NCS000246_Field Screening SOP_20220920

City of Fayetteville
NPDES Permit Program
Dry Weather Field Screening
and Follow-up Standard
Operating Procedures (SOP)
f
Cityet
STO R M WAT E R
Permit Number NCS000246
October 20, 2014

Table of Contents
Section 1: Purpose and Applicability....................................................................................I
Section2: Background...........................................................................................................2
Section3: Objectives...............................................................................................................3
Section 4: Summary of Method.............................................................................................4
Section 5: Health and Safety Warnings................................................................................5
Section 6: Personnel Qualifications.......................................................................................5
Section 7: Equipment and Supplies......................................................................................6
Section 8: Field Screening Program......................................................................................6
8.1 Establish a Field Screening Program Schedule...................................................................6
8.2 Establish an IDDE Training Program.................................................................................8
8.3 Establish a Field Screening Program..................................................................................8
8.3.1 Legal Authority...........................................................................................................8
8.3.2 Field Procedures..........................................................................................................8
8.3.2.1 General Field Screening Procedures.................................................................8
8.3.2.2 Pre -Assessment Phase......................................................................................9
8.3.2.3 Assessment Phase...........................................................................................10
8.3.2.4 Post -Assessment Phase...................................................................................12
Section 9: Follow -Up Procedures........................................................................................13
9.1 Reconnaissance.................................................................................................................13
9.2 Field Investigation.............................................................................................................14
9.3 Analytical Samples...........................................................................................................14
9.3.1 Analytical Sample Documentation...........................................................................15
9.3.2 Sample Collection and Handling..............................................................................16
9.4 Notification.......................................................................................................................17
Section 10: Data and Records Management..........................................................................18
Appendix A: Equipment List for Field Screening and Sampling..........................................19
Appendix B: Field Screening Tasks Checklist.........................................................................21
Appendix C: Dry Weather Field Screening Checklist.............................................................24
Appendix D: Analytical Sample Checklist...............................................................................27
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NPDES Permit No. NCS000246 — Dry Weather Field Screening SOP October 20, 2014

List of Tables
Table 9-1 Recommended General Analysis...........................................................................16
List of Figures
Figure 8-1 Major Watersheds....................................................................................................7
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NPDES Permit No. NCS000246 — Dry Weather Field Screening SOP October 20, 2014

Section 1: Purpose and Applicability
The US Environmental Protection Agency (EPA) implemented regulations that require
municipalities to reduce point source discharges of Stormwater to "waters of the United States".
The National Pollutant Discharge Elimination System (NPDES) regulations were published in
the Federal Register in November 1990 and apply to the City of Fayetteville. The NPDES
program was implemented as a result of the Federal Water Pollution Control Act of 1972 (also
known as the Clean Water Act or CWA).
In North Carolina, the NPDES program is administered by the North Carolina Department of
Environment and Natural Resources (NCDENR), Division of Energy, Mineral and Land
Resources. The NCDENR issued Municipal Separate Storm Sewer System (MS4) NPDES
Permit Number NCS000246 to the City of Fayetteville in December 1994. This permit is
currently renewed for a second term effective March 1, 2013 through February 28, 2018.
Associated with the NPDES Permit is the City Stormwater Quality Management Program, herein
referred to as the Stormwater Plan. The Stormwater Plan establishes strategic goals and
objectives that form the fundamental basis for current and future stormwater management. The
Stormwater Plan includes the results of prior field screening efforts and sets goals for developing
the Illicit Discharge Detection and Elimination (IDDE) program. Fayetteville's Stormwater
Division is responsible for implementing the dry weather field screening activities. To date, the
following field screening (or related) activities have occurred:
➢ During the Permit Application from December 1991 through August 1992, initial
screening was conducted on 268 of 935 identified outfalls. Results indicate 94 potential
illicit connections.
➢ In 1995, a Stormwater Hotline was established to promote public reporting of water
quality concerns, to include illicit discharges and improper disposal.
➢ Public Education concerning water quality and pollution prevention was implemented in
1995 and is considered an on -going initiative.
➢ In 1995, a complaint investigations program designed to provide limited follow-up
investigations was established through the Stormwater Division.
➢ In 1997, the City of Fayetteville adopted an Illicit Discharge and Improper Disposal
Ordinance.
➢ Based on the above Ordinance along with the complaint investigations program,
Fayetteville's Stormwater Division has issued Notices of Violations and Civil Penalties to
those who have violated the Ordinance through improper disposal as well as having illicit
connections.
➢ During the Stormwater Inventory, the field crews noted any conditions (odor, color,
sheen, etc.) that would indicate an illicit discharge or improper disposal. The Stormwater
Division Inspectors were provided with this data and performed follow-up investigations.
➢ As a result of the Stormwater Inventory, the Stormwater Division has identified 279
major outfalls (36 inches and larger) that discharge to Waters of the State. Each of these
outfalls was screened initially for any dry weather flows and any evidence of illicit
discharges or improper disposal. Each year, the City aims to screen 100% of the
identified outfalls for dry weather flows and evidence to detect and eliminate illicit
connections or improper disposal.
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NPDES Permit No. NCS000246 — Dry Weather Field Screening SOP October 20, 2014

Each of these aforementioned activities supports implementation of an ongoing Dry Weather
Field Screening Program. The primary purpose of the Dry Weather Field Screening Program is
to provide a means of detecting illicit discharges of pollutants to Waters of the State and to
remove or reduce the occurrence of such discharges. Dry weather flows are one indicator of
illicit connections. A secondary aspect of this Program is to identify improper disposal practices
that may impair the quality of stormwater runoff. Closely related to improper disposal practices
are water quality risk reductions. Water quality risk reductions are issues or concerns that should
be proactively addressed before any water quality problems or impairment occurs. This standard
operating procedure (SOP) serves as a set of instructions for the Stormwater Division and as a
stand-alone document that should be distributed to each individual involved in the Dry Weather
Field Screening Program. The SOP includes details on the Field Screening Program and Follow-
up procedures. Follow-up procedures may be initiated following discovery of an illicit discharge
or improper disposal.
