HomeMy WebLinkAboutNCS000482_ENG 3366 Illicit Discharges and Spills_20220526City
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ILLICIT DISCHARGES AND SPILLS REPORTING
SOP No. ENG-3366
Origination Date:
Revision Date:
Approved:
PURPOSE
Provide general oversight and procedures for Investigating, responding, documentation, and
eliminating illicit discharges and spills from entering into the City's drainage system or to surface
waters. This procedure addresses the steps to follow from the time the report is made to the
Engineering Department, through the final clean-up is complete or the illicit connection is
disconnected from the drainage system. Spills or leaks of polluting substances released,
discharged to, or having the potential to be released or discharged to the stormwater
conveyance system, should be contained, controlled, collected, and properly disposed. All
affected areas should be restored to their pre-existing condition.
PROCEDURE
The following procedures will be followed when a call, email, or verbal notification is received by
Engineering Department staff regarding a possible illicit discharge or spill:
1. Illicit discharge can be received from customers from either the Stormwater hotline at 704-
282-4515 or reported on the City Webpage.
2. All spills and/or illicit discharges should be forward to the Stormwater Compliance
Coordinator. If the Stormwater Compliance Coordinator is not available, the Stormwater
Engineer will be notified.
3. The Stormwater Compliance Coordinatorwill determine if the discharge is within the corporate
limits of the city. The City's GIS system should be used to locate the address, if needed. As a
courtesy, if the discharge is not within the City Limits, the Stormwater Compliance Coordinator
should attempt to give the caller a phone number or other contact information to the
community, county, or other agency, in which the discharge pertains to.
4. The Stormwater Compliance Coordinator will assess the spill or illicit discharge to determine if
the situation is an emergency or the priority. In addition, the Stormwater Compliance
Coordinator will check to see if the incident or property owner is a repeat offender.
Depending on the type of spill or illicit discharge, the Stormwater Compliance Coordinator
may contact the Monroe Fire Department immediately. The Monroe Fire Department will
conduct the cleanup and documentation. Copies of all spill information and cleanup will be
given to the Stormwater Compliance Coordinator to record in the file located
I:\Stormwater\Stormwater Management Program\NPDES Phase ll\Six Measures\Illicit
Discharge\Tracking, per the City's NPDES stormwater requirements.
5. Depending on the priority of the reported illicit discharge, the Stormwater Compliance
Coordinator, or his/her designee, will investigate the report using the following criteria:
a. High Priority
Immediate attention is required to address an active discharge situation.
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SOP No. ENG-3366
Origination Date:
Revision Date:
Approved:
• Discharge has or may enter a surface water or the drainage system.
➢ Respond as soon as possible, but within 24 hours.
b. Medium Priority
• Requires attention, but problem is not actively occurring and rain is not forecasted.
➢ Respond same day (if not an ongoing discharge)
c. Low Priority
• The situation requires stormwater / illicit discharge education and awareness to allow
for the cleanup of the material and to prevent future occurrence.
➢ Respond within 2 to 3 days
6. The Stormwater Compliance Coordinator will coordinate with the Stormwater Engineering
Technician, the information of the incident. The Stormwater Engineering Technician shall visit
the site (based on the priority) and shall complete the Incident form, located in the
I:\Stormwater\Stormwater Management Program\NPDES Phase II\Six Measures\Illicit
Discharge\Tracking to record initial information including:
a. Time and date of discharge / Inspected By
b. Location (address) of reported discharge or spill
c. Narrative description of Problem findings
d. Descriptive Field Notes
e. Sit Investigation Details
f. Pollution Information
g. Reporting Party's name
h. Owner Information
Watershed
j. How was Report Received
k. Priority Rank
I. LID / Parcel
Once the information is entered and a site visit with photos have taken place, the information
is given to Stormwater Compliance Coordinator. Any further information to be updated by
Stormwater Compliance Coordinator and is inputted on the Access program, located in the
G:\City\StormWater to record in GIS.
Note: The incidents are numbered consecutively, using a 5-digit code. The first two numbers
correspond to the year, and the ►ast three digits correspond to the consecutive incident in that
year. For example, the third incident in the year 2021 is coded Incident ID 21003.
Note: When incidents are called in, the Stormwater Compliance Coordinator will research the
Tracking Spreadsheet to check for repeat offenders.
7. Contacts
The Stormwater Compliance Coordinator should contact the following agencies depending
on the type of spill or illicit discharge:
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SOP No. ENG-3366
Origination Date:
Revision Date:
Approved:
Table 1 - Contact Information
Material Discharged
Contact
Oil, Chemicals and other Hazardous
911
Materials
Hazardous Materials Team
Monroe Fire Department
704-282-4739 Office (8 AM - 5 PM, M-F)
911 (24 hour)
Wastewater
Water Resources Department
704-282-4601 (This number rolls over to
the Police Department during non -
business hours)
Trash on private property and outside
City of Monroe Building Code
of Right -of -Ways within the City limits
Enforcement
704-282-5770
Yard waste that is left in front of
City of Monroe Building Code
property that is in violation of City
Enforcement
Code.
