NCS000434_IDDE Program_20191217

Illicit Discharge Detection and Elimination (IDDE) Program —City of Archdale Summary
Revision —2019
The following document has been prepared and shall be modified as necessary. As part of the ACE
Integrated Stormwater Management Program, utilization of other day to day functions throughout the
city remains an integral part of compliance. Many of the annual monitoring and day to day activities
continue to be performed as a result of other functions necessary.
Overview
An illicit discharge is generally any discharge, release, or pumping of a pollutant or polluted water into
the stormwater system. The National Pollutant Discharge Elimination System (NPDES) regulates the
discharge of stormwater under the authority of the Federal Clean Water Act. The Department of
Environmental Quality (DEQ) Division of Energy, Mineral & Land Resources Stormwater Program has the
designated authority to administer the Minor Individual NPDES within the state of North Carolina. Under
this authority, DEQ has issued the Minor Individual NPDES permits regulating the discharge of
stormwater. The City of Archdale is under the regulation of the Minor Individual Phase II Municipal
Stormwater Permit issued on May 15, 2017. The current Phase II permit will remain in effect until
February 19, 2022, after which a new Phase II permit will be issued.
The Phase II permit mandates permittees to prepare and implement an Illicit Discharge Detection and
Elimination (IDDE) program. This plan as authorized by the City Council on February 2, 2008 and its
implementation satisfies this requirement and maintains a regulatory mechanism for enforcement. The
goal of this plan is to identify and then eliminate illicit discharges. Examples of illicit discharges include
but are not limited to: Direct or indirect sanitary wastewater discharges that connect to the storm sewer
or watercourse, such as a shop floor drain connected to a storm drain, a cross -connection between the
municipal sanitary sewer and storm sewer systems, a damaged sanitary sewer line that is leaking
sewage into a cracked storm sewer line, or a failing septic system that is leaking into a water course.
Materials (e.g., used motor oil) that have been dumped illegally into a storm drain catch basin. Improper
home or business owner activities such as washing paint brushes into a catch basin, washing new
textured concrete driveways into a storm drain, draining swimming pools to the storm system
(swimming pools have high pH, chlorine, or minerals and salt), excess use of fertilizers, or washing cars
with chemicals that enter the storm drain system. This monitoring of the city system includes the listing
of PART 1 PERMIT COVERAGE, Subparagraph H.2. In terms of risk assessment, the main receiving waters
is a tributary identified as WS-IV 17-19-(1) with an approximate reach of 5.89 miles, a valley of 5.10
miles, and a sinuosity of 1.155. The buffer of undeveloped land associated with 47 parcels of property
amounts to 990.27 acres and the potential commercial development consists of 79.26 acres (which is
approximately 7.11% or less than 1% of the corporate city limits of the City of Archdale. In addition, by
regulation, the maximum amount of development allowed on the commercial sites is 55.48 acres or

