking
Form.
5.3 Timeframes for Performing Investigations
In general, the timeframe for initiation of an investigation should be prioritized with first priority given to illicit
discharges suspected of being sanitary sewage or otherwise significantly contaminated. More specifically,
timeframes for initiating an investigation are established asfollows:
• Obvious — First priority, begin investigation within two business days of identification of an illicit
discharge.
• Suspect— Second priority, begin investigation within one week of the report of a suspected illicit
discharge.
• Potential - Third priority, begin investigation within two weeks of the report of a potential illicit
discharge.
If, after performing an investigation of an observed or reported illicit discharge, the source of the discharge
has not been identified and the non-stormwater discharge has not been detected again after 6 months, efforts
will be documented and the discharged identified as "non -recurring" with "source not found" on the IDDE
Tracking Form. At that time, no further action is necessary. However, investigatory due diligence should include
(with documentation):
• The tracking and field inspection methods described in the previous Section were performed;
• At least one additional dry -weather screening during the 6-month time period; and
• At least one wet -weather screening.
If an observed discharge is intermittent, the Town of Butner Public Works staff will perform three separate
investigations attempting to observe the discharge when it is flowing. If these attempts are unsuccessful, the
Town of Butner Public Works staff will also document the occurrence and process and no further action is
necessary.
6.0 ELIMINATING VERIFIED ILLICIT DISCHARGES
The ultimate goal of the IDDE Program is to eliminate illicit discharges from the MS4. Once an illicit discharge
has been identified and an investigation has determined the source of the discharge, the appropriate actions
need to be taken and documented to eliminate the discharge.
6.1 Source Elimination
Article 15.4 of the Town of Butner LIDO prohibits illicit discharge through the MS4. Further, the Town of Butner's
daily operations intend to prevent illicit discharges through the practices described in the Town of Butner
Pollution Prevention Plan. Through these mechanisms (See Figure 4), the Town of can eliminate illicit
discharges in which the source occurs on Town property.
Whenan illicit discharge originates within theTown of Butner's property, the Town of Butner Public Worksstaffwill
take the necessary corrective action to eliminate the discharge. Follow-up inspections may be necessary to
ensure the discharge into the Town of Butner storm drain system has ceased. Periodic inspections should be
conducted during both wet and dry weather after the initial illicit discharge to confirm the identified discharge
has been eliminated. Actions and resolutions must be documented and maintained on file for 3years.
When the source of an illicit discharge originates off -campus, and therefore, the Town of Butner does not have
authority to eliminate the source, DEQ or interconnected MS4 should be contacted by the Public Works
Director, as applicable. Figure 5 provides examples of the enforcement authorities to contact based on the type
of illicit discharge. This list is not all-inclusive but is based on typical sources of illicit discharges. IDDE Tracking
Forms should be maintained on file along with information related to the case, including dates, locations,
photos, results of screenings and investigations, and identified sources.
/Interconnected MS4
(City, County or NCDOT, as applicable)
• Cooking oil & Grease
• Paints
• Chemical Cleansers (e.g. detergents, soaps)
• Landscape Wastes (e.g. leaves, grassclippings)
• Fertilizers
• Sediment from off -campus sources
• Septic/sewer wastewater
\. • Gray water (e.g. clothes washing, dishwasher)
DEQ
(Pollution Response & Preparedness Program)
• Automotive fluids
• Solvents
• Pesticides and herbicides
• Chlorinated swimming pool discharges
• Unknown/other
Figure 5. Illicit discharge enforcement contacts for off -site illicit discharges entering the Town of
Butner property.
6.2 Follow-up on Source Elimination
Prior to closure of an illicit discharge investigation, the Town of Butner is required to conduct or
request a follow-up investigation to ensure the illicit discharge has been eliminated .The follow-up
investigation will include a field inspection with documentation including photographs where the
source had previously been identified.
6.3 Administrative Action, Enforcement, and Penalties
Article 15.4 of the Town of Butner Land Development Ordinance (LDO) prohibits illicit discharge into
its MS4 If an illicit discharge is detected a Notice of Violation (NOV) will be sent via certified mail to the
owner of the property per article 4 of the Town of Butner LDO.
6.4 Reportable Spills
If any unusual or extraordinary discharge should occur from a facility and the discharge enters or could
be expected to enter surface waters, the Town of Butner shall promptly notify, in no case later than
within 24 hours, DEQ by telephone after the discovery of the discharge. This notification shall provide
all available details of the incident, including any known adverse effects on aquatic life. Unusual and
extraordinary discharges include but are not limited to any discharge resulting from:
• Unusual spillage of materials resulting directly or indirectly from processing operations;
• Breakdown of processing or accessory equipment;
• Spills of large quantities of chemicals or fuels; and
• Flooding or other acts of nature.
APPENDIX A: Outfall Inspection
APPENDIX B: IDDE Tracking Form
IDDE TRACKING Form
Date Illicit Discharge Observed/Reported: Outfall # (if applicable):
Description of IDDE:
Date of Investigation:
Was the Source found? ❑ Yes No
If "Yes", please describe:
Was IDDE Resolved? Yes No
If "Yes", please explain how it was resolved (Please include any personnel or outside parties contacted or involved):
If "No", please explain why it was not resolved:
Is any follow-up action required? Yes ❑ No
If "Yes", please explain:
Date investigation closed:
Attach photos to this form and retain for records.
