NCS000450_Carrboro Illicit Discharge Program Plan 2_20220630

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Town of Carrboro
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3.2.4 Provide educational information to municipal employees, businesses and the public of
hazards associated with illicit discharges, illegal dumping, and improper disposal of
waste.
3.2.5 Provide a stormwater hotline/helpline for public education and outreach.
3.3 Public Involvement and Participation Program
The SWMP shall identify the specific elements for implementing, documenting and tracking a
Public Involvement and Participation Program that complies with State and local public notice
requirements and, at a minimum, shall:

3.3.1 Provide mechanisms for public input on stormwater issues and the stormwater program.
3.3.2 Provide volunteer opportunities to ongoing citizen participation.
3.4 Illicit Discharge Detection and Elimination Program
The SWMP shall identify the specific elements to develop, implement, and enforce an Illicit
Discharge Detection and Elimination (IDDE) Program in accordance with 40 CFR §122.34(b)(3).
At a minimum, the IDDE Program shall:
3.4.1 Develop, update and maintain a municipal storm sewer system map including stormwater
conveyances, flow direction, major outfalls and waters of the United States receiving
stormwater discharges.
3.4.2 Provide an IDDE ordinance or other regulatory mechanism that provides legal authority
to prohibit, detect, and eliminate illicit connections and discharges, illegal dumping and
spills into the MS4, including enforcement procedures and actions.
3.4.3 Maintain and implement a written IDDE Plan to detect and address illicit discharges,
illegal dumping, spills and any non-stormwater discharges identified as significant
contributors of pollutants to the MS4. The plan shall provide standard procedures and
documentation to:
a) Locate priority areas likely to have illicit discharges,
b) Conduct routine dry weather inspections of all major outfalls,
c) Identify illicit discharges and trace sources,
d) Eliminate the source(s) of an illicit discharge, and
e) Evaluate and assess the IDDE Program.
3.4.4 Provide a mechanism for tracking and documenting each illicit discharge, illicit
connection or illegal dumping event including date(s) reported and/or observed, the
results of the investigation, any follow-up of the investigation, the date the investigation
was closed, the issuance of enforcement actions, and the ability to identify chronic
violators.
3.4.5 Train municipal staff and contractors who, as part of their normal job responsibilities,
may observe an illicit discharge, illicit connection, illegal dumping or spills. Training
shall include how to identify and report illicit discharges, illicit connections, illegal
dumping and spills. Each staff training event shall be documented, including the
agenda/materials, date, and number of staff participating.
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Town of Carrboro
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3.4.6 Provide a mechanism for the public and staff to report illicit discharges, illegal dumping
and spills. The mechanism shall be publicized to facilitate reporting and shall be managed
to provide rapid response by appropriately trained personnel.
3.5 Construction Site Runoff Control Program (Construction Program)
The SWMP shall identify the specific elements to develop, implement, and enforce a
Construction Program to reduce pollutants in stormwater runoff from construction activities that
result in land disturbance of greater than or equal to one acre, and any construction activity that is
part of a larger common plan of development or sale that would disturb one acre or more.

Reliance upon a North Carolina Sediment Pollution Control Act of 1973 (SPCA) program as
defined in 15A NCAC Chapter 04 may be used to meet requirements 3.5.1 through 3.5.4 below.
At a minimum, the Construction Program shall:

3.5.1 Provide an ordinance or other regulatory mechanism to require erosion and sediment
controls, as well as sanctions to ensure compliance, to the extent allowable under State,
Tribal or local law.
3.5.2 Require construction site operators to implement appropriate erosion and sediment
control BMPs.
3.5.3 Provide procedures for site plan review which incorporate consideration of potential
water quality impacts.
3.5.4 Provide procedures for site inspection and enforcement of control measures.
3.5.5 Require construction site operators to control waste such as discarded building materials,
concrete truck washout, chemicals, litter, and sanitary waste at the construction site that
may cause adverse impact to water quality.
3.5.6 Provide and promote a means for the public to notify the appropriate authorities of
observed erosion and sedimentation problems.

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Article IV
ILLICIT DISCHARGES INTO AND CONNECTIONS
TO STORM SEWER SYSTEM
Section 5-30 Purpose
The purpose of this article is to regulate illicit discharges into and connections to the storm sewer
system in order to comply with the requirements of the Town’s National Pollutant Discharge
Elimination System Permit.
Section 5-31 Definitions
Unless otherwise specifically provided, or unless otherwise clearly indicated by the context, the
words and phrases defined in this section shall have the meaning indicated when used in this
article.
(1) Administrator. The person assigned by the Town Manager to enforce or otherwise
perform any duties required under this article.
(2) Discharge. To put, place, dump, spill, pump, pour, or otherwise deposit any solid or
liquid material.
(3) Illicit Connection. Any drain, pipe, or other constructed or manufactured conveyance
through which or by which any liquids, other than stormwater or those liquids listed in
subsection 15-32(b), are conveyed and discharged directly into the storm sewer system or
a surface water.
(4) Illicit discharge. A discharge that violates Subsection 5-32 (a).
(5) Pollutant. Anything which causes or contributes to pollution. Pollutants may include,
but are not limited to: paints, varnishes, and solvents; soaps and cleaning solutions;
kerosene, gasoline, oil and other automotive fluids; liquid and solid wastes and yard
wastes; refuse, rubbish, garbage, litter, or other discarded or abandoned objects or
accumulations, to the extent that the same may cause or contribute to pollution;
pesticides, herbicides, and fertilizers; hazardous substances and wastes; sewage, sewage
sludge, fecal coliform and pathogens; dissolved and particulate metals; animal wastes;
dredged spoil; filter backwash; salt; chemical wastes; biological materials; toxic
materials; radioactive materials; wrecked or discarded equipment; sand; dirt; ashes and
incinerator residue; wastes and residues that result from constructing a building or
structure; and noxious or offensive matter of any kind. This includes any chemical
additive to water potentially causing or contributing to pollution. (Amend. 5/3/22)
(6) Pollution. The alteration of the physical, thermal, chemical, or biological quality of,
or the contamination of, any water of the State or of the United States, that renders the
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water harmful, detrimental, or injurious to humans, animal life, vegetation, or property, or
to the public health, safety, or welfare, or impairs the usefulness or the public enjoyment
of the water for any lawful or reasonable purpose.
(7) Storm Sewer System. A system of human-produced structures owned by the Town of
Carrboro or the North Carolina Department of Transportation or another State agency
that is designed to collect or convey stormwater, including but not limited to streets
(including associated curbs, gutters, drainage ditches, or swales), inlets, culverts, drainage
pipes, detention or retention basins, and other drainage structures and facilities.
(8) Stormwater. Any surface flow, runoff, or drainage that occurs during or following any
form of natural precipitation and that results from such precipitation.
(9) Surface waters. All, streams, lakes, and ponds that appear as surface waters on either
the most recent version of the soil survey map prepared by the Natural Resources
Conservation Service of the United States Department of Agriculture or the most recent
version of the 1:24,000 scale (7.5 minute) quadrangle topographic maps prepared by the
United States Geologic Survey (USGS) as well as Town regulated streams. (Amend.