704-282-5770
Trash in drainage system and for large
Streets Superintendent
quantities in City of Monroe Road
704-282-4553
Right -of -Way
All discharges / spills caused by city
City of Monroe Safety and Risk
employees and/or on City Property
Coordinator
704-282-459 7
Trash and Releases on DOT Right -of-
NC Department of Transportation
way
704-218-5140
Spills or releases that are the
Emergency Response Contractor
responsibility of the City, but cannot
(refer to ENG - 3364 - Environmental
be handled internally by City Staff
Contractor Resource List
For discharges outside The City of
Union County Emergency
Monroe, within Union County
Management Coordinator
500 N Main Street
Monroe, NC 28112
704-283-3575 phone (8 AM - 5 PM, M-F)
704-283-3716 fax
For Illicit Discharges in Indian Trail
Town of Indian Trail
704-821-1314
Illicit Discharges
Illicit discharges may include the discharge, emission, disposal, pouring, or pumping directly or
indirectly of any liquid, solid, gas, or other substance, other than stormwater to any stormwater
conveyance, the waters of the State, or upon the land in manner and amount that the substance
is likely to reach a stormwater conveyance or the waters of the state. Prohibited substances
include but are not limited to: oil, anti -freeze, chemicals, animal waste, paints, garbage, and litter.
Additional illicit discharges may include grass clippings, leaves, wash water, and sewage.
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SOP No. ENG-3366
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Revision Date:
Approved:
Examples of Illicit Discharges Investigation:
Illicit discharges investigated may include leaks, accidental sills, as well as deliberate or
inadvertent connections or discharges to the storm drain system or to the ground.
Examples may include: wash water, motor oil, cooling oil, grease, paint, plaster, grout, cleaners,
chemicals, grass clippings, leaves, mop water, dumpster leakage, chlorinated pool water,
pesticides, soil/sand, erosion, animal/pet waste, filter backwash, salt/brine, soap, sewage, and
concrete wash water. Spills, assumed accidental, may include automobile fluids from vehicles,
dumping of materials into the storm drain, tank overflows, sewage cleanout overflows, chemicals,
dumpster leakage, etc.
Except for sewage from overflowing, cleanouts on private property are to be address by the
Stormwater Compliance Coordinator. All sanitary sewer and Wastewater Treatment Plant
overflows are addressed by the Water Resourced Department and the Stormwater Compliance
Coordinator shall document these sewer spills.
Examples of Reportable Spills
Spills or releases of hazardous substances or oil are subject to reporting requirements under state
and federal regulations. Reporting requirements depend on the amount spilled and the location
of the spill.
Link to NC DEQ Emergency Response:
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1. Oils - includes Hydrocarbons, motor oil, gasoline, various fuel oil, lubricating oil, hydraulic
oil, asphaltic residuals. Harmful quantities are described as: (1) violates water quality standards,
or (2) cause a film or sheen upon or discoloration of the surface of the water or adjoining shorelines
or cause a sludge emulsion to be deposited beneath the water surface or upon adjoining
shorelines.
Federal Oil Spill Reporting Requirement: Visible sheen on surface water of violates a water quality
standard
State Oil Spill Reporting Requirement: petroleum products requirements found in North Carolina's
Oil Pollution Act § 143-215.85 (a and b) are as follows:
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If the petroleum discharged, released or spilled:
• Is 25 gallons or more,
Or
• Causes a sheen on nearby surface water,
Or
• Is 100 feet or less from surface water body,
Or
• Is less than 25 gallons, and is not cleaned up with 24 hours
2. Hazardous - Federal government has established Superfund Reportable Quantities (RQs).
�.ulp. rfuir d........._ ..poriable Quanfiifiies (. _Q.s.1. If a hazardous substance is released to the
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SOP No. ENG-3366
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Revision Date:
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environment in an amount that equals or exceeds its RQ, the release must be reported to
federal authorities, unless certain reporting exemptions for hazardous substance releases also
apply. Reportable spills includes all releases during a 24-hour period of oil or hazardous
substance in an amount equal to or in excess of reportable quantities under Section 311 of the
Clean Water Act, Section 102 of the Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA) and extremely hazardous substance under Section 304 of the
Superfund Amendments and Reauthorization Act, Title III (SARA Title III). These regulations are
listed in Title 40 of the Code of Federal Regulations, Parts 1 10, 117, 302, and 255 respectively. To
determine whether a spill or discharge requires reporting:
1. Check the Material Safety Data Sheet (MSDS) of the released material for any
hazardous constituents;
2. Look for the hazardous constituents in the most recent versions of 40 CFR 1 10, 117, 302,
and 355 to see if an RQ is listed; and If the hazardous constituent has an RQ, calculate
the amount spilled (in lbs.) based on the % composition and specific gravity values
found on the MSDS.
This link to Lists of RQs may be helpful: h..l.t�s,//www,epa.g.o l .pc ra/consolidated list�-lists
3. Wastewater Spills - Sanitary wastewater spills and overflows form the City's wastewater
system are the responsibility of the City of Monroe Water Resource Department. Their
spill report is emailed to the Stormwater Compliance Coordinator.
The table below lists the contact information to report spills of oil and hazardous substances.
