23_IDDE Staff Training Presentation

Detectingand El
• • •
Illegal and Ill
Connections
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William T. Sabata, PE
.' ES&GS Services PLLC
Fuquay-Varina, NC
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Y 23 June 2021

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Quick Summary
o Review existing Stormwater Management Program
o Review Illicit Discharge Detection and Elimination
(IDDE) Program
o Discuss role of Police/Fire/Inspectors and other City
Staff in IDDE
o Provide information for implementation of IDDE
o Provide cautions

Neuse River Rules, Phase II , and the
Stormwater Management Program
o Neuse River Rules 2001 (State)
o Phase II Permit July 2005 (Federal)
o Renewal permit effective 15 January 2012
o New Renewal permit in January 2017
o The Stormwater Management Program
o Six Minimum Control Measures
o Illegal Discharge Detection and Elimination Program
(IDDE Program)

IDDE Program
*Part of the Neuse River Rules and Phase II
*In the City's Phase II Permit
o Section D, Part II, Page 5-6 of 15
o Para 2.(0 The permittee shall implement and document a training
program for appropriate municipal staff who as part of their
normal job responsibilities, may come into contact with or
otherwise observe an illicit discharge or illicit connection to
the storm sewer system.
*Part of an overall program that includes
O Inspection/Screening program to detect dry weather flows
in the storm sewer system
o Public education
o Public reporting mechanism

Permit Language
1. Objectives for Illicit Discharge Detection and Elimination
a. Implement and enforce a program to detect and eliminate illicit discharges into the MS4.
b. Maintain a storm sewer system map, showing the location of all major out-falls and the
names and location of all waters of the United States that receive discharges from those
outfalls;
C. Prohibit, through ordinance, or other regulatory mechanism, non-storm water discharges
except as allowed in this permit and implement appropriate enforcement procedures and
actions;
d, Implement a plan to detect and address non-storm water discharges, including illegal
dumping, to the MS4;
e. Inform public employees, businesses, and the general public of hazards associated with
illegal discharges and improper disposal of waste, and
f. Address the following categories of non-storm water discharges or flows(i.e., illicit
discharges)only if you identify them as significant contributors of pollutants to the MS4:
water line flushing, landscape irrigation, diverted stream flows, rising ground waters,
uncontaminated ground water infiltration, uncontaminated pumped ground water,
discharges from potable water sources, foundation drains, air conditioning condensation,
irrigation water, springs,water from crawl space pumps, footing drains, lawn watering,
individual residential car washing, !lows from riparian habitats and wetlands,
dechlorinated swimming pool discharges, and street wash water(discharges or flows
from fire fighting activities are excluded from the effective prohibition against non-storm
water and need only be addressed where they are identified as significant sources of
pollutants to waters of the United States).

o Uniform Development Ordnance, Section 6.6
Illegal Discharge Control
o Provides for legal means to enter and inspect
property for illegal discharge
• The Building Inspector (or other authorized agent of the City) has
full power and authority to enter upon a premise for the purpose of
investigating an illegal discharge. (Paragraph 1 , 6.6. 12
INSPECTIONS)
o Provides for responsible party liability for cost of
clean-up and correction of violation
o Provides for both civil and criminal penalties
IDDE Enforceable by Ordinance

What's an ID / IC?
o What's an illegal (illicit) discharge?
o Any non-stormwater discharge to the MS4 that is not
expressly allowed in the permit
o What's an illicit (illegal) connection?
O Any discharge point that would allow an illegal discharge
to enter the stormwater sewer system
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Non - Stormwater
Flows

Non-stormwater Flows
*Typically observed during dry weather
*Allowed (See Section 6.6.9 UDO)
o Uncontaminated groundwater discharge
o Residential car wash, a/c condensate, wash water without
detergent, swimming pool discharge
o Fire fighting, irrigation, foundation drains
oNot Allowed
o Commercial car washing
o Cooling tower blowdown
o Industrial/commercial activities, process water

Four Components of the
IDDE Program
o Mapping -_
o Tracking
t O Documenting
o Enforcing
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Mapping
o Locate all outfalls
o Map stormwater sewers ' i
o Map sanitary sewers
o Locate all critical elements = + `
o Industrial Activity s
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o Activities w/discharge permits
o Government facilities
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0 on-going process/GIS

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Tracking
o General Public
o Illicit Discharge Hotline
o Engineer Department
o Screening of Priority Areas
o Dry Weather Screening (Public Works)
o Notifications
o Police/Fire/Inspections
o Observing and Reporting

Priority Areas
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DryWeather Screening
o Conducted by the Public Works Department
o Starts at known discharge points
o If a discharge is suspected, uses known stormwater system to
track to source
o May require multiple visits to confirm discharge and source
o Spot checking; does not -7�7
provide continuous
monitoring
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O Service Bays
o Food Service Wash
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O Sanitary Sewer _
o Food Preparation Areas ' , s
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* Industrial processes
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Cooling
Tower ji
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Blowdown
Observing
(Illicit Connections) Open Pipe