5/3/22)
Section 5-32 Illicit Discharges Prohibited
(a) No person may discharge or cause to be discharged, or allow to be discharged from
property under such person’s control, any pollutant directly or indirectly into the storm
sewer system or into surface waters.
(1) A direct discharge occurs when a pollutant is discharged within the physical
limits of the storm sewer system or within the banks of a stream or inside the
mean high water level of a pond or lake.
(2) An indirect discharge occurs when a pollutant is discharged outside the
physical limits of the storm sewer system or outside the banks of a stream or
beyond the mean high water level of a pond or lake but takes place in such a
manner or location that the pollutant is carried into the storm sewer system or
surface water in some way other than by action of the wind or stormwater. By
way of illustration without limitation, an indirect discharge would occur if water
from a commercial car wash is discharged onto the area where the cars are
washed and allowed to drain into a public street.
(3) An indirect discharge also occurs when a pollutant is discharged (i) outside the
physical limits of the storm sewer system or outside the banks of a stream or
beyond the mean high water level of a pond or lake, but (ii) with the specific
intent that the pollutant be disposed of by being carried (by the wind or
stormwater or otherwise) into the storm sewer system or a surface water, and (iii)
the pollutant or some part or portion thereof does reach the storm sewer system or
surface water. By way of illustration without limitation, dumping used oil near the
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edge of a stream with the intent that the next rain will carry the oil into the stream
constitutes an indirect discharge within the meaning of this subsection.
(b) Notwithstanding the other provisions of this article, the following shall not be
regarded as constituting an illicit discharge:
(1) Water line or hydrant flushing;
(2) Landscape or garden irrigation or lawn watering;
(3) Diverted stream flows;
(4) Rising ground waters;
(5) Uncontaminated ground water infiltration (as defined at 40 CFR 35.2005(20));
(6) Uncontaminated pumped ground water;
(7) Discharges from potable water sources;
(8) Foundation drains;
(9) Air conditioning condensation;
(10) Springs;
(11) Water from crawl space pumps;
(12) Footing drains;
(13) Individual residential car washing or charity car washing that does not allow
water to directly enter the stormwater system; (Amend. 5/3/22)
(14) Flows from riparian habitats and wetlands;
(15) Dechlorinated swimming pool discharges that discharge across ground in a
diffuse and non-erosive manner outside the stream buffer; (Amend. 5/3/22)
(16) Street wash water;
(17) Flows from fighting fires;
(18) Other non-stormwater discharges for which a valid NPDES discharge permit
has been approved and issued by the State of North Carolina;
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(19) Runoff from residential properties that is discharged as diffuse flow in a non-
erosive manner outside the stream buffer. (Amend. 5/3/22)
Section 5-33 Illicit Connections Prohibited
(a) No person may cause, suffer, or permit on property under such person’s control any
illicit connection to the storm sewer system, including without limitation connections of
drains or lines that convey sewage, process wastewater, wastewater from washing
machines, wash water from commercial vehicle washing or steam cleaning, or water from
indoor sinks or floor drains.
(b) Subject to subsection (c), if, on the effective date of this article, an illicit connection
as defined in this article exists, then such situation shall not be considered a violation of
this article until ninety (90) days after the Town mails by first class mail written notice to
the owner (according to the most recent property records) of the property where the
condition exists, informing such owner of the nature of the violation and what must be
done to correct it.
(c) The ninety day grace period provided for in subsection (b) of this section shall not
apply if the administrator concludes that an illicit connection:
(1) Is likely to result in the discharge of hazardous materials or otherwise pose an
immediate threat to health or safety, or is likely to result in immediate injury to
real or personal property, natural resources, wildlife, or habitat; or
(2) Was made in violation of any applicable statute, regulation, or ordinance.
Section 5-34 Inspections
(a) Upon the presentation of proper credentials, Town officers, agents, and employees
engaged in the enforcement of this article shall have a right to enter on any premises
within the Town at all reasonable hours for the purpose of making inspections,
collecting samples or carrying out other enforcement actions under this article. (Amend.
5/3/22)
(b) No person may obstruct or interfere with any Town officer, agent, or employee of the
Town engaged in the lawful performance of any task authorized or required by this
article.
Section 5-35 Enforcement
The Administrator is authorized to enforce the provisions of this article through the penalties and
remedies available for enforcement as set forth in Section 5-21 of this chapter. In addition,
nothing in this article is intended to preclude the Town from resorting in appropriate
circumstances to the procedures set forth in Chapter 11, Article V, Part 2 of the Town Code
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dealing with the summary abatement of conditions dangerous or prejudicial to the public health.
(Amend. 5/3/22)
(6) Timing of application.
(7) Recycling of grass clippings.
(8) Type of spreader (gravity or centrifugal).
(9) Name and contact information of applier.
(10) Reference document(s) used to develop the plan
Records shall be kept and updated annually to document the actual implementation of these
components. Nutrient quantities stored and applied shall be documented via sales receipts or
similar records.
(f) Landowners and other individuals applying nutrients to areas less than two acres
in size are encouraged to adopt manage practices to reduce the risk of surface water impacts and
apply nutrients at rates recommended by the North Carolina Cooperative Extension Service.
Section 5-21 Penalties and Remedies.
(a) A violation of any of the provisions of this chapter, other than those set forth in
Article III, shall constitute a misdemeanor, punishable as provided in G.S. 14-4.
(b) A violation of any of the provisions of this chapter, other than Section 5-15,
shall subject the offender to a civil penalty of $25.00 for the first offense, $50.00 for the second
offense within a 30-day period, and $100.00 for the third or any additional offense that occurs
within any 30-day period. A violation of the provisions of Section 5-15 shall subject the
offender to a civil penalty in the amount by which the contribution exceeds $250.00. If a person
fails to pay this penalty within 10 days after being cited for a violation, the town may seek to
recover the penalty by filing a civil action in the nature of debt. (Amend. 11/18/08, 3/3/09)
(bl) A violation of the provisions of Article IV of this chapter shall subject the offender to
a civil penalty of up to five thousand dollars ($5,000.00). In determining the amount of the civil
penalty assessment, the administrator shall consider the following factors, and the decision levying a
civil penalty shall cite those factors deemed applicable: (Amend. 11/18/08)
(1) The degree and extent of harm to the natural resources of the town, to the public health, or
to private property resulting from the violation;
(2) The duration and gravity of the violation;
(3) The cost to the violator or others of rectifying the damage;
(4) The amount of money saved by the violator by noncompliance;
(5) Whether the violation was committed willfully or intentionally, negligently, or as the
result of an unforeseeable or unavoidable accident;
(6) Whether the violator promptly ceased the violation upon notice by the town and took
whatever steps were reasonably possible to limit or correct any damage caused by the
violation;
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(7) The prior record of the violator in complying or failing to comply with the provisions of
Article IV of this chapter;
(8) The cost to the town of the enforcement procedures;
(9) Whether the civil penalty is levied for a single day's violation or a single event or
whether it is levied on a daily basis for a continuing violation, as authorized under
subsection (d) below. Civil penalties levied on a daily basis may cumulatively exceed
the $5,000.00 cap set forth in this subsection.