Agency to Notify
Contact Information
Union Co. Emergency Management
704-289-1591
Union County Emergency Management
704-283-3575
Coordinator
Union Co. Environmental Health
704-283-3553
NC Department of Environmental Quality,
704-663-1699
Mooresville Regional Office
North Carolina Division of Water Quality
919- 807-6308
Raleigh, NC Emergency Management
Monday -Friday
8 AM- 5 PM
800- 858-0368 24 hr. Hotline
National Response Center
800-424-8802 24 hr.
EPA Region 4 Emergency Response Spill Report
404-562-8700
Hotline, Atlanta, GA
EPA Region 4 Emergency Response and
800-564-7577
Removal Branch
North Carolina Hazardous Waste Section
919-508-8400
For guidance on disposal
Poison Control, if applicable
800-222-1222
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SOP No. ENG-3366
Origination Date:
Revision Date:
Approved:
REPEAT OFFENDERS
To determine if the incident or property owner is a repeat offender, the Stormwater Compliance
Coordinator will search the incident in the spreadsheet log by address and / or by responsible
party for repeat offences at the same location / address.
FOLLOW UP PROCEDURES
1. Letters
A letter will be sent to the property owner, tenant, or business operator by the Stormwater
Compliance Coordinator asking the tenant or resident to clean up or discontinue the illicit
discharge. A time frame will be given for corrective action to take place. If the corrective
action is not taken within the time frame, a Notice of Violation (NOV) letter is written with
citations. The Stormwater Engineer must review all letters before sending out. The review
process may be streamlined using preapproved templates for various situations.
If the issues pertain to a dumpster violation, the violations shall be forward to Code
Enforcement to address. #0 days after the dumpster issues has been forward the Code
Enforcement staff, the Stormwater Compliance Coordinator or their designee shall visit the site
to verify that the dumpster issue has been resolved.
Note: The Stormwater Compliance Coordinator will include educational information (ex.
brochure) on how the property owner, tenant, or business operator can help reduce
stormwater pollution from site. In addition, the Environmental Educator can assist with
educating the property owner, tenant, or business operator staff on good housekeeping
practices to reduce stormwater pollution.
2. Letters of Notice of Violations
Depending on the type of Illicit Discharge, the Stormwater Compliance Coordinator will send
a letter of Notice of Violation (NOV) to the property owner(s), and/or tenant, to inform them
of the violation of the City's Stormwater Management Ordinance. Educational material may
be included. This may include door hanger, brochures and flyers. Brochures may be specific
to the violation. Examples are grass clippings, leaves and yard waste, pet waste,
trash/litter/food waste, soil erosion/sediment and oil. If an NOV is warranted, the NOV shall be
sent out Certified Mail. An affidavit of service must be filled out and sealed by notary for the
file. Prior to sending out, the Engineering Director and the Stormwater Engineer must review
the NOV letter.
Note: For industrial sites, the City of Monroe Economic Development shall be contacted prior
to any enforcement action. The issue should be reviewed with Economic Development
Department staff. Depending on the type of spill or illicit discharge, the regional office of NC
DEQ may be notified for sites that have an Industrial Stormwater NPDES permit, discharge
directly into surface waters, or where a priority Illicit Discharge is found and not corrected in a
timely manner.
3. Tracking and Record Keeping
All maps, letters, spill reports, and other information related to the illicit discharge or spill will be
filed electronically in "Illicit Discharge Sites" folder on the I -drive. The incidents are arranged
by year and address.
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Revision Date:
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Documents are filed on the I -drive.
/:\Stormwater\Stormwater Management Program\NPDES Phase II\Six Measures\Illicit
Discharge\Tracking\Illicit Discharge Sites
Photos are stored on the P-drive.
P:\Stormwater\Stormwater Management Program\NPDES Phase II\Six Measures\Illicit
Discharge\Tracking
The incident is entered into Access to record in GIS on the G drive.
G:\City\StormWater\IDDE_TRACKING_GIS
As information is received, such as contacts, type of discharge, verified discharge, etc. the
data should be filled in the Access program to record on GIS layer Data Base. This will allow
the City to track all spills and illicit spills to determine the areas of high priority. In addition, this
will allow Stormwater Compliance Coordinator to track reoccurrences for all locations by
adding notes of each visits.
Once the incident is logged in the tracking form, the Stormwater Compliance Coordinator
schedules a revisit on the outlook calendar with the Stormwater Technician to re -visit the site.
4. The Stormwater Compliance Coordinator will periodically reviews the list and makes site re-
visits to check the status of any illicit discharge that is not considered resolved.
CLOSEOUT PROCEDURE
1. Final Site Visit - The site will be re -visited by the Stormwater Compliance Coordinator or their
designee with documentation of the previous site visits including photos.
2. Once the illicit discharge or spill has been corrected/cleaned/discontinued, a close out letter
shall be sent out to inform the customer or the property owner of that the site is in compliance
and will still be monitored periodically. All information pertaining to the site will be kept in the
I drive until the City's NPDES stormwater permit cycle changes.
3. When new permit cycle begins all files pertaining to the past permit, the cycle should be move
to LaserFiche.
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