Observing
(Illegal Discharge)
* Sight (dry weather discharge, sheen)
O No rain and a drainage ditch with water
o PVC Pipe from gas station opening on ditch
* Smell (odor)
o Fuel oil smell from street inlet
*Feel (step on) � � �►
o Spongy feel on grass beside ditch
*Hear (dripping/trickling)

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Sheen , Color, Turbidity
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0 oily sheen on discharge water
o Color �'� '
o Foam, suds '=
o Cloudiness and turbidity ,
o Floaters
o Sediment Construction Site?
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Documenting
o Date/Time
o Location , -�`j
o Description V *0
o Source (if possible) v �
* Point of Contact v
o Turn in Information

Reporting
TO BE USED TO REPORT THE IDENTIFICATION
OF AN ILLEGAL DISCHARGE OR ILLICIT CONNECTION
DATE/TIME:
LOCATION:
DESCRIPTION:
SOURCE:
CONTACT:
REPORT INFO TO: OTHER PHONE NOS
CITY ENGINEER PUBLIC WORKS: 734-8674
PHONE (P): 580-4367 CODE ENF: 580-4312/3
PHONE (A): 580-4328 INSPECTIONS: 580-4385

Exercise
o The street name is Douglas Road, the cross-street to the west is
Aspen Drive.
o Sanitary sewer is buried 6 feet under centerline of road, stormwater
sewer runs along north side of street.
o Service station is relatively new, built in last 10 years.
o Four stores in strip mall are UPS store, Nail Care store, Donut
Store, and Dry Cleaners who send items out to another location for
treatment.
O Two retail/commercial stores are Custom Countertops store and
Auto-Zone.

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Exercise
o It's 3 pm and you are just returning to your car parked along the
street. On the north side of the street there's a service station, a
strip mall with four stores, and two retail buildings. On the south
side there is a forested and grassy area, with a grassed ditch along
the roadway. You look over at the ditch and see a small PVC pipe
sticking out with a grey-brown discharge and you notice an earthy
smell emanating from the ditch. The street name is Douglas Road,
the cross-street to the west is Aspen Drive, and the pipe is about
100 yards east of Aspen.

Exercise
o Fill in your reporting card with the appropriate information using
today's date.
o Add any additional information that may be useful.
o What actions will follow the report?
o Report is logged in
o Inspector will go out
o Sewer maps will be consulted (stormwater/sanitary)
o Industrial Stormwater Discharge Permits reviewed
o Sample may be taken
o Type of retail/commercial establishments checked

Exercise
o Inspector takes a sample for visual inspection, allows sample to
settle and sees a fine clay like sediment.
o Service station and three strip mall stores are not a factor; Dry
Cleaner does no treatment on site. Auto-Zone only sells
merchandise.
o Custom Countertops cuts stone slabs for installation in homes
behind the store. This previously was a garden store that sold
shrubs and small trees that were watered in the back.

Custom Countertops
o Uses a machine to cut stone countertops
o In the work area, there is a stormwater inlet
o Previous owner watered bushes in this area
o Wire used in cutting the stone has to be lubricated
with a water and chemical mix to keep it cool and
avoid breaking
o Discharge is considered an illegal discharge as the
store does not have a permit to discharge non-
stormwater.

Enforcing
6.6.13 CIVIL PENALTIES
1. Illicit discharges Any person who allov s or assists in a violation of this Chapter shall be
subject to civil penalties as follows:
For first time offenders. if the discharge consists of domestic or household products in
quantities considered ordinary for household purposes. the person shall be assessed a
civil penalty not to exceed $100 per violation or per day for any continuing violation. If
the discharge contains non-domestic substances. including but not limited to process
waste water. or if the person cannot provide clear and convincing evidence of the volume
and nature of the substance discharged. the person shall be assessed a civil penalty not to
exceed $1.000 per violation or per day for any continuing violation.
For repeat offenders. the amount of the penalty shall be double the amount assessed for
the previous penalty. not to exceed $10.000 per violation or per day for any continuing
violation.
6.6.15 CRIMINAL PENALTIES
,-kiiy person who kiioR ingly or «illfiillv Violates any prop ision of this Chapter, rz-le, reg elation, order
duly adopted or issued piusnant to this Chapter shall be Vulty of a nusdeineanor, pmushable by a
fuse not to exceed S500. Each violation shall be a separate offense.

Cautions
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Oil Spills and = -
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Hazardous -
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Oil Spills and Hazardous Materials
*Report Oil Spills to Inspections Department
*Report any suspected Hazardous Materials to Fire
Department—if an emergency, call 911
* Only an illegal discharge if it gets into the storm sewer
system
* Other regulations may
apply
*Do not put yourself at
risk!
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Warning!
*Do not gather evidence just report sighting
*Do not breath in vapors
*Do not enter, even with just your head, a
confined space
*Do not attempt to take a sample
*Do not touch
*Let the experts investigate

Conclusion
*Role is to record and report any observation of
illegal or illicit discharge or connection
* Goal is to eliminate illegal discharges to surface
waters

Any Questions?
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