Discharge screening results, documented improper disposals, and follow-up actions will be
included in the annual reports of permit compliance, which will be submitted to NCDENR
permitting officials.
Section 2: Background
The 1992 Part I NPDES Permit Application identified 935 stormwater outfalls in the City of
Fayetteville. Of the 935 outfalls included in the inventory, 268 outfalls, or approximately 29%
were field screened for dry weather flow. The presence of dry weather flow at an outfall
indicates the possibility that either an illicit connection or improper disposal is present in the
drainage area above that point. Illicit discharges and improper disposals can be differentiated in
that the former implies a more constant presence, such as an illicit connection, while the later
implies a sporadic or irregular pattern of occurrence.
Of the 268 outfalls that were field screened, 103 showed signs of pollution either through visual
observations or chemical analysis. Because the presence of visual indicators does not necessarily
indicate an illicit discharge or improper disposal, field screening for specific chemical
compounds was performed. Field screening is an on -site method used for determining the
presence and approximate concentration of specific indicator pollutants. The tests conducted in
1992 screened discharges for pH, phenol, chlorine, copper, temperature, and detergents, and were
conducted on 92 of the outfalls with dry weather discharges. Conclusions of the initial field
screening activities recommend further investigation, or follow-up activities, at about 20% of the
field screened sites. Since 1992 and in addition to the routine investigation of water quality
complaints, the Stormwater Division has followed -up on all of the potential illicit discharges and
improper disposal practices noted during the Stormwater Inventory. Also, the major outfalls
have been identified, located, and field screened for dry weather flows on an annual basis.
To achieve the Stormwater Plan goals, the Dry Weather Field Screening Program is designed to
identify dry weather flows, screen the discharge for a series of indicator pollutants, and initiate
follow-up procedures. To date, efforts have been concentrated on conducting field screening of
outfalls as the Stormwater Inventory progressed through the City of Fayetteville. As potential
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problems were identified by the inventory crews, Stormwater Division Inspectors conducted
follow-up investigations. Additionally, the major outfalls are now being field screened on an
annual basis for dry weather flows. Last of all, random screening and/or analytical sampling has
and will continue to occur in response to complaints or when an illicit discharge or improper
disposal practice is suspected.
Section 3: Obiectives
The EPA has defined an illicit connection as "the point discharge of non-stormwater not subject
to an NPDES permit through municipal separate storm sewer systems to waters of the United
States." This essentially means an unpermitted point source discharge to the storm drainage
system that eventually flows into Waters of the United States. The point source is generally
referred to as an outfall, which may include structural outfalls, such as pipes; or other man-made
drainage ways, such as ditches. The point where the draining discharge enters Waters of the
United States is considered the outfall. Detection of unpermitted discharges at outfalls is the
principal objective of the Dry Weather Field Screening Program. The secondary objective of the
Dry Weather Field Screening Program is to identify and document improper disposal practices.
In most cases, good judgement will define an improper disposal practice. Improper disposal
practices may range from discharges at structural outfalls that do not discharge directly to Waters
of the United States (e.g. an overflow pipe for a sedimentation pond), to accumulations of
discarded solid waste that can impair the quality of stormwater runoff, thereby contributing to
water pollution. The key for identifying improper disposal practices is to determine if the
discharge has the potential for impairing water quality. In addition to documenting illicit
connections and improper disposal practices, the SOP also addresses water quality risk
reductions. No discharge is actually occurring at sites identified as having water quality risk
reductions, but a risk exists. For the purpose of this SOP, a water quality risk reduction is
essentially an issue or concern that should be proactively addressed before any water quality
problems or impairment occurs (e.g. uncapped sanitary sewer line).
The dry weather field screening aspect of the program is designed to detect the presence of dry
weather discharges as an indicator of illicit connections. All dry weather discharges will be
screened for a series of indicator pollutants. If any of the indicator pollutants are present,
measures will be taken to document the occurrence, then eliminate or properly permit the
discharge. The program will be implemented to the maximum extent practicable (MEP)
standards set forth in the Federal regulations and will achieve the following goals established in
the City of Fayetteville Stormwater Plan:
1. Maintain appropriate legal authorities
• Continue administration and enforcement of the Illicit Connections and Improper Disposal
Ordinance.
2. Maintain a Storm Sewer System Base Map
• Continue to maintain storm sewer map in GIS and update as necessary to show additional
outfalls.
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3. Inspection / detection program to detect dry weather flows at MS4 outfalls
• Implement the established IDDE program.
4. Employee training
• Develop an employee training plan and procedures and conduct employee training.
5. Provide public education
• Continue to provide public information and education per established education plans and
mediums.
6. Maintain a public reporting mechanism
• Maintain a hotline that receives information from the public 24 hours a day.
Section 4: Summary of Method
Assessments will be conducted by teams walking stormwater receiving areas, such as perennial
and intermittent streams, to identify outfalls and assess for dry weather flow or other indicators
of improper disposal practices. All assessed sites will be documented through the collection of
physical and location data. When dry weather discharges are encountered, field screening will be
conducted to determine the presence or absence of indicator pollutants. Data will also be
collected on improper practices and water quality risk reductions. Digital photographs will be
used to further document all findings. All data collected on -site, for each assessed site, will be
entered onto one field data sheet. Recorded data will be used to support the field screening
database.
