NCS000446_Illicit Discharge and Elimination SOP_20201218

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Illicit Discharge Detection & Elimination
Standard Operating Procedures
May 2013
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TABLE OF CONTENTS
1.0 Purpose 2
2.0 Program Administration 2
3.0 Policy 2
4.0 Legal Authority 2
5.0 Definitions 2
6.0 Reporting and Response 2
7.0 Identification of Priority Areas 3
8.0 Procedure for Dry Weather Flow Inspections 5
9.0 Procedure for Illicit Discharge Detection 5
10.0 Procedure for Illicit Discharge Elimination 7
11.0 Issuance of Notices of Violation & Civil Penalties 7
LIST OF TABLES
Table 1. Assessment of Illicit Discharge Potential
LIST OF MAPS
Figure 1.
Middle Creek Basin MS4 Map
Figure 2.
Williams & Swift Creek Basin MS4 Map
Figure 3.
Beaver Creek Basin MS4 Map
Figure 4.
Big Branch Basin MS4 Map
Figure 5.
Crabtree Creek Basin M54 Map
Figure 6.
White Oak Creek Basin MS4 Map
ATTACHMENTS
1. Town of Apex IDDE Ordinance
2. Town of Apex Illicit Discharge Incident Tracking Form
3. Town of Apex IDDE Dry Weather Flow Inspection Form

ACRONYM LIST
DENR
Department of Environment and Natural Resources
DWQ
Division of Water Quality
EP
Environmental Programs
EPA
Environmental Protection Agency
IDDE
Illicit Discharge Detection & Elimination
IDP
Illicit Discharge Potential
MS4
Municipal Separate Storm Sewer System
NC
North Carolina
NOV
Notice of Violation
NPDES
National Pollutant Discharge Elimination System
SOP
Standard Operating Procedure

1.0 Purpose
The purpose of this document is to establish standard operating procedures (SOP5) for addressing
illicit discharges and connections into the Town of Apex (Town) Municipal Separate Storm Sewer
System (MS4) and Waters of the State.
2.0 Program Administration
The Town Public Works & Utilities Department - Environmental Programs (EP) Division shall
administer, implement, and enforce the provisions of the Illicit Discharge Detection and
Elimination (IDDE) Program.
3.0 Policy
All users are responsible for ensuring that pollutants do not enter the Town MS4 or Waters of
the State so as to protect public health, safety, and welfare. The Town shall take the actions
identified in this SOP when users fail to meet their responsibility to protect public safety and the
water quality within Town corporate limits.
4.0 Legal Authority
The IDDE Program Ordinance (Municipal Code, Ordinance No. 08-0617-09) adopted by the Apex
Town Council on July 15, 2008 gives the Town proper legal authority to provide for the health,
safety, and general welfare of the citizens of the Town by controlling the introduction of
pollutants into the MS4 in order to comply with the requirements set forth in the National
Pollutant Discharge Elimination System (NPDES) Phase II permit effective July 1, 2005
(Attachment 1).
5.0 Definitions
Please refer to the Town IDDE Program Ordinance (Section 12-198 Definitions) for a complete
listing of relevant definitions.
6.0 Reporting and Response
Illicit discharge reports may originate from a variety of sources including cross -trained Town staff,
residents, and other individuals who witness these potentially illegal acts. To respond to reports
accurately and efficiently, EP administrative staff is trained to complete the Town Illicit Discharge
Incident Tracking Form (Attachment 2) and submit it to the Public Works Engineering Projects
Coordinator or his/her designee.
Field verification by EP staff will occur within the first 24 hours of the reported illicit discharge
incident and shall follow the SOPs outlined in Section 9.0 of this document
F,

7.0 Identification of Priority Areas
The Town's NPDES Phase II permit requires the development of procedures for identifying areas
that present the greatest risk for illicit discharges. Therefore, the following methodology for
identifying priority areas within the Town corporate limits has been created.
The Town's MS4 drains to two (2) major river basins (Neuse and Cape Fear River Basins). Within
these major river basins are seven (7) sub -basins:
• Swift Creek basin (Neuse)
• Williams Creek basin (Neuse)
• Middle Creek basin (Neuse)
• Crabtree Creek basin (Neuse)
• Beaver Creek basin (Cape Fear)
• Big Branch basin (Cape Fear)
• White Oak Creek basin (Cape Fear)
These smaller sub -basins provide Town staff with a feasible approach to conducting dry weather
flow inspections. It is the goal of the EP Division to conduct dry weather flow inspections within
every sub -basin; however, available staffing resources do not allow this to occur on an annual
basis. Therefore, EP staff shall conduct dry weather flow inspections on a priority based
approach.
Each smaller basin identified in the bulleted list above has been evaluated using Illicit Discharge
Potential (IDP) screening factors. The Environmental Protection Agency (EPA) has developed a
standard list of ten (10) IDP screening factors for identifying priority areas; however, since each
municipality is different, screening factors that are unique to the community must be developed.
Through discussions with various Town departments, review of available mapping resources, and
general common knowledge of the Town, the following IDP screening factors have been
developed for the Town of Apex:
• Past Discharge Complaints and Reports
• Stormwater Outfall Density
• Age of Development
• Presence of Older Industrial Operations
• Aging or Failing Sewer Infrastructure
• Aging Septic Systems
Table 1 shows an assessment of each Town sub -basin once screened with the six (6) IDP factors
listed above. The normalized IDP score indicates that the Middle Creek basin has the highest risk
for an illicit discharge followed by the Swift Creek and Williams Creek basins. Based on this
information, EP staff will focus their initial illicit discharge program efforts on the Middle Creek,
Swift Creek, and Williams Creek basins.