APPENDIX C: Reportable Discharge Form
Reportable Discharge Form
Form use: This form is used to determine if a discharge, spill or release is reportable to the Department of Environmental Quality
under the MS4 General Permit reporting requirements Section II(B)6(b)(4)(h) and Section III G, H, & I.
Section 1 - Discharge Classification
Note: If any item checked below, proceed to Section 2. If not, the discharge does not require a report to DEQ.
Is the discharge "unusual' or "extraordinary', including a "bypass" or"upset"?
■ "Unusual" or "extraordinary" discharges include but are not limited to any discharge resulting from:
Unusual spillage of materials resulting directly or indirectly from processing operations, breakdown of
processing or accessory equipment, failure or taking out of service some or all of the Public Works or
flooding or other acts of nature.
■ "Bypass" means the intentional diversion of waste streams from any portion of a treatment facility.
■ "Upset" means an exceptional incident in which there is unintentional and temporary noncompliance
with technology based state permit effluent limitations because of factors beyond the reasonable control
of the operator. An upset does not include noncompliance to the extent caused by operational error,
improperly designed treatment Public Works, inadequate treatment Public Works, lack of preventive
maintenance, or careless or improper operation.
Is it possible the discharge may adversely affect surface waters or may endanger public health?
Is the discharge sewage, industrial waste, other wastes or any noxious or deleterious substance or a
hazardous substance or oil in an amount equal to or in excess of a reportable quantity established
under either 40 CFR Part 110, 40 CFR Part 117 or 40 CFR Part 302?
Section 2 - Potential to Enter Surface Waters
Note: If any item checked below, proceed to Section 3. If not, the discharge does not require a report to DEQ.
j Did the discharge enter or is reasonably expected to enter surface waters?
Section 3 - DEQ or SGWASA Notification
Note: Only complete this section if yes was answered for item(s) in Section 1 and Section 2 above.
Notify North Carolina Division of Environmental Quality (NCDEQ) North Regional Office at 919.791.4200 within
24 hours after the discharge discovery and provide the information listed below, as applicable. Space has been
provided for documentation of information verbally reported to DEQ or via email at:
scott.vinsonp-ncdenr.gov.
1. Any adverse effects on aquatic life:
2. The known number of fish killed:
3. Any unanticipated bypass:
4. Any upset which causes a discharge to surface waters:
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For reports outside of normal working hours, leave a detailed message and this shall fulfill the immediate
reporting requirement. For emergencies, the North Carolina Department of Emergency Management maintains
a 24-hour telephone service at 800.858.0368 or 919.733.3300.
Section 4 — Follow-up Written Report
Note: Only complete this section if items were checked for both Sections 1 and 2 above, and Section 3 has been completed.
Note: The board or its designee may waive the written report on a case -by -case basis for reports of noncompliance under
Section III I if the verbal report has been received within 24 hours and no adverse impact on surface waters has been
reported.
A written report shall be submitted to the NCDEQ Northern Regional Office within five days after the discharge
discovery and shall contain the information listed below, as applicable. This completed form may serve as the
written report submitted to NCDEQ.
1. A description of the nature and location of the discharge:
2. The cause of the discharge:
3. The date on which the discharge occurred:
4. The length of time that the discharge continued:
5. The volume of the discharge:
6. If the discharge is continuing, how long it is expected to continue:
7. If the discharge is continuing, what the expected total volume of the discharge will be:
8. Any steps planned or taken to reduce, eliminate and prevent a recurrence of the present discharge or
any future discharges not authorized by this state permit:
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Please mail completed forms to:
North Carolina Department of
Environmental Quality Northern
Regional Office
217 West Jones St.
Raleigh, NC 27603
919.791.4200
Maintain a copy with your records.
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APPENDIX D: IDDE Response Procedures
June 2022
In the Event of an Illicit Discharge
1. Contact Public Works. If the discharge is large and hazardous call 9-1-1. Report an
illicit discharge immediately to the Public Works Director at 919.691.0095. The Public
Works Director shall report the illicit discharge to NCDEQ within 24 hours.
2. Assess the risk. When a discharge occurs, determine the risks that may affect human
health, the environment and the property. This may be done easily in cases where the
type of contaminant discharged is known. In situations where the contaminant is
unknown, determining risks may involve some investigation. In cases where the
chemical is unknown, the spilled material may be identifiable from the container label
or the Safety Data Sheet.
3. Select personal protective equipment (PPE). It is crucial that the appropriate PPE is
chosen to stop, confine, and cleanup the contaminant. Appropriate PPE may be a pair
of gloves, eye and foot protection, or face masks. If the chemical is unknown and the
risk level uncertain, use the highest level of caution and protection. Refer unknown
chemical cleanup to the Fire Department and do not attempt to cleanup without
appropriate guidance.
4. Stop the source. Stopping the source of a discharge may be apparent or may require
investigation. In any case, the source should be controlled as quickly as possible.
5. Confine the spill. It is crucial to confine the discharge. In some cases, this step may
need to occur before stopping the source. The proper containment measures
necessary should be assessed based on the size and type of the discharge. If a large
spill of fuel, sewage, or other hazardous materials occurs, contact the Fire Department
to assist in response and cleanup.
6. Evaluate the incident and implement cleanup. Once the discharge is stopped and
confined, the person responsible for cleanup should develop a plan of action to
cleanup the discharge. Once the discharge is cleaned up, the waste material should be
disposed of properly. See the Waste Management and Disposal Procedures section of
Good Housekeeping & Pollution Prevention Manual for disposal guidance.