5.48%. As a final point, the largest city maintained culvert is 192-inches located in the Bradford Downs
Subdivision. This culvert installed (circa 2000's) has an exit point with a wide mouth and significant
meadering and has a capacity in a 5-inch per hour intensity of 4 times the existing acreage of the
corporate city limits. This discharge follows a path through the 100-acre Creekside Park where children
fish "catch and release" before heading downstream outside of the city limits. (See TAB 9, Photograph
A42 for current condition of outfall)
Currently, the City of Archdale maintains several day to day mapping of infrastructure obtained from
multiple sources over the years i.e., multiple jurisdiction coverages of GIS data, AutoCad drawings, and
As -Built submissions. As time permits, layers are modified and combined as part of a long term initiative
not reflected in the conditions of the permit. The majority of the mapping is contained on layers in a GIS
format database. However, a secondary non-GIS map is also utilized in the office of the Stormwater
Manager which depicts locations of extreme saturation due to changes in weather experienced over the
years, street mapping and paving maintenance. (See last page of this summary, photograph of existing
day to day auxillary map)
Currently in the City of Archdale, only one septic tank system is known to be utilized at 10223 North
Main Street Archdale, North Carolina 27263-2809. This location may be affected by the planned turn
around scheduled in the future for the North Carolina Department of Transportation Improvements
Project. The incorporated boundary of the city of Archdale is approximately 8.65 square miles in two
counties — Guilford and Randolph. However the majority of the corporate city limits is in Randolph
County. The majority of the city system is roadside ditches visual along the roads and are vegetated
grass swales maintained by the residents approximately > 80 percent of the connectivity. The largest
length of catch basin and pipe system exists on the main corridor controlled by the North Carolina
Department of Transportation I,e., All bridges in the corporate city limits are also under the control of
the North Carolina Department of Transportation. Although there are some minor stream tributaries in
the City of Archdale, the largest collector is an unnamed tributary of Muddy Creek meandering through
Creekside Park. This collector does sustain habitat in which children and adults regularly fish using
"catch and release" along the banks.
A map of all structural BMPs owned, operated, or maintained in the city is contained on a GIS layer. The
Public Works Department maintains a list of large pipes (on the order of 24-inch or larger) and routinely
checks for obstructions before and after rain events. Currently these locations are identified on the
mapping in the Stormwater Managers' office as well as by the Public Works personnel. Tributary
conveyances (type, material, and size where known), associated drainage areas, and land use are
maintained and generated by AutoCad (Last iteration of LIDAR layer produced 518 sub -basins
throughout the corporate city limits. Although most of the watercourses and pipes have a cross -
sectional area less than a 24-inch diameter pipe with a configuration of a partial cross -sectional area i.e.,
one quarter to one half vegetated bottom of pipe. These pipe outfalls allowing for driveway crossings
are routinely viewed under (dry weather) conditions throughout the City as part of the response to
citizen inquiries. We are approximately at the half way point of the initial inception of the ACE

Integrated Stormwater Management Program which by Council Action occurred on January 2,2008. The
initial implementation and assessment of the todays' program was established by Mr. D. J. Seneres, PE,
PWLF. Shortly after the inception, during a period of time commencing on September 29, 2008 and
ending on October 14, 2008, Mr. Seneres visited every single residential and commercial lot changing
out 20-gallon open container recycling bins and replacing them with 85-gallon closed lid containers. This
procedure established two significant mindsets of the existing program. One, changing out the type of
container for recycling significantly reduced the contribution of trash to our waterways and more
importantly, established a mindset that other functions could also be used for the purposes of
maintaining, assessing, and improving our receiving waters. During this implementation, every location
was walked and assessed as related to the stormwater conveyances in the right-of-ways and the date of
the assessment was documented by the implementation date as maintained on a spreadsheet
maintained on the City of Archdale server. It also reiterated that as authorized by Congress and set by
the Budget Office that the maximum fine for knowingly violating the Clean Water Act of 1972 was
$26,000.00. Of course, today, approximately 10 years later, the maximum fine set by Congress is
$51,575.00 Through education and outreach, the mindset is now a cultural part of the our approach
that we have an obligation to protect and if we choose to not protect, then the fine is significant.
Ordinances and Permits
In general all ordinances are available to the citizens online at the City website — www,archdale-nc.gov.
However, current printouts of the documentation are contained in a binder entitled "UNANNOUNCED
Compliance Audit Documentation 2019" maintained in the office of Stormwater Program Manager or
his designee. Additional copies are also prepared for presentation to Federal or State Audit Personnel.
There have been no changes to the program since inception on January 2, 2008 with the exception of
automatic implementation of guidance documents provided by the North Carolina Department of
Environmental Quality (DEQ), Division of Mineral & Land Resources Stormwater Manager (DEMLR).
Changes provided have not affected the program parameters, only the presentation of the information.
The latest document provided is a prescriptive Pre -Audit Template introduced by DEQ DEMLR in 2019,
which the City of Archdale has completed and believes is now something that can be used as standard
format for both its Annual Assessment Report Compliance document as well as documentation of the
Annual Stormwater Management Plan (SWMP-See TAB 1)
The City currently utilizes full time field personnel to fulfill an illicit discharge detection and elimination
(IDDE) program which includes: commercial property inspections, outreach and education, water quality
sampling (as needed) and stormwater system operation and maintenance. Personnel in the city respond
to public reports of water quality problems. Due to the size of the city and the minimum number of
personnel, response times are relatively quick.
City personnel respond to water quality problems associated with the road and stormwater system. City
personnel responds to water quality problems associated with construction and grading, to water