(c) The town may seek to enforce this chapter through any appropriate equitable action.
(d) Each day that a violation continues after the offender has been notified of the
violation shall constitute a separate offense.
(e) The town may seek to enforce this chapter by using any one or a combination of
the foregoing remedies.
(f) Complaints regarding alleged violations of the provisions of Subsection 5-12(4)
(which deal with construction noise) may be filed with the police department or with the town
manager or the manager's designee (other than a member of the police department). Complaints
filed with the manager or the manager's designee shall be referred to the police department. The
police department shall investigate such complaints and take such action as is warranted by
the results of that investigation.(Created 3/24/15)
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Town of Carrboro
Stormwater Division
Rev. 1/19/2022 Page 1 of 4
Outfall Inspection Standard Operating Procedure
1 Purpose
The purpose of this procedure is to accurately, efficiently and safely conduct outfall inspections
in order to detect illicit discharges in accordance with the Town of Carrboro’s MS4 permit.
This Standard Operating Procedure complies with the requirements of the Town of Carrboro’s
Municipal Separate Storm Sewer Permit, as issued by the State of North Carolina Department of
Environmental Quality. Specifically, this partially fulfills permit requirement 3.4.3: IDDE Plan.
This procedure was developed in part from the Illicit Discharge Detection and Elimination
Guidance Manual produced by the Center for Watershed Protection and Robert Pitt, University
of Alabama (2004), hereafter referred to as “the CWP Manual”.
2 Scope
An outfall is the point where a Municipal Separate Storm Sewer System discharges to surface
waters. An illicit discharge is any direct or indirect non-storm water discharge to the storm drain
system.
3 General Requirements
3.1 Responsibility
3.1.1 Stormwater Utility Manager
The Stormwater Utility Manager is responsible for ensuring that employees are properly
informed of and trained on how to follow these procedures and are using the most current
version of the procedures.
3.1.2 Personnel Performing the Job
Anyone responsible for conducting outfall inspections must follow these procedures and
specifically Chapter 11 of the CWP Manual- The Outfall Reconnaissance Inventory.
3.2 Recordkeeping
The Outfall Inspection Field Sheet, pictures, and related documents shall be stored in CityWorks
in accordance with the Section 4.4. of this document and the IDDE Documentation Standard
Operating Procedure.
4 Procedures
4.1 Inspection Schedule
Outfall inspections may be conducted on a regular basis in accordance with the Town of
Carrboro Illicit Discharge Detection and Elimination Program, or as needed due to stormwater
hotline calls or emails, observations of illicit discharges, or for any other reason.
Town of Carrboro Stormwater Division
Outfall Inspection SOP
Rev. 1/19/2022 Page 2 of 4
4.1.1 Ideal conditions
Inspections are best conducted when stream vegetation is at a minimal level, and ideally when
disease-carrying or dangerous animals are not present; the best time of year maybe late fall,
winter, or early spring.
Inspections should also be conducted during dry weather, when there has been at least 48
hours without any precipitation, and when groundwater levels are low. Staff may find weather
data at the North Carolina Climate Office website, at this link:
https://climate.ncsu.edu/cronos/?station=CHAP
4.2 Preparation
4.2.1 Background Information
Before conducting an outfall inspection, personnel should familiarize themselves with the outfall
being visited, the surrounding land use, property ownership issues, and historical factors. It may
be helpful to complete the “Background Data” portion of the Outfall Inspection Field Sheet
before visiting. Staff may also wish to print out aerial photographs of the area, GIS information,
or other documents as necessary.
4.2.2 CityWorks
Schedule the inspection in CityWorks.
Select “Create” > “Inspection”
Entity Group: “Stormwater”
Select Feature “Outlets”
Select the “Outfall Inspection” template
Assign the inspector, date, priority, and other relevant information. Keep status as
“New” if preparing in advance.
Make sure to save the inspection.
4.2.3 Materials
The following materials should be assembled before visiting the site:
-Digital camera, or electronic device with camera capabilities
-Town-issued iPad with CityWorks platform installed
-Maps, aerial photographs or other helpful spatial documents
-Blank Outfall Inspection Field Sheets
-Tape Measure
-Stop watch, or other time-keeping equipment
-Personal Protective Equipment, including hip waders/rain boots, appropriate clothing,
footwear, and hats
-Field test kits, including pH, turbidity, and flow meters and/or Hach meter
-Sample collection bottles
-Cooler with ice for sample bottles
4.3 Conducting the Inspection
The outfall inspection will be conducted utilizing the attached Outfall Inspection Field Sheet and
filling in all applicable sections. Some information may be gathered before or after the field
inspection. For specific guidance on completing each section of the Field Sheet, and pictures
that provide examples, refer to the CWP Manual, beginning on Page 98.
4.3.1 Background Data
This section includes information about the location of the outfall, time and date of the
inspection, surrounding land use, and other relevant contextual information. This section may
be partially completed before the inspection.
Town of Carrboro Stormwater Division
Outfall Inspection SOP
Rev. 1/19/2022 Page 3 of 4
4.3.2 Outfall Description
Information about the outfall itself, including the material, shape, and dimensions of the pipe or
open drainage channel. First, select whether the outfall is a closed pipe or open drainage, fill in
corresponding characteristics, and identify flow type (if any).
4.3.3 Field Data for Flowing Outfalls
If collecting a sample, time how long it takes to fill the volume of the bottle and record the time
under Flow #1. This measurement can also be helpful if samples are not being sent for analysis,
to give a characterization of flow speed. If the flow is of a measurable depth and width, record
that information under Flow #2. Also record the temperature, pH, and ammonia level of the
flow using your field kits.
4.3.4 Physical Indicators for Flowing Outfalls Only
Record any physical characteristics of the flow, including odor, color, turbidity and floatables.
Check the appropriate boxes, and rate the severity from 1 to 3. Record any additional physical
indicators you observe.
4.3.5 Physical Indicators for All Outfalls
Record physical characteristics of the outfall itself, including any damage, stains, abnormal
vegetation, poor pool quality or benthic growth within the pipe. Make any additional comments
that may help determine whether or not illicit discharge is ongoing.
4.3.6 Overall Outfall Characterization
Utilize the information you have gathered to make an overall characterization of the outfall – do
the physical indicators and overall appearance indicate that an illicit discharge may be
occurring? Make any necessary comments.
4.3.7 Sample Collection
If a sample is being collected for analysis, mark whether it was taken from the flow or pool, and
whether or not an intermittent flow trap was set. Make sure to also fill in the Chain of Custody
as appropriate.
4.3.8 Non-Illicit Discharge Concerns
List any additional concerns you may have about the outfall.
4.3.9 Additional Comments
Record any other comments.
4.4 Reporting the Results of the Inspection
4.4.1 Paperwork
Take a picture or scan the hard copy Outfall Inspection Field Sheet and save in the appropriate
folder on the shared Stormwater drive.