When dry weather flows are encountered, they will first be assessed using four sensory indicators
— odor, color, turbidity, and floatables. If any of these four sensory indicators are positive, the
dry weather flow will be tested with portable field screening kits. If the results from the field
screening kit are positive, the dry weather will be tested again within a 24-hour period (greater
than 4-hours between samples). If both samples confirm the presence of an indicator pollutant,
follow-up procedures are implemented. Follow-up procedures include collection of discharge
samples for more detailed laboratory analysis. The elements of the Dry Weather Field Screening
Program include the following:
➢ Assess all outfalls, including digital photographs
➢ When dry weather flow is discovered, conduct field screening
➢ Document improper disposal practices and water quality risk reductions, when
encountered
➢ Document all findings on provided field data sheets
➢ When warranted, implement follow-up procedures
➢ Transpose all findings into a database
The field screening approach recommended closely follows the description of field screening
guidance provided in the EPA's "MS4 Program Evaluation Guidance" document. Additionally,
this document was prepared using the format found in EPA's "Guidance for Preparing Standard
Operating Procedures (SOPs)". As an additional resource, the Stormwater Division personnel
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are directed to the document "Illicit Discharge Detection and Elimination: A Guidance Manual
for Program Development and Technical Assessments" (October 2004) for detailed information
on implementing a field screening program.
The field screening program will achieve the "effective prohibition" and reduction of pollutant
discharges to the maximum extent practical or "MEP" as required by the Clean Water Act. Field
activities will concentrate on the more urbanized areas of Fayetteville paying particular attention
to "high risk" potential source areas.
Section 5: Health and Safety Warnings
Safety is paramount. All personnel involved in field screening and follow-up activities should
review and consider the safety topics presented within this SOP. This information is presented
for the express purpose of promoting awareness of potential hazards that may be encountered
during field screening but is not designed to address all possible hazards.
Because hazards exist, US Infrastructure of Carolina, Inc. recommends at least two team
members participate on each field screening team. The primary safety risk associated with
screening activities is heat -related injuries. Due to the nature of this physically demanding work,
the Stormwater Inspections Supervisor and individual team members will need to arrange for
ample water that is readily available. Other medical concerns include falls, cuts, abrasions,
possible exposure to noxious plants, and insect or snakebites.
Prior planning is essential to reduce safety mishaps and accidental injuries. At a minimum, first
aid and snake bite kits should be readily available during all fieldwork. Adequate precautions
will be observed during sample collection, including the use of personal protective equipment,
such as latex gloves and eye protection. Communication with field teams will be necessary.
Cellular phones, or other means of communication such as 2-way radios, will be provided to each
field screening team by the Stormwater Division. All emergencies or accidents will be
immediately reported to the Stormwater Inspections Supervisor.
Prior to initiating field activities, the nearest medical treatment or emergency care center will be
identified and emergency phone numbers will be provided to all participants. Because some
areas to be assessed will be remote, it is also recommended that the Stormwater Inspections
Supervisor develop a medical emergency evacuation plan for each specific field area.
Section 6: Personnel Oualifications
This SOP is written specifically for City of Fayetteville field screening team members. Team
members will need to go through the established training program outlined in Section 8.2. In
addition to the training program, precise map reading and good navigation skills are a
prerequisite for field screening team members to ensure accurate map locations of identified
discharges. Each team member should be familiar with basic land navigation orientation and
map reading.
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Section 7: Equipment and Supplies
The reader is referred to Appendix A. This attachment lists equipment, for both field screening
and follow-up sampling. The initiation of follow-up procedures, including the possible
collection of analytical samples, will require some specialized sample collection support
equipment. The equipment list referred to as Appendix A is the minimally needed equipment for
each sampling team. If samples are being collected for laboratory analysis, technicians at the
supporting laboratory should be contacted for special instructions concerning sample containers
and handling procedure.
Section 8: Field Screening Program
8.1 Establish a Field Screening Program Schedule
In order to facilitate the management of the Dry Weather Field Screening Program, sites were
assessed on a major drainage area basis. There are fifteen major drainage areas in the City of
Fayetteville (See Figure 1 on the next page) covered by the NPDES Permit. Field screening
activities occurred in each major drainage area immediately following completion of the
infrastructure inventory. This schedule was most preferred since the results of the inventory were
used to support any follow-up activities that were necessary, thereby reducing the time spent on
illicit discharge and improper disposal investigations. Additionally, procedures were
implemented for survey crews to document suspect illicit discharges and improper disposals
during their normal survey duties associated with the infrastructure inventory. Potential illicit
discharges and improper disposals discovered by the survey crews were documented and
followed -up on by the Stormwater Division Inspectors. This schedule proved to be the most
productive by allowing field screening assessors to concentrate on suspect problem areas.
The infrastructure inventory was initiated in the Little Cross Creek Basin in 1999. Therefore, the
initial field screening and follow-up efforts were conducted in Little Cross Creek Basin following
completion of the inventory. Subsequent field screening and follow-up efforts were conducted in
each basin following the completion of the infrastructure inventory in that basin.
In addition to identifying potential illicit discharges and improper disposal activities during the
infrastructure inventory, the Stormwater Division identified 279 major outfalls (36 inches and
larger) that discharge to Waters of the State. Each of these major outfalls was located in the field
and initially screened for any dry weather flows and any evidence of illicit discharges or
improper disposal. Follow-up investigations were conducted as necessary. Additionally and in
an effort to detect any future illicit discharges or improper disposal activities, these major outfalls
are now typically being field screened by the Stormwater Division Inspectors on an annual basis.
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NPDES Permit No. NCS000246 — Dry Weather Field Screening SOP October 20, 2014

Legend
MAJOR WATERSHED BOUNDARY
FAYETTEVILLE CITY LIMIT
Figure 8-1: Major Watersheds
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8.2 Establish an IDDE Training Program
Multiple training opportunities are included for implementing the Field Screening Program. The
training will be twofold, encompassing both field screening activities and follow-up procedures.