quality problems related to agriculture, to water quality problems related to municipal wastewater
collection and treatment systems, on -site septic systems, solid waste and hazardous waste.
Police Department
Public Works
Parks and Recreation
Facilities and Grounds
City Hall
26
6
11
6
20
5
5
12
91
Sworn Officers (1 vacant)
Dispatchers
Field Personnel
Field Personnel
Seasonal
Field Personnel
Field Personnel
Customer Care
IDDE Auxillary
No Field
IDDE Annual Refresher
IDDE-Education-Outrea
IDDE, By association
IDDE Annual Refresher
IDDE Education-Outrea
No Field
All personnel are exposed to the culture of Stormwater Management and the priority associated with
excellent stewardship.
Prioritization Procedures
In addition to maintaining a hotline for citizen complaints through Customer Service, the City proactively
conducts general field assessments to identify illicit discharges and illegal connections on all calls.
However, it is noted to date that only reports from citizens to date have resulted in IDDE
documentation. The first step of this proactive work is to prioritize those areas most likely to contain
illicit discharges. See assessment in 2nd paragraph above. Current exposure is less than 1 percent.
1. Locations where there have been repeated problems in the past. This could include areas with
water quality data or where repeated complaints have been filed.
2. Older areas of a community typically have a higher percentage of illegal connections. Also,
deteriorating sewer pipes can allow wastewater to exfiltrate out of the sanitary lines and into
the surrounding environment.
3. Commercial and industrial areas tend to have a higher percentage of illicit discharges.
4. Areas with large and/or many storage vessels of hazardous solids or liquids.
See TAB 9 Outfalls
The city chooses to conduct a visual assessment of impacts to surface waters by walking conveyances.
This activity can also be used to ground -truth the outfall map, determine the accessibility of the streams
for future monitoring (if required), and provide a photographic record of existing conditions. As of 2019,

the City of Archdale has 3580 outfalls classified as 12-15-inch and 43 outfalls greater than 15-inch (See
TAB 9 for > 15-inch)
Since inception the city continues to conduct field assessments of all outfalls discharging to water bodies
in the city under dry weather conditions consistent with integration of responsibilities. It will be
expected that field personnel will collect additional data on the physical conditions at the outfall as well
as water samples for lab analysis (when necessary). New information will be forwarded to the
Stormwater Manager or his designee.
Current contacts for water sampling:
Phillip Yates Public Works [phone]
Bryan Causey Guil-Rand Fire [phone]
A GIS-based layer can be developed of potential hot spots as related to WS-IV 17- 19 (1). It is expected
that due to internal training of staff and public outreach efforts required by the NPDES permit, the City
will develop a better understanding of the causes and locations of illicit discharges. The GIS map (or
other tracking tool) can be regularly updated to reflect reports from staff and the public as well as
information learned by the on -going field assessment work as the `; - IDDE program matures.
Physical Parameters
During dry weather field inspections, a variety of physical parameters +V e recorded at each site to
assess conditions. At flowing outfalls this includes flow, odor, color, turbidity, and presence or absence
of floatables. The information that is obtained from the physical characteristics observed are indicators
and cannot be fully relied upon by themselves.
A qualitative observation of flow (none, trickle, moderate, or substantial) should be made. Flow rates
can be estimated by one of the following simple methods:
a. Record the time required for the full flow to fill container of a known volume. b. Multiply cross -
sectional flow area by flow velocity. For most instances, flow area is based on an estimate of mean
depth and width. Flow velocity is based on the time of travel for an object floating near the surface over
a known length.
Odor is described by one of the following terms sewage, rancid/sour, petroleum/gas, sulfide, or other.
The severity of the odor should also be recorded in the field.
Color can be a description of color type and intensity. It is also a quantitative measurement expressed in
cobalt -platinum units (Table 1).
Turbidity can be a qualitative descriptor (clear, slight cloudiness, cloudy, or opaque) with a physical
reference to turbidity of Creekside Park at high bank condition. Alternatively, it can be measured in the
field or in the office with a hand held turbidimeter. When the conditions exist that equipment is
required, it is recommended that the City use a single make and model of meter to reduce the
differences in readings associated solely with equipment readings.