4.4.2 CityWorks
Navigate to the appropriate inspection in CityWorks. If it has not been scheduled ahead of time,
follow the instructions in 4.2.2 of this document. Enter your observations into the appropriate
field of the inspection template. Make sure to tag individuals who may need to be involved in
issues that were observed. Assign work orders as necessary. Attach any pictures taken, a scan or
picture of the completed Field Sheet, and any relevant emails.
Town of Carrboro Stormwater Division
Outfall Inspection SOP
Rev. 1/19/2022 Page 4 of 4
4.5 Follow-Up
4.5.1 Contacts
The following individuals may be helpful or need to be alerted if issues are discovered:
Name Organization Title Phone
Number
Email
Randy Dodd Town of Carrboro Stormwater Utility
Manager
919-918-7341 [e-mail]
Daniel Snipes Town of Carrboro Interim Public
Works Director
919-918-7432 [e-mail]
Victoria Hudson Orange County Environmental
Health Director
919-245-2365 [e-mail]
Jesse Duclau OWASA Distribution and
Collection Systems
Manager
919-537-4280 [e-mail]
NCDEQ Environmental
Emergency Hotline
1-800-858-0368
NCDEQ Raleigh Regional
Office
1-877-623-6748
4.5.2 Sample Analysis
If samples have been collected for analysis, prepare them for shipment to the appropriate
laboratory. If sewage is suspected to be present, the samples should be analyzed by the OWASA
laboratory. Otherwise, samples should be sent to another certified laboratory. Make sure to
complete the appropriate Chain of Custody form and store samples at the required temperature
(usually 2-4˚C).
5 Review of Procedures
This Standard Operating Procedure shall be reviewed annually in accordance with the Town of
Carrboro Illicit Discharge Detection and Elimination Program.
6 Outfall Inspection Field Sheet
See attached.
Revision Date: 1/19/2022
Revised By: Emily Cochran, Stormwater Administrator
Approval Date:
Approved By:


TOWN OF CARRBORO STORMWATER DIVISION
OUTFALL INSPECTION FIELD SHEET
Section 5: Physical Indicators for All Outfalls
Are physical indicators that are not related to flow present? ❑ Yes ❑ No
(If No, Skip to Section 6)
INDICATOR
CHECK IF
PRESENT
DESCRIPTION
COMMENTS
❑ Spalling, Cracking or Chipping
Outfall Damage
❑
❑ Peeling Paint
❑ Corrosion
Deposits/Stains
❑
❑ Oily ❑ Flow Line ❑ Paint
❑ Other:
Abnormal
El
Excessive ❑ Inhibited
Vegetation
❑ Odors ❑ Colors
Poor pool quality
❑
❑ Floatables ❑ Oil Sheen
❑ Suds ❑ Excessive Algae
❑ Other:
Pipe benthic
❑
❑ Brown ❑ Orange
growth
❑ Green ❑ Other:
:Peczion o: vveran nnciz viscnarge %, ciractenzaLion
❑ Unlikely ❑ Potential
(presence of two or more indicators)
❑ Suspect ❑ Obvious
(one or more indicators with a severity of 3)
Comments:
Section 7: Sample Collection
1. Sample for the lab?
❑ Yes
❑ No
2. If yes, collected from:
❑ Flow
❑ Pool
3. Intermittent flow trap set?
If Yes, type: ❑ OBM ❑ Caulk dam
❑ Yes
❑ No
4• Chain of Custody completed?
❑ Yes
❑ No
Section 8: Non -Illicit Discharge Concerns (e.g., trash or needed infrastructure repairs)?
Section 9: Additional comments
Rev. 10/8/2020 Page 3 of 3

Town of Carrboro
Stormwater Division
Rev. 10/9/2020 Page 1 of 5
IDDE Documentation
Standard Operating Procedure
1 Purpose
The purpose of this procedure is accurately and efficiently document investigations, hotline
notifications, and other communications pertaining to the Town of Carrboro’s Illicit Discharge
Detection and Elimination Program.
This Standard Operating Procedure complies with the requirements of the Town of Carrboro’s
Municipal Separate Storm Sewer Permit, as issued by the State of North Carolina Department of
Environmental Quality. Specifically, this partially fulfills permit requirement 3.4.3.: IDDE Plan,
3.4.4.: IDDE Tracking and 3.4.6.: IDDE Reporting.
2 Scope
The Town of Carrboro’s Illicit Discharge Detection and Elimination Program was developed in
order to identify sources of pollution to the storm sewer system and surface waters. Many
aspects of this program require proper documentation to ensure proper procedures are
followed and any illicit discharges identified are properly recorded and responded to. This SOP
provides procedures for adequately reporting and documenting in accordance with the
Program.
3 Responsibility
3.1 Stormwater Utility Manager
The Stormwater Utility Manager is responsible for ensuring that employees are properly
informed of and trained on how to follow these procedures and are using the most current
version of the procedures.
3.2 Stormwater Division Staff
Anyone responsible for responding to reports of illicit discharges, conducting investigations or
making inquiries in accordance with the IDDE Program shall be subject to this Procedure.
4 Documenting Reports of Illicit Discharges
4.1 Stormwater Hotline
4.1.1 Background
The Stormwater Division has established a stormwater hotline [phone]) which is used to
report issues of flooding, potential illicit discharges, and general inquiries. This number is
published on the Stormwater Division website (www.townofcarrboro.org/287/Stormwater) and
advertised during events and on promotional materials. All calls placed to the stormwater
hotline lead to a voicemail box. Voicemails are automatically emailed to Stormwater Division
staff.
Town of Carrboro Stormwater Division
IDDE Documentation SOP
Rev. 10/9/2020 Page 2 of 5
4.1.2 Documentation Procedure
Upon receipt of an email containing a voicemail message from the hotline, the Stormwater
Administrator determines whether or not the message warrants substantial follow-up from
staff. If so, the call is recorded as a Stormwater Investigation in Cityworks (categorized as a
service request). The Investigation is marked as “Stormwater Hotline” as a custom field. The
Administrator records the caller’s contact information, general notes about the request or
report, and dispatches the Investigation to appropriate personnel.
If staff determine that the call requires only minimal follow-up that does not reach the threshold
for requiring an investigation, the email is forwarded to appropriate personnel for response.
All emails containing stormwater hotline voicemails are stored in an Outlook folder. Summary
information of the call and related investigation are recorded in the Event Tracking spreadsheet.
4.2 Stormwater Hotline Email
4.2.1 Background
The Stormwater Division developed a shared email address ([e-mail])
in order to effectively dispatch questions, requests and reports to all Stormwater Division staff.
Emails sent to the above address are automatically forwarded to all Stormwater Division staff.
4.2.2 Documentation Procedure
Upon receipt of an email sent to the shared address, the Stormwater Administrator determines
whether or not the message warrants substantial follow-up from staff. If so, the email is
recorded as a Stormwater Investigation in Cityworks (categorized as a service request). The
Investigation is marked as “Stormwater Hotline” as a custom field. The Administrator records
the sender’s contact information, general notes about the request or report, and dispatches the
Investigation to appropriate personnel.