Training will include a limited amount of classroom instruction with most learning occurring
through hands-on application. Classroom instruction will include review of the concepts and
procedures presented in the Field Screening and Follow-up SOP, concentrating on the technical
and legal issues related to sample collection. Other issues included in the classroom portion of
training include:
➢ The use and handling of test equipment
➢ Sampling Procedures
➢ Recording data and documentation
The hands-on application based training will follow a train -the -trainer format. Basically, an
experienced sample collection technician - who has conducted field screening and follow-up
activities - will work with Stormwater Division staff during the initial pilot field screening
activities, or when requested. Upon completion of the pilot study, Stormwater Division persons
will continue to implement the program, adhering to the SOP. As new staff members begin to
participate in the field activities, they will be trained through a combination of exposure to the
Field Screening and Follow-up SOP and by other trained personnel.
8.3 Establish a Field Screening Program
8.3.1 Legal Authority
In 1997, an Illicit Connection and Improper Disposal (ICID) Ordinance was adopted by the
Fayetteville City Council. The ordinance supports field screening efforts by prohibiting
placement, deposition, or discharges of anything other than stormwater runoff into the storm
drainage system. There are few exceptions — but in general the ordinance is inclusive. The
ordinance further provides the Stormwater Division with right -of -entry onto private property
including any buildings. The ordinance details the timelines allowed for the removal of illicit
connections and civil penalties associated with violating local regulations.
8.3.2 Field Procedures
8.3.2.1 General Field Screening Procedures
The objective of field screening is to provide an effective means of detecting pollutants in dry
weather flows as an indicator of illicit connections and/or improper disposal practices. Most
field screening assessments will occur at outfalls and stormwater receiving areas. Follow-up
procedures will generally require tracking the discharge up into the drainage system until the
source of the discharge is uncovered. Follow-up procedures are detailed in Section 9 of this
SOP.
The location of each observed illicit discharge or improper disposal and water quality risk
reduction should be plotted on field maps provided to each field screening team. The physical
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description and map location of each illicit discharge or improper disposal will be used for
follow-up activities and to assist in developing a citywide illicit discharge and improper disposal
database.
The most time consuming portion of these assessments will be in the more populated areas where
there is a higher density of stormwater outfalls. The intent is to walk the entire stormwater
receiving areas for all residential, commercial, and industrial areas. As for the more rural areas,
where few drainage structures are expected and most land use is agriculture, the assessment will
be limited to receiving waterway intersections with roads. In these cases, waterways will be
assessed for an illicit discharge or improper disposal approximately 200 yards beyond the
roadway. Unlined drainage ditches that discharge into Waters of the State will be assessed as
outfalls.
Responsibilities. The City of Fayetteville Stormwater Inspections Supervisor will supervise and
manage the Field Screening Program. Responsibilities include training assigned field
technicians, recruiting the work force, providing map coverage for areas to be screened,
assigning areas of responsibility, providing and maintaining necessary assessment equipment,
quality assurance, and data management. Summary checklists outlining the general
responsibilities for the Stormwater Inspections Supervisor and Field Screening Team members
are included in Appendix B.
8.3.2.2 Pre -Assessment Phase
Weather Monitoring. The Stormwater Inspections Supervisor will be responsible for
monitoring local weather patterns prior to initiating field screening activities. Weather
monitoring should include a combination of precipitation data reported by local weather
monitoring services, such as National Oceanic and Atmospheric Administration (NOAA)
weather station data, rainfall data from the Fayetteville Regional Airport, and rain gauge data
from existing rain gauges throughout Cumberland County. In accordance with the NPDES
regulations, dry weather field screening can only occur following 72 hours without significant
precipitation (<O.1 inch).
Assessment Team Coordination. Due to the aforementioned requirement to only conduct field
screening during extended periods of dry weather, many field events may be cancelled due to
unexpected precipitation. It is imperative that the Stormwater Inspections Supervisor maintains
an updated roster of all field team members' telephone numbers. The Stormwater Inspections
Supervisor should contact all team members prior to the assessment to provide on -going
information on weather conditions and project status.
Data Review. In addition to monitoring weather patterns and maintaining contact with
assessment teams, the Stormwater Inspections Supervisor must also review all available data
prior to initiating any field assessments. At a minimum, the Stormwater Inspections Supervisor
will review the list of outfalls included in the infrastructure inventory and the identified "suspect
illicit discharges and improper disposals" documented by survey crews during the inventory.
These sites should be included on the field maps and teams should be made aware of the
presence of these possible illicit discharges and improper disposals and the need to assess them.
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Public Notice. Prior to initiating screening efforts through residential or private properties, the
Stormwater Inspections Supervisor will be responsible for notifying landowners of the intent of
the sampling program and the date(s) field screening activities are scheduled through their
respective communities. Notification may occur through a variety of mediums, to include:
television or radio announcements, mail outs, fliers, or door hangers. For residential areas, prior
contact with homeowner's associations is recommended.
Additionally, each member of the field screening assessment team will be issued a uniform that
designates team members as "Fayetteville Stormwater Division Water Quality Team". These
uniforms (tee-shirts) will assist with identification and increase public awareness of the on -going
program. Team members will also carry identification business cards with a list of supervisory
personnel and the Stormwater Division Hot Line number, [phone]. These cards will be
distributed when field teams encounter citizens who wish to contact the Stormwater Division for
additional information.
8.3.2.3 Assessment Phase
Field screening teams will include one team leader and one field technician. Prior to field
screening activities, the Stormwater Inspections Supervisor will contact each team member to
confirm in -brief meeting times, assigned tasks, and inform individuals on their areas of
responsibility. The Stormwater Division will provide transportation, equipment, maps, and other
necessary supplies to the assessment teams.