Floatables are the best physical indicator. The most common floatables are sewage, suds, and oil
sheens. Floatables do not include trash. The observation of sewage at an outfall location indicates that
there is a severe problem with that IViS4 and should be looked at as to where the source for the sewage
is emanating from. Suds can indicate a variety of things. Some suds are naturally formed by the
movement of the water. If the suds are located at a water drop off and break up quickly, this may only
be water turbulence related. If the suds have a fragrant odor, this can indicate the presence of laundry
water or wash water in the waterbody. Oil sheens need to be looked at to try and determine the source
of the oil sheen. Some oil sheens are common and occur naturally by instream processes. This occurs
when an iron bacteria forms a sheet -like film. This can be determined by looking at the sheen and seeing
if it cracks when disturbed. Synthetic oil sheens, on the other hand, will swirl when disturbed. If this
occurs, then the sheen is from an oil source.
The City may select a few water quality parameters that can be measured with inexpensive probes and
test kits/strips in the field. These include temperature, pH, ammonia, conductivity, chlorine, and
hardness. Other than conductivity, temperature and pH these same parameters can be assessed during
laboratory analyses so the field testing is usually unnecessary. It is generally recommended that the
majority of analyses be conducted in a more controlled —labll setting (Center for Watershed Protection
& Pitt, 2004).
There may be physical indicators of illicit discharges even if no flow is present. These include: outfall
damage, deposits/stains, abnormal vegetation, poor quality of pooled water, benthic growth in pipe.
During a dry weather inspection, observed flows are considered non-stormwater related. The flow may
or may not be the result of an illicit discharge. Also, the absence of a flow does not indicate the absence
of an illicit discharge since these discharges can be intermittent or transitory. It is important to observe
carefully during the dry weather inspection to determine if an intermittent or transitory pollution
problem has occurred.
Water Quality Sampling and Testing
Based on the initial assessment of the conveyances at inception, regular dry weather inspections for
physical clues will be done on an annual basis during regular stormwater inquiries and during
concentrated paving operations. This integrated approach allows for a minimum review of 5% of the
systems conveyances annually. In addition, water quality sampling and testing will be a supplemental
part of the City's IDDE program. Some parameters can be directly measured in the field using a portable
instrument or test kit whereas others require laboratory analysis. Refer to October 2004 reference
document the parameters that must be sampled as well as suggested/optional parameters to be
sampled to isolate an illicit discharge. The reference document contains tables related to sampling
parameters and possible analytical methods used when samples are sent to an accreditated laboratory.
When tests are necessary refer to benchmark concentrations based on samples collected from storm