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8.0 Procedure for Dry Weather Flow Inspections
8.1 Site Investigation
A program for field screening of dry weather flows at stormwater outfalls can aid in identifying
possible locations of illicit discharges or connections. Dry weather flow inspections are to be
conducted only after a period of 48 hours with no runoff -producing rainfall.
An accurate map of the sub -basin to be inspected is an essential component of a dry weather
flow field screening. The map can help determine the extent of discharged dry weather flows,
the possible sources of these flows, and the particular water bodies that flows may be affecting.
The sub -basin to be inspected should be based on priority as determined in Section 7.0.
In addition to accurate sub -basin maps showing all major stormwater outfalls, other field
equipment necessary for proper dry weather flow inspections include, but is not limited to:
• GPS unit
• Cell phone
• First aid kit
• Dry Weather Flow Inspection reporting form (Attachment 3)
o To be completed and filed even if no evidence of an illicit discharge is found
It is important to document each dry weather flow inspection even if no flow is discovered. The
documentation creates a baseline record of when and where dry weather flow inspections
occurred and what the conditions were like at that time.
8.2 Tracing the Dry Weather Flow
If a flow is encountered during a dry weather flow inspection event, the inspector should note
and document the following on the Dry Weather Flow Inspection Form where indicated:
• Type of pipe
• Estimated flow rate
• Color
• Turbidity
• Odor
o E.g. a chlorine odor may indicate the flow is potable water
• Origin (if possible)
If a dry weather flow appears to be an illicit discharge, the incident should be further documented
following the procedures outlined in Section 9.0.
9.0 Procedure for Illicit Discharge Detection
9.1 Site Investigation
The following initial steps shall be followed by EP staff while investigating the source of an illicit
discharge:
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1) Check the scene for obvious signs of danger. In the event of a hazardous material
discharge which poses an immediate threat to health and safety, or is likely to result in
immediate injury and harm to real or personal property, natural resources, wildlife, or
habitat, report the illicit discharge immediately to the Town Fire Department at (919) 362-
4001.
2) Identify and evaluate all stormwater infrastructure in the area and confirm the general
flow direction.
3) Identify where the illicit discharge may have occurred. Indications of an illicit discharge
or connection may be puddles, stains, or a flowing discharge. If visual observations do
not confirm the origin of the illicit discharge, listen for running water or smell for obvious
odors such as gasoline. If visual observations do not confirm an illicit discharge, proceed
to the use of field instruments to check pH, fluoride, temperature, dissolved oxygen,
turbidity, etc. If field instruments are not available, collect a sample in a sterile sample
bottle and take to the Middle Creek Water Reclamation Facility (WRF) at 300 Pristine
Water Drive for proper analysis.
4) After the location of the illicit discharge is confirmed, follow the illicit discharge
downstream to determine if the illicit discharge has entered the MS4.
a. If the illicit discharge has entered the M54, continue to inspect catch
basins or other stormwater structures to determine if the illicit
discharge has entered Waters of the State.
5) Proceed by following the illicit discharge upstream to confirm the source of the illicit
discharge. If the illicit discharge is flowing inside catch basins and other stormwater
structures then they all must be inspected for the discharge. Evaluate these structures
for similar color flows, stains, or puddles. Continue to listen for running water if the illicit
discharge is flowing and smell for obvious odors.
6) In some situations, the use of dye testing and collecting grab samples for lab analysis will
be an appropriate method for documenting an illicit discharge.
7) Fill out appropriate documentation (see Attachment 2).
9.2 Notification of Proper Authorities
9.2.1 Depending on the type and severity of the Illicit Discharge, EP staff will notify the Fire
Department and other relevant Town departments. Examples of when the Town Fire
Department should be notified include, but are not limited to, the following:
a. Hazardous materials;
b. Gasoline spills; and
c. Spills which are too large for the responsible party/user or EP staff to contain.
9.2.2 The North Carolina Department of Environment and Natural Resources (DENR), Division
of Water Quality (DWQ) shall be notified of illicit discharges which significantly impact
water quality. Examples would include, but are not limited to, the following:

a. Discharges which enter Waters of the State;
b. Discharges which result in a fish kill;
c. Private property owners who own and operate a sanitary sewer system must
notify DWQ in the event of an illicit discharge (if illicit discharge comes from the
Town sanitary sewer system, Public Works & Utilities will inform DWQ).
9.2.3 After the source of the illicit discharge is confirmed, determine who is responsible. In
some cases, witnesses may need to be interviewed to fully determine the responsible
party or user.
a. If a responsible party or user is confirmed, EP staff will ensure that the
responsible party or user eliminates the illicit discharge per the requirements set
forth in Town IDDE Program Ordinance.
b. If a responsible party or user cannot be confirmed, EP staff will work with the
Public Works & Utilities Director to determine the next course of action.
10.0 Procedure for Illicit Discharge Elimination
Once an illicit discharge has been detected and the source or origin of the illicit discharge has
been confirmed and well documented, EP staff shall follow all applicable procedures for
eliminating the illicit discharge as outlined in the Town IDDE Program Ordinance.
11.0 Issuance of Notices of Violation & Civil Penalties
EP staff is responsible for any enforcement actions required to eliminate Illicit Discharges and
Illicit Connections. EP staff shall follow all applicable requirements set forth in Town IDDE
Program Ordinance Section 12-207 when issuing a Notice of Violation (NOV). Any civil penalties
resulting from NOVs will be assessed by the Town Public Works Director or his/her designee.
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