In addition to assessing outfalls for discharges, field personnel will also note improper disposal
practices and water quality risk reductions, both of which may result in water quality degradation.
The primary difference in improper disposal practices and water quality risk reductions are that
improper disposal practices are affecting the quality of stormwater runoff. In contrast, water
quality risk reductions are potential problems that are not currently affecting or degrading water
quality, but have the potential to pollute. An example of a water quality risk reduction would
include an open sanitary sewer stand pipe that is not discharging onto the ground surface but
poses a risk. When water quality risks are observed, the risk will be described on the datasheet,
along with its location and digital photographs. All noted water quality risk reductions should be
incorporated into on -going public education programs.
Field screening assessment teams will collect four types of data, including:
➢ Site -Specific Observations
➢ Location: Map Points
➢ Digital Photographs
➢ Analysis of Discharges
All data collected will be noted on the Dry Weather Field Screening Checklist (Appendix C).
Site -Specific Observations. The two -person field screening teams will locate and assess all
stormwater conveyances and associated dry weather discharges as they walk areas where illicit
discharges or improper disposals are expected (e.g. intermittent and perennial streams).
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Datasheets will be completed for ALL assessed sites, to include, illicit discharges and improper
disposals, all outfalls, and water quality risk reductions. This information will provide data on
the number of sites considered versus the number of sites with actual discharges.
The general appearance of each site will be noted and a site diagram transcribed onto the
datasheet in the space provided. The diagram should include a description of the outfall, notable
deposits, stressed vegetation, and/or the presence of aquatic biota in the receiving waterway.
During the initial assessment, team members will verify the presence or absence of dry weather
flow. If dry weather flow is encountered, specific physical and visual data related to the
discharge will be entered onto the datasheet, these include odor, color, turbidity, and floatables.
If any of these four sensory indicators are positive, the discharge will then be chemically
analyzed (i.e. field screening) for specific compounds. Physical data should include a site
description, flow estimation, and predominant land use. Descriptions of outfalls, or other
structures, should include dimensions, sizes, general condition, material of construction, and any
apparent structural concerns. When the outfall is an open conveyance, such as a man-made ditch,
information on the width and depth of the conveyance will be noted on the datasheet.
Location: Map Points. The location of each assessed site or outfall will be noted on field maps
provided to each field screening team.
Once a site is identified for assessment, the site will be numbered by date and sequential number
based on a pre -determined database layout coordinated through the City of Fayetteville's
geographic information system (GIS) staff. The identifying nomenclature will be noted directly
on the field map and also on the datasheet. The Stormwater Inspections Supervisor will be
responsible for collecting all data from the field maps to re -plot each location on a master
inventory map.
Digital Photographs. Digital photographs will be collected every time a datasheet is completed.
When a dry weather flow is encountered, photographs will be taken of the receiving area, the
discharge, and the potential source of the discharge. The intent is to fully document the
discharge while on site. If digital cameras are not available, disposable 35mm cameras are
recommended.
In order to facilitate photograph identification during the data management phase, 4-inch by 6-
inch field index cards will be marked with the serial number or other locator of the assessed site
in bold letters and included in each photograph.
Analysis of Discharges. When dry weather flow is observed, it will first be assessed using four
sensory indicators — odor, color, turbidity, and floatables. If any of these four sensory indicators
are positive, portable field screening kits will be used to assess the presence or absence of
specific indicator chemical compounds
Field screening teams will collect and analyze samples with portable field screening test kits
immediately following a positive assessment of one of the four sensory indicators from a dry
weather free flowing discharge. The sample point for the discharge will be marked with colored
tape, stakes, fluorescent spray paint, or other landmarks in a manner that will allow future
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identification without sole reliance on memory or personnel recollection. A second visit to the
site will be conducted within 24-hours (with a minimum period of four hours between samples)
to confirm screening results. If both field screening analyses indicate the presence of indicator
pollutants, the site will be considered a confirmed illicit discharge or improper disposal. At this
point, the Stormwater Inspections Supervisor may initiate follow-up procedures.
Portable field screening test kits will be utilized to detect the presence or absence of specific
chemical compounds. The sample analysis for the field screen will be conducted using the
following:
1) Horiba U-5000 Multi -Parameter Water Quality Meter,
2) HACH Total Chlorine Test Kit, Model CN-70T, and
3) HACH Detergents Test Kit, Model DE-2.
The Horiba U-5000 Multi -Parameter Water Quality Meter has the capability to measure the
following parameters:
1) pH
2) Oxidation Reduction Potential (ORP)
3) Dissolved Oxygen
4) Conductivity
5) Salinity
6) Total Dissolved Solids (TDS)
7) Seawater Specific Gravity
8) Temperature
9) Turbidity
All tests will be conducted for each discharge having a positive confirmation for one of the four
sensory indicators. When collecting the discharge samples, field screen personnel must be
careful not to contaminate the collected samples. Eye protection and latex gloves will be worn
during sample collection to protect the integrity of the sample and also protect the personnel from
possible contaminants
The Stormwater Inspections Supervisor will maintain test kit inventories and other sampling
equipment.
8.3.2.4 Post -Assessment Phase
Field Screening Database Management. A GIS-compatible database will be used to maintain
the location of all sites considered and assessed during field screening activities. It is imperative
that the database program employed be designed to store the field screening data results, analyze
data, and generate reports. The program should be able to flag areas where similar type problems
are occurring. The reports generated should include trends in data over time, statistical analysis
of results, and identify repeat offenders.
There are numerous commercial database packages available that can be used to manage the field
screening data set. The program used should be compatible with the City of Fayetteville's
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existing GIS capabilities. It is not necessary that the data be part of the overall GIS data set, but
only that the GIS system (and other systems) can access it.
Long-term GIS capabilities may include a digital map with `hot links' to digital photographs of
assessed sites and electronic data sheets. The goal is to maintain a dynamic system where
geographic problem areas may be readily identified and reasonable solutions implemented.