drains nationally. Subsequently, benchmark concentrations would be lower for samples drawn from
watercourses since the natural base flows would likely dilute any pollutants in water discharged from a
contributing storm drainage system.
Water Quality Parameter
Water Quality as identified in the EPA Guidance Manual 2004, when assessment is required.
Immediate Response Procedures
The field personnel or citizens should be prepared to take immediate action in the event of
encountering one of the following situations:
Individuals actively in the process of introducing possible illegal substances or materials to the storm
drain system
Very strong chemical odor emanating from storm drain system
Presence of fumes or smoke emanating from storm drain system 0 Visible significant stream of a
controlled chemical or petroleum product flowing in storm system or downstream waters
Large chemical plume in stream or lake downstream of an outfall
Any condition that poses or could pose an immediate threat to property, human health or safety, or
aquatic life.
The crew should take the following steps if one of the above situations is encountered:
1. Ensure crew and public safety by instructing people to stay clear of the area
2. Call 911 to report active illegal dumping or potential fire or significant chemical incident
3. Call the customer service at [phone] to report a possible illegal discharge of Stormwater
Program Manager at [phone].
4. The following offices must all be called if an unauthorized discharge of oil or hazardous material
such as a spill has occurred:
a. Guil-Rand Fire Department - [phone]
5. If a spill is encountered the following information should be recorded if possible:
a. Where is the spill?
b. What spilled?

c. How much spilled?
d. How concentrated is the spilled material?
e. Who spilled the material?
T. Is anyone cleaning up the spill?
g. Are there resource damages (e.g. dead fish or oiled birds)?
h. Who is reporting the spill?
i. Your contact information?
5. If possible isolate or contain visible chemical pollution in the effected water body with any
materials that are accessible. For small discharges earth dams, absorbent pads, and containers
may be useful to contain part of the illicit discharge
6. Take detailed notes and photos/video for subsequent investigation by other agencies.
At a minimum, follow-up work includes contacting appropriate State agency if any additional reporting
or investigative actions are necessary.
CAS#
Analyte Name
PQL
Result
UOM
95-63-6
1,2,4-Trimet hylbenzene
1.0
8.0
µg/L
108-67-8
1,3,5-Trimethyl be nzene
1.0
1.6
µg/L
ALKEN ES
360 N 1
µg/L
108-38-3
m,p-Xylene
2.0
1.5 N3
µg/L
91-20-3
Naphthalene
2.0
10
µg/L
103-65-1
n-Propylbenzene
1.0
0.72 N3
µg/L
95-47-6
o-Xylene
1.0
1.1
µg/L
99-87-6
p-Isopropyltoluene
1.0
0.56 N3
µg/L
135-98-8
sec-Butylbenzene
1.0
0.69 N3
µg/L
This is a UTto Muddy Creek, Cape Fear river basin, WS-IV*
The above data is from an IDDE investigation which initially started on 1-12-2017 4:20 pm following the
weekend snow storm. This IDDE investigation was concluded satisfactorily on 2-2-2017 11:04 am follow
IDDE protocols in place since inception of the program. No changes to protocol are recommended. In
summary, this approximate 5 gallon release of heating oil due to faulty equipment resulted in cleaning
the reaches between the origin and 3 outfall locations downstream.
For incidents not determined to be emergencies, the city should investigate or refer to the appropriate
agency any complaints, reports, or monitoring information that indicates a potential illicit discharge,
spill, or illegal dumping.