If staff determine that the email requires only minimal follow-up that does not reach the
threshold for requiring an investigation, the email is forwarded to appropriate personnel for
response.
All emails sent to the shared stormwater email address are stored in an Outlook folder.
Summary information of the email and related investigation are recorded in the Event Tracking
spreadsheet.
5 Documenting Investigations and Inspections
5.1 Stormwater Investigations
Stormwater Investigations may be prompted by reports via the stormwater hotline or email
address, issues observed by staff or personnel in other departments, or for a variety of other
reasons. If it is determined that an issue requires inquiry from Stormwater staff, it shall be
entered into Cityworks as a Stormwater Investigation, classified as a Service Request.
Complete as much information as is available. Ensure that the category “Stormwater Hotline” is
selected under “Custom Fields.” If the investigation is suspected to be an illicit discharge, select
“Illicit Discharge Detection & Elimination (IDDE)” under the “Project Name” field. Record
information in the Comments section, tagging individuals as appropriate. Attach all related
emails, voicemails, pictures and related documents under the “Attachments” field. Ensure that
the status is accurate – New, In Progress or Complete.
Town of Carrboro Stormwater Division
IDDE Documentation SOP
Rev. 10/9/2020 Page 3 of 5
If a field visit or other work is required, generate a work order through the service request page,
so it is appropriately associated with the investigation. Outfall Inspections, Stormwater Control
Measure Inspections and other inspections with specified templates should be recoded as
Inspections rather than Work Orders. See the below sections for details.
As the Stormwater Investigation is in progress, update the service request with new comments
and attachments as necessary. When the issue has been resolved, change the status to
“Complete” and update the information in the Event Tracking spreadsheet.
5.2 Outfall Inspections
Outfall Inspections are documented both in the field and in Cityworks. Utilize the “Outfall
Inspection Field Sheet” while in the field and refer to the “Outfall Inspection SOP” for details.
When the inspection has been completed, take a picture or scan the Field Sheet. Generate a
new Inspection in Cityworks and ensure that the appropriate outfall has been selected as an
associated asset. Fill out all appropriate information and attach pictures and the scan/photo of
the hard copy Field Sheet. If the inspection was related to a Stormwater Investigation, make
sure that it is associated.
Additionally, save all related information in the Stormwater shared drive.
5.3 Stormwater Control Measure Inspections
Stormwater Control Measure Inspections are completed using a variety of hard copy field
inspection sheets. Record them in Cityworks by generating a new Inspection and filling in all
appropriate information. Additionally, attach scans or photos of related documents, pictures,
and relevant emails to the Inspection in Cityworks. Also save all related information in the
Stormwater shared drive.
At the time of this revision, templates for SCM Inspections are in development. This section will
be updated accordingly when they are complete.
6 Standard Operating Procedures
6.1 Standard Operating Procedure Development
Below is a list of current or anticipated IDDE SOPs and their development status:
Procedure Status Revision Date
IDDE Documentation Complete 11/11/2020
Outfall Inspection Complete 10/9/2020
Illicit Discharge Identification
and Response
Planned
6.2 Review and Revision
SOPs will be revised as necessary, and at least annually. They will be reviewed and approved by
the Stormwater Utility Manager, with the revision and approval dates recorded.
7 Cityworks Platform
For the Stormwater Division, and in the context of the Illicit Discharge Detection and Elimination
Program, the Cityworks platform serves to integrate asset management, work orders,
Town of Carrboro Stormwater Division
IDDE Documentation SOP
Rev. 10/9/2020 Page 4 of 5
investigations, and geospatial mapping into a cohesive platform. As such, Cityworks serves many
functions with an array of tracking systems that cannot fully be enumerated here. However,
below is a list of relevant IDDE documentation that may be accessed via Cityworks, excluding
those described in the previous sections:
-Stormwater system mapping
-Inventory of storm drains
-Inventory of priority and non-priority outfalls
-Delineation of subwatersheds
-Inventory of stormwater control measures
-Tracking of reported flooding issues
-Tracking of reported illicit discharges
-Work orders pertaining to outfalls, SCMs or other structures
8 Sharing and Accessing Files
Digital files are stored on the Stormwater Share Drive, a secure drive managed by the Town of
Carrboro Information Technology Department. This drive is only accessible by Stormwater
Division Staff.
Files are shared throughout the Public Works department, and between departments within the
Town of Carrboro by using different secure drives also managed by the Information Technology
Department.
Files are shared with external parties by utilizing the Town of Carrboro Sharefile website,
located at https://townofcarrboro.sharefile.com. This is a secure website that allows larger files
to be accessed by anybody with the private link.
9 Review and Revision
This Standard Operating Procedure continues to be developed in accordance with the
requirements of the Town’s MS4 Permit.
Revision Date: 11/11/2020
Town of Carrboro Stormwater Division
IDDE Documentation SOP
Rev. 10/9/2020 Page 5 of 5
Revised By: Emily Cochran, Stormwater Administrator
Approval Date:
Approved By:
Town of Carrboro
Stormwater Division
Rev. 6/30/2022 Page 1 of 3
Illicit Discharge Investigation Program and Procedure
1 Purpose
The purpose of this program is to outline the process for performing illicit discharge
investigations including reporting, response, tracking, elimination and documentation of illicit
discharge events.
This program supports the requirements of the Town of Carrboro’s Municipal Separate Storm
Sewer Permit, as issued by the State of North Carolina Department of Environmental Quality.
Specifically, this partially fulfills permit requirement 3.4.3: IDDE Plan.
2 Scope
An illicit discharge is any direct or indirect non-storm water discharge to the storm drain system.
An illicit discharge could occur at any point in the MS4 or into surface waters.
3 General Requirements
3.1 Responsibility
3.1.1 Stormwater Utility Manager
The Stormwater Utility Manager is responsible for ensuring that employees are properly
informed of and trained on how to follow these procedures and are using the most current
version of the procedures.
3.1.2 Personnel Performing the Job
Anyone responsible for conducting illicit discharge investigations must follow these procedures.
3.2 Recordkeeping
Relevant correspondence, pictures, and related documents shall be stored on Cityworks in
accordance with the Section 4.4. of this document and the IDDE Documentation Standard
Operating Procedure.
4 Procedures
4.1 Notification
Staff may be notified of an active or past illicit discharge from members of the public, other
Town staff, or other agencies such as the Orange Water and Sewer Authority (OWASA). Upon
notification, staff shall record the location of the suspected illicit discharge, nature of the
discharge (e.g. sewage, paint, etc.), impacted streams or infrastructure, and contact information
of the responsible and/or notifying party if possible.
4.2 Investigation
4.2.1 Background Information
Before conducting an illicit discharge investigation, personnel should identify the location of the
discharge on the map and become familiar with the surrounding stormwater infrastructure and
land use.
