04_NCS000467_NS4 IDDe SOP_20211208

�,, TOWN of 301 S. Brooks Street
AM ,! Wake Forest, NC 27587
WAKE FOREST (919.435,9400
www_H akclorestnc.go%-
Stormwater MS4 - Illicit Discharge Detection and
Elimination IDDE)
Introduction
As specified in 40 CFR part 122.34, the regulated public entity must implement an Illicit Discharge
Detection and Elimination program. The program will focus on continuously updating the storm sewer
system map, implementing enforcement procedures through the Town Ordinances, utilizing a plan to
detect and eliminate non stormwater discharges, and maintaining a set of educational materials tailored
to illicit discharge detection and elimination.
A summary of the Town's strategy for Illicit Discharge Detection and Elimination can be found in the
Stormwater Management Plan (SWMP).
Regulatory Mechanisms and Enforcement of the IDDE Ordinance
The Town adopted the Illicit Stormwater Discharge Ordinance on November 18, 2003 in the Town Code
of Ordinances Chapter 32, Article VI to address illicit discharges to its stormwater system. The Town also
maintains IDDE regulatory mechanisms and enforcement in Section 12.5.8 of the Unified Development
Ordinance.
The Town continues to utilize and enforce the existing ordinances as part of the NPDES MS4 permit and
stormwater management plan. The SeeClickFix software is used to receive notices for illegal illicit
discharge reported both externally and internally by Town staff. The software will contain the date and
address of each report and will allow the Town to keep track of first-time violators or repeat offenders
and make sure the appropriate measures put in place. The Town has also developed a ESRI dashboard to
track open violations to ensure resolution of all stormwater violations, including illicit discharges.
Stormwater System Map of Major Outfalls
The Town maintains and updates the Stormwater System Map using GIS. When new development
occurs field inspectors will collect stormwater infrastructure data and then enter it into the GIS
database. Using the GIS database, the number of major outfalls can be provided as well as their
characteristics, such as the outfall structure type, receiving streams, and drainage areas. Currently 95%
of the outfall mapping has been completed with help from WK Dickson, Brown and Caldwell, and
internal Town staff. As of 2006, the City of Raleigh owns and maintains the sanitary sewer system for the
Town. Sanitary sewer infrastructure mapping is handled by the City of Raleigh. Information on sewer
agreements with the City of Raleigh can be found in General Program Documentation.
11

TOWN of
WAKE FOREST
utfall Inspections and Inventory
Dry Weather Flow Detection Program
301 S. Brooks Street
Wake Forest, NC 27587 O
1919.435.9400
W ILV W.Wakeforestttc-go v
Dry weather inspections are made at points along major and minor outfalls at hotspots. When it comes
to the frequency that dry weather inspections occur there are few sources that are used to determine
which outfalls to inspect including field data collection, public reporting, and priority areas. Generally
major outfalls will be inspected once per permit cycle, however, if the Town is contacted regarding an
observed illicit discharge then the system will be inspected as needed until the illicit discharge is
eliminated.
While collecting data for the stormwater system inventory, structures are inspected for dry weather
flows. IF dry weather flows are observed, samples may be collected to help determine the characteristics
of the flow. The sample will help identify the source and if it is a pollutant. Further explanation of the
inspection process is included in the IDDE Monitoring Plan.
Citizens are encouraged to report illicit discharges through SeeClickFix. Illicit discharges reported
through SeeClickFix will be responded to by a member of the Town's staff as soon as they have been
notified of the incident report. In addition to citizen reports, priority areas will also be inspected more
frequently for first time or repeat illicit discharges. Priority areas are areas that present higher potential
for spills, leaks, or illicit discharges. Priority areas that fit that description, and are currently monitored,
include but are not limited to: Transportation facilities, Commercial facilities, Industrial facilities,
Institutional facilities, Municipal operations, areas with older sewer infrastructure, and areas previously
identified with illicit discharges.
All inspection reports are completed using our NewWorld inspection process. Inspections will note the
condition and observations of the outfall. A ranking system can be used to help prioritize maintenance
for the Public Works staff. A ranking of 1 is the highest priority, while a ranking of 4 reflects an outfall in
good condition.
Investigate sources of identified illicit discharges
When an illicit discharge is identified at an outfall it will be followed upstream through the stormwater
system to track down the source or the general origin area. After a dry weather flow has been observed
a follow up inspection is scheduled to verify the issue has been resolved.
Track and document investigations of illicit discharges
X

TOWN of 301 S. Brooks Street
(7 Wake Forest, NC 27587
WAKE FOREST 1919.435 9400
w►► v.-.wakelorestu�c,gov
The Town utilizes SeeClickFix in order to track external and internal reports of non-stormwater
discharges. The Town has also developed a ESRI dashboard to track open violations to ensure resolution
of all stormwater violations, including illicit discharges.
Employee Training
A Spill Response Plan have been developed to be utilized by Town staff. The spill response plan
assembled for municipal facilities serves as a template that each facility fills out to best fit the
characteristics of the site. This plan also references the Town's list of safety data sheets and will be
included with each facility's Operation and Maintenance plan.
Employees will be trained to handle spill response and clean up for municipal facilities and spill response
for external spills. The Spill Response Plan will be referenced during training so that staff will become
familiar with its procedures prior to utilizing the plan in a real scenario. It is also include in Appendix B
of high risk facility Stormwater Pollution Prevention Plans.
Training is available to all employees on how to utilize the spill kits available at Town facilities. The
Stormwater engineer, or other appropriate Town staff will conduct training sessions as needed to
demonstrate how to use materials in the spill kit, as well as proper response procedures. This training
also includes stormwater awareness which teach staff how to detect an illicit discharge and encourages
staff member to report them to the Engineering Department,
Public Education and Outreach
The Town maintains a public and employee education and outreach program to inform these groups on
what to look for and who to contact if they do observe illicit discharge. An Illicit discharge detection and
spill response handout has been created to inform citizens and employees on the differences between
illicit discharges, illicit connections, and spills. Materials including handouts and the website are utilized
for education and outreach. IDDE is incorporated into all the general clean water materials to show how
non-stormwater discharge can impact the Town's waterways.
Public Reporting Mechanism
The Town utilizes SeeClickFix on their website and mobile app to receive information from the public
about a variety of concerns, including illicit discharge and spills. As a secondary option, citizens can
contact the Town's Stormwater staff directly. Social media is also be used to promote SeeClickFix and
teach citizens how to report non-stormwater discharges. More information on social media posts can be
found in the Stormwater Social Media SOP.

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