Section 9: Follow -Up Procedures
Follow-up investigation procedures to identify pollutant sources or source areas can be an
expensive and time consuming task. The investigation techniques employed may vary greatly
based on geographic constraints, types of pollutants, knowledge of infrastructure and other
issues. The intent of follow-up procedures, as presented, is to provide a general framework to
initiate the investigative process. The Stormwater Inspections Supervisor should incorporate site
specific concerns as he or she directs the investigation.
When analysis of field screening data indicate conditions that suggest an illicit discharge or
improper disposal, the field screening team will notify the Stormwater Inspections Supervisor or
Stormwater Manager. Sites will be considered for follow-up investigation when two field
screening chemical analysis collected within a 24-hour period both indicate positive results. The
team must document an accurate location and physical description of the site during the initial
assessment. The Stormwater Inspections Supervisor will be responsible for initiating and
coordinating the follow-up investigations.
Individual field screening teams (or others) may be assigned the task of conducting follow-up
investigations, as deemed necessary. When assigned follow-up investigations, teams will usually
begin with less complex methods of source identification, such as document review and
reconnaissance, and lead into more complex methods like additional field investigations. In
some circumstances, analytical sampling may be required.
9.1 Reconnaissance
Follow-up investigations of possible illicit discharges and improper disposal practices should
begin with a review of all possible source areas located in the vicinity of the discovered pollutant
discharge. Valuable information may be easily obtained from GIS maps, industrial NPDES
facility maps, pollution incident databases, infrastructure inventory data, etc. The location of
many of these potential source areas is maintained in databases by the Stormwater Division. If
not available through the Stormwater Division, sources may be available through various
NCDENR resources. A summary of possible source areas should be assimilated to guide further
investigation efforts.
The next phase of the reconnaissance is to revisit the outfall where the suspect pollutant
discharge was discovered. Additional water quality tests or field screening may be conducted at
this time to determine pollutant concentrations and to identify other possible "marker" pollutants
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in the discharge. In some cases, analytical data coupled with research material may uncover the
source, if not; then additional fieldwork will be necessary.
9.2 Field Investigation
If reconnaissance efforts do not yield the source of the polluting discharge, a field investigation
will probably be necessary. The field investigation should include a walk-through along the
conveyance system, moving from the point of discharge up into the system. Access to the
infrastructure inventory is an invaluable asset for this process. As the follow-up team is
conducting the walk-through, they may employ field screening or other methods to aid in
tracking the source of the discharge. The follow-up team will check access points as they move
further up the system, conducting field screening analyses as they progress. Field screening
efforts will follow the trace for one or more marker pollutants, as supported by field screening
analysis, until the pollutant ceases to exist in the flow. The goal is to isolate the potential source
area between two known access points.
Once two access points have been found, one with pollutants and one without, a more detailed
investigation for an illicit discharge is recommended between the two points. This may be
achieved by employing one of many different methods, which include; smoke tests, dye tests, or
in -pipe sewer cameras.
Once the possible source (infiltration, illicit connection, illegal dumping etc.) is located, more
detailed laboratory analysis may be required to fingerprint the pollutants.
9.3 Analytical Samples
Occasionally, follow-up procedures may include the collection of a discharge sample for delivery
to a North Carolina certified laboratory for detailed analysis. These analyses can be expensive
and should only be conducted when other measures have failed to uncover the source of the
discharge. Analytical sampling will be conducted at the discretion of the Stormwater Inspections
Supervisor. Analytical samples may be necessary to assist in the source investigation or when
enforcement action is being actively pursued.
Because field screening analysis only provides data for indicator pollutants, more detailed
information about the source of the discharge may be obtained through laboratory analysis. For
instance, a discharge that tests positive via field screening for detergents may have many
different potential sources, to include; commercial car washes, laundry services, industrial
process water, or a sanitary sewer illicit connection. A positive laboratory analytical test with an
unusually high concentration of coliform bacteria may serve as additional "proof' that the
discharge is from a sanitary sewer source, thereby narrowing the extent of investigation.
Another situation where laboratory analytical services may be of value is when the Stormwater
Division pursues enforcement actions against a known violator(s). In most cases, field screening
will not withstand legal challenges due mostly to a lack of precision and accuracy with the
screening methodology. Laboratory analytical samples, in contrast, are much stronger in terms of
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legal defense. Additionally, the laboratory analysis may also provide detailed information on
specific chemicals only used by or discharged by the violator(s).
Regardless of the need for analytical samples, if collected it is important to strictly follow
laboratory procedures and protocol. The intentional misrepresentation of sample results
could lead to fines and possibly criminal charges.
9.3.1 Analytical Sample Documentation
The collection of analytical samples for laboratory analysis requires specific documentation be
prepared for each submitted sample. The required documentation will vary from laboratory to
laboratory and should be coordinated prior to sample collection. In most cases, the contract
laboratory will provide sample request forms, sample labels and seals, blank chain -of -custody
documents, coolers, and sample containers. The Stormwater Manager will collect these supplies
from the laboratory on an as -needed basis. The following discussion serves to familiarize staff
with the basic documentation requirements.
Field Notes. A record of every sample collected for laboratory analysis should be included in the
field inspector's notes. Records should include the sample requested and the reasoning for the
specific analytical test. Other important information may include weather conditions at time of
sample collection, visual observations of discharge, and field screening results.
Sample Request. Sample request forms are usually included in the sampling package provided
by the laboratory. A sample analyses request will accompany each sample to the contract
laboratory to dictate the desired method of analysis (tells the laboratory what to sample for). In
most circumstances, the form will list all analyses performed by the contract laboratory with
check boxes for each test method. If an inspector is unsure of the exact analytical test method
number, contact the contract laboratory for a list of methods and testing criteria.