Town of Carrboro Stormwater Division
Illicit Discharge Identification and Response SOP
Rev. 6/30/2022 Page 2 of 3
4.2.2 Materials
The following materials should be assembled before visiting the site:
-Digital camera, or electronic device with camera capabilities
-Town-issued iPad with Cityworks platform installed
-Maps, aerial photographs or other helpful spatial documents
-Tape Measure
-Stop watch, or other time-keeping equipment
-Personal Protective Equipment, including hip waders/rain boots, appropriate clothing,
footwear, and hats
-Field test kits, including pH, turbidity, and flow meters
-Sample collection bottles
-Cooler with ice for sample bottles
-Rubber gloves
-Paper towels
4.2.3 Conducting the Inspection
When staff arrive at the location, the discharge may or may not be obvious. If the source of a
suspected discharge has been identified, staff can move directly to directing responsible parties
to cease the discharge. However, the discharge may have to be tracked backwards from the
point of observation (such as a stream) and use the GIS map of stormwater infrastructure to
locate potential sources. Staff should investigate all potential sources and use sight as well as
scent to determine the source.
4.2.4 Sample Collection
If the source of the discharge cannot be identified, staff should collect samples of the discharge
into sterile bottles and prepare for analysis either with the Hach multimeter or for transfer to a
certified laboratory for analysis. Potential parameters to analyze are pH, ammonia, conductivity,
temperature, chlorine, fluoride, metals, E. coli or fecal coliform, or petroleum hydrocarbons.
If samples have been collected for analysis, prepare them for shipment to the appropriate
laboratory. If sewage is suspected to be present, the samples should be analyzed by the OWASA
laboratory. Otherwise, samples should be sent to another certified laboratory. Make sure to
complete the appropriate Chain of Custody form and store samples at the required temperature
(usually 2-4˚C).
4.3 Stopping the Discharge
Once the source and nature of the discharge have been determined, and staff have decided that
the discharge is contrary to the Town Code (i.e. is actually an illicit discharge), staff should notify
the responsible party to cease discharging and prevent further stormwater impacts
immediately. This may include the following actions:
-Asking the property owner to turn off the water line to the house to prevent additional
sewage from flowing
-Blocking stormwater inlets from the discharge using absorbent materials or mats
-Stopping any leaks or transfer of materials from their source, such as a leaking oil tank
4.4 Enforcement
Once the discharge has been stopped, remedies and enforcement should be pursued. For
sewage spills, property owners are required to fix the issue that caused the spill (such as a
clogged sewer lateral), and clean up the impacted area (remove solid and liquid wastes, apply
lime to affected soil for at least 24 hours).
Town of Carrboro Stormwater Division
Illicit Discharge Identification and Response SOP
Rev. 6/30/2022 Page 3 of 3
Staff should generate a Notification of Illicit Discharge, the template for which may be found in
the G: drive. Notifications should be addressed to any responsible parties including the property
owner, lessee if a rented property, contractors if responsible, etc. Notifications do not
necessarily hold a party liable, but are meant as a formal, written notification of the illicit
discharge.
Additional penalties may be pursued in accordance with the Town Code, Section 5-21.
4.5 Reporting the Results of the Investigation
4.5.1 Cityworks
Schedule an inspection in Cityworks.
Select “Create” > “Service Request”
Under Problem Tree, select “Stormwater” then “Stormwater Investigation”
Enter information including the address, details, and comments for both Incident
Information and Caller Information
Attach any relevant photos, generate work orders as necessary, assign responsible staff,
etc.
Under “Project Name,” choose “Illicit Discharge Detection & Elimination (IDDE)”
Make sure to save the service request.
4.5.2 Illicit Discharge Tracking spreadsheet
Record all relevant details in the Illicit Discharge Tracking spreadsheet including the reporting
party, impacted stream and subwatershed, nature of discharge, follow-up actions, and
enforcement actions.
4.6 Follow-Up
4.6.1 Contacts
The following individuals may be helpful or need to be alerted if issues are discovered:
Name Organization Title Phone Number Email
Randy Dodd Town of
Carrboro
Stormwater
Utility Manager
919-918-7341 [e-mail]
Daniel Snipes Town of
Carrboro
Public Works
Superintendent
919-625-2973 [e-mail]
Orange County Environmental Health 919-245-2361 [e-mail]
OWASA 919-968-4421
5 Review of Procedures
This Standard Operating Procedure shall be reviewed annually in accordance with the Town of
Carrboro Illicit Discharge Detection and Elimination Program.
Revision Date: 6/30/2022
Revised By: Emily Cochran, Stormwater Administrator
Town of Carrboro
Stormwater Division
Rev. 10/13/2020 Page 1 of 3
Fecal Coliform Reduction Program
1 Purpose
The purpose of this plan is to reduce the amount of Fecal Coliform and the bacteria Escheria coli
present in the stormwater system and surface waters in the Town of Carrboro’s jurisdiction. This
is accomplished through measures to control pet waste and on-site domestic wastewater
treatment systems (also known as septic systems).
Septic system management is coordinated with the Orange County Health Department,
Environmental Health Division (OCEH).
This program plan complies with the requirements of the Town of Carrboro’s Municipal
Separate Storm Sewer Permit, as issued by the State of North Carolina Department of
Environmental Quality. Specifically, this partially fulfills permit requirement 3.6.6. Fecal Coliform
Reduction.
2 Responsibility
2.1 Orange County Environmental Health Division
The Orange County Environmental Health Division maintains authority for the septic system
program in the Town of Carrboro’s jurisdiction, including issuing permits, responding to inquiries
and reports of failures, managing maintenance reports, etc.
2.2 Town of Carrboro Stormwater Division
The Stormwater Division staff coordinate with the OCEH by responding to reports of failures
that may impact stormwater quality. The Stormwater Division maintains a tracking system of
these events when they are reported, and ensures that the results of such events are recorded.
Staff also accompanies OCEH staff during environmental surveys when requested.
3 On-Site Wastewater (Septic) Systems
3.1 Tracking of Systems
The Orange County Environmental Health Division maintains a database of residential parcels
that contain on-site wastewater systems, which is tracked via EnerGov Permitting and
Inspections Software. Data collection is also supported by in-person inspections, detailed
records and drawings, and GPS units to precisely locate septic system components, wells,
building structures and other data points. The database is updated continuously.
This database has been shared with Town of Carrboro staff via excel spreadsheet and will be
compiled into a GIS layer.
3.2 Requirements for Owners
Before septic systems are installed, property owners must receive an Improvement Permit and
Construction Authorization. Septic tanks and drainfields must be properly maintained for a
standard conventional system, but systems including an effluent filter must be checked and/or
Town of Carrboro Stormwater Division
Fecal Coliform Reduction Program
Rev. 10/29/2020 Page 2 of 3
serviced every 2 to 3 years. Some septic systems have complex equipment that require routine
monitoring as per Orange County Regulations. According to the regulations, “Type of monitoring
and monitoring frequency shall vary by type of approval, the designated performance standard,
system design flow, and history of system performance…” (Section 1970(n)).
See the attached “Informational Justification of WTMP Inspections and Fees” document.