Isolating Illicit Discharges (Source Tracing)
The City hotline is [phone] will continue to be an effective tool for locating illicit discharges.
However, in situations where outfall screening identifies an illicit discharge several methods can be used
to trace to the source of the illicit discharge techniques include visual inspections of drainage structures
and lines, dye testing, damming lines to isolate areas, video inspection, indicator monitoring, smoke
testing, and optical brightener monitoring traps. Other more elaborate approaches include using remote
sensing tools to identify soil moisture, water temperature, and vegetation anomalies associated with
failing septic systems and tracking illegal dumping activities. The most common approach for the
County will likely rely upon visual inspections of the catch basins in the storm line above the outfall in
which an illicit discharge is suspected.
Several resources exist to assist in evaluating the likely source of an illicit discharge. Generally, the
sources are washwater, sanitary sewer or septage, potable water leak, animal contamination, illegal
dumping, or industrial discharge.
Investigation and Response Procedures - Public Education and Information
As part of the City's public outreach program, outreach material will be made available to citizens form
State sources. The education campaign will rely upon the State's website, brochures, print ads, website
ads, drain markers and/or fact sheets to make citizens aware of stormwater, water pollution, and inform
them of the city's hotline for reporting on possible illegal dumping, connections, or discharges.
Additionally, target audiences with a high risk as a potential source, such as auto shops, mobile
businesses, and commercial property owners/mangers may receive specialized educational material
The City has established a customer phone number for reporting of spills or illicit discharges. The
hotline is the main customer service number [phone] It is operated during the work week at. An
after-hours message directs callers to report emergencies to 911 or leave a message for a
nonemergency situation.
Reporting and Recordkeeping
Record Keeping shall be accomplished by
1) Microsoft Outlook investigations to stormwater inquiries
2) Annual Resurfacing Contract as documented by City Council Minutes and list of streets
paved according to 5-year priority listing. Currently, Stormwater Program Manager is on
site during paving operations and adjacent stormwater swales are assessed under dry
weather conditions. This assessment produces a 5% annual IDDE assessment of the system

annually; Documentation provided by the contractor establishes the date and time of the
assessment on the streets being paved. — Upon retirement of current Stormwater Manager
at 30 years of service, this responsibility will be transferred to either the new Stormwater
Manager or a Public Works employee to meet the 5% annual assessment; Based on the first
15-years of the program, 95% of these conveyances are dry with the remaining 5% filtering
water through grass swales; Less than 5% of the city swale systems are exposed to erodible
conditions either due to Public Works Maintenance of the roadside ditch of difficult incised
roadside ditches.
Tracking (Spills, Inspections, and Public Comment/Feedback)
Tracking and documentation is a required part of the IDDE program Currently, all calls are maintained
using Microsoft Outlook in which all site visits have a component of IDDE dry weather investigation.
Queries in the program provide a general listing of sites visited for NPDES reporting purposes.
As a summary, all calls field by Stormwater Management subject to a site visit follow a general protocol.
1) Information concerning a stormwater concern is forwarded to the Stormwater Program
Manager or his designee
2) Stormwater Manager of his designee visits the site and assesses the situation for possible
maintenance repairs.
3) A Stormwater Work Order is submitted requesting camera work for the appropriate location if
piping is involved. This protocol of camera work allows for subservice investigation of the line.
a. The results of this camera work by Public Works personnel typical results in either joint
separation or root intrusion then requiring maintenance by the owner of the
encroachment in the right-of-way
b. In the event a connection is discovered not identified, IDDE is in effect.
4) In the event an IDDE is in effect, IDDE will be noted in the subject of the Microsoft Outlook.
All public comment/feedback will be conveyed to the Stormwater Program Manager or his designee to
ensure that the program is responsive to citizen complaints. The public will be directed to either the
program manager directly or the hotline if they have general comments they would like to make.
Staff Training
Staff Training will be conducted concurrently with the Annual Flagging Training Refresher Course as a
round table discussion and referring to current 2004 guidance. General training targets city staff who
may potentially see an illicit discharge including staff from the following departments: Public Works,
Planning & Zoning. Facilities and Grounds, and Parks and Recreation. Note that the current program
serves as an annual refresher due to 9.62 annual length of service retention statistic.
Detailed Training

Detailed training will be assigned to those individuals specifically involved in the immediate response
procedures i.e. Guil-Rand Fire Department personnel and Public Works personnel responsible for water
source tracking of potential illicit discharges and sampling. Note that the City may elect to retain
consultants for source tracking of potential illicit discharges and sampling outside of what has been
typically observed by the city personnel since inception of the program. In the years that consultants are
used, the training may be waived.
References
The following reference was used to prepare this plan and contain supplemental information that may
be helpful to City staff.
Center for Watershed Protection and Robert Pitt. Illicit Discharge Detection and Elimination: A Guidance
Manual for Program Development and Technical Assessments. October 2004. U.S Environmental
Protection Agency. Washington, D.C.