The standard analytical sample methodology for follow-up analysis should be directed at
compounds suspected in the discharge or compounds used by the "most probable" source. If the
exact source is not known, a general analysis may be conducted to assist in source identification.
A recommended general analysis may include those listed in Table 9-1 on the following page:
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Table 9-1: Recommended General Analvsis
Recommended Field Screening Anal ticals
Biochemical Oxygen Demand (BODO (mg/1)
Total Phosphorus (P) (mg/1)
Chemical Oxygen Demand (COD) (mg/1)
Dissolved Phosphorus (P) (mg/1)
Total Suspended Solids (TSS) (mg/1)
Total Recoverable Zinc (Zn) (mg/1)
Total Dissolved Solids (TDS) (mg/1)
Total Recoverable Copper (Cu) (mg/1)
Total Kjeldahl Nitrogen (TKN) (mg/1)
Total Recoverable Lead (Pb)(mg/1)
Nitrite + Nitrate Nitrogen (N) (mg/1)
Total Recoverable Cadmium (Cd) (mg/1)
Oil & Grease (mg/1)
Fecal Coliform (FC) (MPN/100 mL)
If site conditions indicate suspect discharges of either pesticide/herbicide/fertilizer (PHF) or other
organic compounds (e.g. petroleum -based products), more compound specific analysis may be
required. This analysis may include analytical method EPA 608 for suspect PHF discharges and
/or analytical methods EPA 6210 D (volatile) or EPA 625 (semi -volatile) for suspect discharges
of petroleum -based products.
Sample Labels. Each container used for collecting analytical samples must accurately identify
the sample, preferably by attaching a tag or label directly to the container. These tags will
provide sufficient information for positive sample identification, including the name of the
sample collector, the date, hour, location, and other data, such as preservatives used, weather
conditions, sample handling, etc.
Sample Seals. Following the collection of a sample, the cap of each sample container will be
securely placed on the container. A strip of security tape provided by the laboratory will be
placed over the cap so that it forms a bond between the sample container and sample container
cap. This procedure will allow for the detection of any unauthorized tampering with the sample
between the time of collection and delivery to the laboratory.
Chain -of -Custody. The chain -of -custody provides a mechanism to trace sample possession
from time of collection through analysis and final disposition. A Chain -of -Custody (COC) will
be required for every sample collected for laboratory analysis. The time analytical samples are
collected, the date, and the location of the outfall will be recorded on the chain -of -custody forms
provided by the laboratory. A copy of the chain -of -custody will be attached to the field screening
worksheet and maintained in a public file.
9.3.2 Sample Collection and Handling
Sample Collection. During follow-up sampling, special precautions are necessary. When
collecting discharge samples, sample containers must be handled in such a way, as they do not
become contaminated before they reach the laboratory. Before filling the sample container, rinse
the bottle with the discharge being sampled, unless the bottle contains a preservative. If a
preservative is required for the specific test method, fill the sample container with the discharge
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without pre -rinsing. Unless otherwise noted, fill the laboratory provided container as full as
possible. Because many of the constituents may be present in concentrations of micrograms per
liter, they may be totally or partially lost if proper sampling and preservation procedures are not
followed.
In most cases, field teams will collect samples for analysis directly from discharging outfalls.
However, during follow-up procedures, field teams may be tasked with collecting samples
further up in the drainage system possibly gaining access to the storm drainage system through
manholes. If necessary, field teams will collect samples from manholes remotely by employing a
portable pump. At no time will field inspectors enter storm drain manholes. This procedure
requires confined entry certification and can present certain safety hazards.
Some set-up will be required to remotely collect samples from drainage manholes via use of a
portable pump. Prior to beginning the set up you will need to ensure safety cones are employed
and appropriate measures have been taken to protect field team members from passing vehicles.
To prepare the peristaltic pump, first install new tygon tubing securely onto the pump head. The
next step is to cut a piece of polyethylene tubing, ensuring it is long enough to reach the
discharge inside the manhole. An in -line (2-stage) pump filter will be fitted on the new piece of
polyethylene tubing. New tubing must be used for each sample collected.
After the equipment is set up, attach the pump electrodes to the portable power source. The
intake of the polyethylene tubing should then be lowered into the discharge. In some cases, a
weight may be necessary to fully extend the tubing into the discharge. Once the tubing is fully
immersed, turn on the pump and collect the sample. After the sample is collected, follow normal
sample handling procedures.
Discard all used tubing and filters between each sample collected. The use of old or used tubing
can result in inaccurate results due to sample contamination.
Sample Storage. To minimize the potential for volatilization or biodegradation between
sampling and analysis, samples should be kept as cool as possible without freezing. Immediately
after the sample is collected, labeled, and sealed, it should be packed in crushed ice. The
laboratory will provide ice coolers for this purpose. Use chemical preservatives only when
required by the laboratory.
Refer to Appendix D, Analytical Sample Checklist, for additional information.
9.4 Notification
The Stormwater Manager, or designated representative, will be responsible for notifying the
suspected violator(s) following discovery of a possible pollutant discharge. At a minimum, the
notice should include the following: 1) characteristics of the discharge, 2) reasons for suspicion,
3) regulatory requirements that prohibit illicit discharges and / or improper disposal to the MS4,
and 4) permitting opportunities, if applicable. The notice should be delivered by certified mail to
ensure receipt. The potential responsible party whom the Notice is directed to should be afforded
an ample period of time to respond to the Notice, in accordance with local ordinances.
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After the suspect discharger is notified, follow-up crews may want to conduct either announced
or unannounced visits to the suspected property for more exact inspections. Once the source is
identified, the responsible party will be required to either eliminate or permit the source of
pollutants.