3.3 System Failure
Upon notification of failure of a septic system, the OCEH responds to the site within one (1)
business day. Personnel make contact with the owner of the property (if possible), determine if
there is a failure or violation, or if the complaint is unfounded or needs to be referred to another
department or jurisdiction. If there is an OCEH violation, an NOV is issued and sent to the owner
with a Repair Permit application. The NOV allows 30 days for correction of the malfunction and
requires pumping by a Licensed Septage Hauler at a frequency to prevent further discharge to
surface or groundwater. OCEH then follows up and verifies repair with a licensed Septic
Contractor and updates records accordingly.
Additionally, a number of system failures are found during the recurring WTMP inspections
(state required on pump systems installed or repaired 7/1/1992 or later). Depending on the
severity of the malfunction and needed repair, a soil evaluation may be needed to locate
additional system area or verify lack of suitable repair area to pursue alternative wastewater
system options such as pretreatment, state permitted discharge, etc.
The Stormwater Division catalogs these system failures and, if necessary, investigates the site to
determine if there have been any impacts to surface water quality.
3.4 Environmental Surveys
OCEH performs environmental surveys within the County. These surveys allow the Division to
randomly sample areas to determine whether or not septic systems may require maintenance,
or have failed and not been reported appropriately. Surveys allow in-person data collection and
direct interface with property owners who may not be aware of the full requirements of
maintaining their systems. Town of Carrboro Stormwater Division staff may accompany OCEH
staff during environmental surveys.
4 Pet Waste Control
The Stormwater Division has initiated a pet waste control program that primarily involves
education for pet owners and placement of pet waste “stations.” The Town encourages pet
owners to scoop and throw out their dog’s waste rather than leaving it on the ground, and to
properly dispose of cat litter by double bagging it and throwing it in the trash. Additionally, the
Town has installed five (5) pet waste stations that provide doggy bags and an informational sign
to encourage dog owners to pick up their pet’s waste.
5 Resources
OCEH Septic Systems webpage: https://nc-orangecounty.civicplus.com/731/Septic-Systems
Orange County Regulations for Wastewater Treatment and Disposal Systems
OCEH Informational Justification of WTMP Inspections and Fees (attached)
Town of Carrboro Stormwater Division
Fecal Coliform Reduction Program
Rev. 10/29/2020 Page 3 of 3
6 Review and Revision
This Program continues to be updated and revised in accordance with the Town’s MS4 Permit.
Revision Date: 10/29/2020
Revised By: Emily Cochran, Stormwater Administrator
Approval Date:
Approved By:
Upper Bolin
Creek
Middle Bolin
Creek
Past discharge complaints and reports 0 2
Storm water outfall density 2 1
Age of subwatershed development 2 2
Sewer conversion 0 3
Aging or failing sewer infrastructure 1 2
Density of aging septic systems 3 3
Raw IDP Score 8 13
Normalized IDP Score (on scale from 0-3)1.3 2.2
Density of generating sites or industrial NPDES storm water permits *0 0
Presence of older industrial operations **0 0
Poor dry weather water quality***TBD TBD
* There is one industrial stormwater permit in Carrboro, located in the Morgan Creek; Ready Mix Concrete, located on Gutherie Avenue
** There is only one current industrial operation in Carrboro; Ready Mix Concrete, located on Gutherie Avenue
*** The Town plans to utilize this screening factor in the future as resources allow.
Lower Bolin
Creek
Morgan Creek
(Below
University Lake)
Upper University
Lake (Morgan
Glen)
Lower
University Lake
0 2 0 0
1 3 2 1
3 3 1 1
0 1 0 0
3 3 0 0
1 1 2 1
8 13 5 3
1.3 2.2 0.8 0.5
0 1 0 0
0 1 0 0
TBD TBD TBD TBD
* There is one industrial stormwater permit in Carrboro, located in the Morgan Creek; Ready Mix Concrete, located on Gutherie Avenue
** There is only one current industrial operation in Carrboro; Ready Mix Concrete, located on Gutherie Avenue
*** The Town plans to utilize this screening factor in the future as resources allow.
Upper Bolin
Creek
Middle Bolin
Creek
Past discharge complaints and reports (ranking based on past 2 years)1 2
Storm water outfall density 2 1
Age of subwatershed development 2 2
Sewer conversion 0 3
Aging or failing sewer infrastructure 1 2
Density of aging septic systems 3 3
Raw IDP Score 9 13
Normalized IDP Score (on scale from 0-3)1.5 2.2
Number of discharge complaints and reports (past 2 years)1 4
Density of generating sites or industrial NPDES storm water permits *0 0
Presence of older industrial operations **0 0
Poor dry weather water quality***TBD TBD
* There is one industrial stormwater permit in Carrboro, located in the Morgan Creek; Ready Mix Concrete, located on Gutherie Avenue
** There is only one current industrial operation in Carrboro; Ready Mix Concrete, located on Gutherie Avenue
*** The Town plans to utilize this screening factor in the future as resources allow.
Lower Bolin
Creek
Morgan Creek
(Below
University Lake)
Upper University
Lake (Morgan
Glen)
Lower
University Lake
2 3 0 0
1 3 2 1
3 3 1 1
0 1 0 0
3 3 0 0
1 1 2 1
10 14 5 3
1.7 2.3 0.8 0.5
4 8 0 0
0 1 0 0
0 1 0 0
TBD TBD TBD TBD
* There is one industrial stormwater permit in Carrboro, located in the Morgan Creek; Ready Mix Concrete, located on Gutherie Avenue