It should be noted some non-stormwater discharges are not considered illicit or improper unless
they are determined to be a significant pollutant source. These discharges (foundation drains,
water line flushing, etc.) are listed in the City's Illicit Connections and Improper Disposal
Ordinance. The responsible party for these sources will not necessarily be cited as a violator;
however, the discharge should still be documented.
Section 40: Data and Records Management
All data collected through implementation of the Dry Weather Field Screening and Follow-up
Program will be entered into a database, with attribute fields approved by the City of
Fayetteville's GIS staff. This data will be reviewed on an on -going basis to identify geographic
problem areas and determine the need to modify monitoring efforts based on confirmed
discharges. The results of the field screening and follow-up procedures will be incorporated into
the City's Annual Reports.
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Appendix A: Equipment List for Field Screening and Sampling
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Field Screening Equipment
• First Aid Kit
• Horiba U-5000 Multi -Parameter Water Quality Meter
• HACH Total Chlorine Test Kit, Model CN-70T
• HACH Detergents Test Kit, Model DE-2
• Digital Camera
• 2-way Radios (or cellular phones)
• 100-foot Tape Measure
• Colored Flagging Tape
• Fluorescent paint
• 4-inch x 6-inch Index Cards
• Permanent Marker
• Clipboard and Pens
• Cooler for drinking water
• Insect repellant
Follow-up Equipment (in addition to the Field Screening Equipment List)
• DC Powered Peristaltic Pump with variable speed control
• In -line (2-stage) Pump Filter
• 0.045 micron Sample Filters
• Tygon tubing for the pump head
• Polyethylene tubing for remote sampling
• Pry Bar and Leather Gloves (for lifting manhole covers or grates)
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Appendix B: Field Screening Tasks Checklist
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Field Screening Checklist - Stormwater Inspections Supervisor
1. Store and maintain screening equipment.
a) Ensure each field screening kit is adequate for screening event.
b) Ensure digital cameras remain functional.
c) Do not store any equipment with batteries installed.
2. Remain aware of weather conditions.
a) Monitor rainfall 4 to 7 days prior to field screening and during screening events.
b) Keep teams informed of impending storms or precipitation events.
c) Coordinate with each team member prior to mobilization.
3. Distribute all necessary equipment, forms, and maps prior to the field screening activity.
a) Provide guidance to team members for digital cameras.
b) Verify map reading and navigation skills.
4. Prioritize and coordinate follow-up investigations following discovery of an illicit discharge or
improper disposal.
a) Supervise reconnaissance.
b) Coordinate with contract laboratory as necessary.
c) Ensure all labeling and chain -of -custody requirements are correct.
d) Initiate enforcement action as necessary.
5. Maintain original records and documentation for at least five years.
a) Include field notes, maps, and follow-up actions.
b) Maintain a master illicit discharge and improper disposal map.
c) Coordinate with GIS for access to outfall location data.
6. Review the Field Screening SOP annually and update as necessary.
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Field Screening Checklist — Team Members
1. SAFETY — SAFETY — SAFETY
a) Never leave your field partner.
b) Wear appropriate safety equipment (eye protection, latex gloves, etc.)
2. Report all accidents or emergencies to the Stormwater Inspections Supervisor.
3. Ensure the following personnel items are provided or available for field work:
a) Field boots, hat, backpack, and sunblock.
b) Canteen with water.
c) Clipboard, waterproof pens/pencils.
d) Wrist Watch.
4. Ensure Field Screening Worksheet is complete and accurate.
a) Note and record arrival time.
b) Record all pertinent site information.
c) Note any damaged drainage structures or other unusual conditions.
5. Become familiar with field screening test kits and other equipment.
a) Clean all equipment and assist with equipment maintenance.
6. Provide feedback to the Stormwater Inspections Supervisor as to difficulties encountered or
possible improvements to the field screening protocol.
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Appendix C: Dry Weather Field Screening Checklist
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STORMWATER DIVISION DRY WEATHER FIELD SCREENING CHECKLIST
Site Location
Sampler's Name:
Sampler's Name:
Sample ID:
Date:
Time:
Hours Since Last Rainfall:
Stage Reading:
Air Temp:
Stage = Flow Rate of cfs
Water Temperature:
Flow pH:
Turbidity:
Sp. Conductance:
Dissolved Oxygen
Visual Observations:
Yes
No
Oil Sheen
Foam
Litter & Trash
Dead Fish
Live Fish
Dead Amphibians
Live Amphibians
Crayfish
Water Bugs (insects)
Mussels
Algal Growth
Color of Water
Odor from Water
Suspected Illicit Discharge?
Comments:
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City of Fayetteville Outfall Sample Sheet
Date/Time Analyst Outfall Location Detergents Total C12
Sampled
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Appendix D: Analytical Sample Checklist
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Analytical Sample Checklist
1. Coordinate with laboratory in advance of conducting field screening activities.
a) Secure about five sample "packages" from the contract lab. Ensure each kit has appropriate
sample containers, bottles, labels, chain -of -custody etc.
b) Consider pre -labeling at least one set of sample containers.
2. Coordinate with Field Screening Team to determine the location of discharge.
a) Find the discharge.
3. Observe discharge and note any unique site specific conditions.
a) Note flow rate.
b) Speculate on possible source areas.
c) Assess discharge for petroleum odor or sheen.
d) Assess area for stressed or dead vegetation.
4. Use safety equipment (eye protection and latex gloves).
5. Sample collection process.
a) Oil & Grease (glass bottle with preservative).
• DO NOT rinse bottle in discharge prior to sample collection.
• Fill container.
b) Other samples (plastic containers)
• Rinse sample containers in discharge.
• Fill containers.
c) Place all samples on ice in the provided cooler as soon as possible.
d) Complete chain -of custody and other required forms.
e) Deliver samples to the contract laboratory.
6. Return all unused containers to the laboratory upon completion of field activities.
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