** There is only one current industrial operation in Carrboro; Ready Mix Concrete, located on Gutherie Avenue
*** The Town plans to utilize this screening factor in the future as resources allow.
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Program Evaluation KPIs
BMP No.Description of BMP Measurable Goal Schedule for Implementation Permit Year(s) Reporting Metric
16 Continuously update stormwater system map Add new infrastructure as it is constructed.Continuously Permit Years 1-5 Total number of outfalls mapped
16 Continuously update stormwater system map Add new infrastructure as it is constructed.Continuously Permit Years 1-5 Number of outfalls added during permit year
16 Continuously update stormwater system map Add new infrastructure as it is constructed.Continuously Permit Years 1-5 Total miles of above ground infrastructure
16 Continuously update stormwater system map Add new infrastructure as it is constructed.Continuously Permit Years 1-5 Total miles of below ground infrastructure
17 Maintain Stormwater Control Measure inventory and mapAdd new SCMs as they are constructed.Continuously Permit Years 1-5 Total number of SCMs mapped
17 Maintain Stormwater Control Measure inventory and mapAdd new SCMs as they are constructed.Continuously Permit Years 1-5 Number of SCMs added during permit year
18 Update the Illicit Discharge Ordinance as necessary to maintain legal authority.Coordinate with Town Attorney to conduct review of Illicit Discharge Ordinance.Once per permit cycle Permit Year 1 Yes/No/Status
18 Update the Illicit Discharge Ordinance as necessary to maintain legal authority.Update Illicit Discharge Ordinance Once per permit cycle Permit Year 1 Yes/No/Status
19 Maintain a written IDDE Plan Conduct comprehensive initial review of current plan and revise accordingly.Once per permit cycle Permit Year 1 Yes/No/Partial
19 Maintain a written IDDE Plan Submit new plan to DEQ for review and approval.Once per permit cycle Permit Year 1 Date submitted
19 Maintain a written IDDE Plan Implement written IDDE Plan.Continuously Permit Years 2-5 Yes/No/Partial
19 Maintain a written IDDE Plan Conduct review of plan, standard documentation, forms, procedures and SOPs; make changes as necessary. Annually Permit Years 1-5 Yes/No/Partial
20 Locate priority areas most likely to have illicit dischargesReview/update MS4 inspection areas using Illicit Discharge Potential matrix.Annually Permit Years 1-5 Review conducted: Yes/No/Partial
20 Locate priority areas most likely to have illicit dischargesReview/update MS4 inspection areas using Illicit Discharge Potential matrix.Annually Permit Years 1-5 Number of high priority subwatersheds
21 Conduct routine dry weather outfall inspections Establish Outfall Reconnaissance Inventory inspection schedule, with minimum of 20% inspected annually Once per permit cycle Permit Year 1 Yes/No/Partial
21 Conduct routine dry weather outfall inspections Develop ORI inspection procedure, standard documentation and forms Once per permit cycle Permit Year 1 Yes/No/Partial
21 Conduct routine dry weather outfall inspections Inspect minimum of 20% MS4 per year (100% every 5 years)Continuously Permit Years 1-5 Number of outfalls inspected
21 Conduct routine dry weather outfall inspections Inspect minimum of 20% MS4 per year (100% every 5 years)Continuously Permit Years 1-5 Number of illicit discharges identified as a result of outfall inspections
22 Identify illicit discharges and connections, trace and eliminate sourcesInvestigate reports of illicit discharges to determine sources.Continuously Permit Years 1-5 Number of potential illicit discharges reported
22 Identify illicit discharges and connections, trace and eliminate sourcesInvestigate reports of illicit discharges to determine sources.Continuously Permit Years 1-5 Number of verified illicit discharges
22 Identify illicit discharges and connections, trace and eliminate sourcesHalt illicit discharges and remedy illicit connections as necessary Continuously Permit Years 1-5 Number of illicit connections and discharges remedied
22 Identify illicit discharges and connections, trace and eliminate sourcesIssue verbal and written enforcement, including Notices of Violation and penalties as appropriate Continuously Permit Years 1-5 Number of enforcement actions issued for illicit discharges or connections
23 Evaluate and assess the IDDE program at least annuallyReview program implementation and IDDE metrics at least annually.Annually Permit Years 1-5 Yes/No/Status
24 Monitor illicit discharges, investigations and enforcement actionsDocument illicit discharges in accordance with the Illicit Discharge Documentation SOP, including the Event Tracking spreadsheet and CityWorks.Continuously Permit Years 1-5 Number of entries in Event Tracking spreadsheet per permit year
24 Monitor illicit discharges, investigations and enforcement actionsReview illicit discharge database for potential chronic violators at least annually Continuously Permit Years 1-5 Number of established chronic violators
25 Train municipal staff to identify illicit discharges Develop written training plan and presentations for Town employees, first responders, and contractors likely to encounter illicit discharges Once per permit cycle Permit Year 1 Yes/No/Partial
25 Train municipal staff to identify illicit discharges Train municipal staff to identify and report potential illicit discharges Annually Permit Years 1-5 Number of staff members trained
25 Train municipal staff to identify illicit discharges Train municipal staff to identify and report potential illicit discharges Annually Permit Years 1-5 Percent of exams with passing score
25 Train municipal staff to identify illicit discharges Evaluate effectiveness of training by analyzing illicit discharges identified by Town personnel Annually Permit Years 2-5 Percent illicit discharges identified by staff
26 Monitor hotline and other reporting mechanisms for public and staff to report illicit dischargesDevelop written procedure for documenting and communicating hotline reports to relevant personnel, reporting tracking system and relevant forms Once per permit cycle Permit Year 1 Yes/No/Partial
26 Monitor hotline and other reporting mechanisms for public and staff to report illicit dischargesDistribute flyers and educational materials with reporting information to Town personnel and public Continuously Permit Years 1-5 Number of educational materials distributed
26 Monitor hotline and other reporting mechanisms for public and staff to report illicit dischargesTrack hotline and email communications Continuously Permit Years 1-5 Number of hotline emails and phone calls
26 Monitor hotline and other reporting mechanisms for public and staff to report illicit dischargesTrack hotline and email communications Continuously Permit Years 1-5 Number of inquiries leading to confirmed illicit discharges
26 Monitor hotline and other reporting mechanisms for public and staff to report illicit dischargesReview efficacy of stormwater email and hotline in identifying illicit discharges with Town personnel at least annually Annually Permit Years 1-5 Yes/No/Partial
IDDE BMPs
Program Evaluation KPIs
BMP No.Permit Reference Metric Result
16 MS4 Map Total number of outfalls mapped
16 MS4 Map Number of outfalls added during permit year
16 MS4 Map Total miles of above ground infrastructure
16 MS4 Map Total miles of below ground infrastructure
17 MS4 Map Total number of SCMs mapped
17 MS4 Map Number of SCMs added during permit year
21 ORIs Number of outfalls inspected
21 ORIs Number of illicit discharges identified as a result of outfall inspections
22 Identify illicit discharges Number of potential illicit discharges reported
22 Identify illicit discharges Number of verified illicit discharges
22 Identify illicit discharges Number of illicit connections and discharges remedied
22 Identify illicit discharges Number of enforcement actions issued for illicit discharges or connections
24 IDDE tracking Number of entries in Event Tracking spreadsheet per permit year
24 IDDE tracking Number of established chronic violators
25 Staff training Number of staff members trained
25 Staff training Percent of exams with passing score
25 Staff training Percent illicit discharges identified by staff
26 Hotline reporting Number of educational materials distributed
26 Hotline reporting Number of hotline emails and phone calls
26 Hotline reporting Number of inquiries leading to confirmed illicit discharges
Metrics to Track
Program Evaluation KPIs
BMP No.Permit Reference Review Review Parties Schedule Date Conducted Additional metric
18 Regulatory mechanism Illicit Discharge Ordinance Town Attorney Once - Permit Year 1
19 IDDE Plan IDDE Plan Once - Permit Year 1
19 IDDE Plan IDDE Plan, standard documentation, forms, procedures, and SOPs Annually
20 IDDE Plan MS4 Inspection areas using IDP matrix Annually Number of high priority watersheds
23 IDDE Plan Program implementation and IDDE metrics Annually
24 IDDE Tracking Illicit discharge database for potential chronic violators Annually Number of established chronic violators
26 IDDE Reporting Efficacy of stormwater email and hotline in identifying illicit discharges Town personnel Annually
Reviews to Conduct
Event Tracking
Date
Reported Date Closed Stormwater
Investigation ID Location Hotline Report? (Yes/No) Illicit Discharge? Non-Illicit Discharge Issue
1/5/2021 1/5/2021 N/A N/A - Foster Lake Pond ManagementYes No SCM
1/7/2021 1/7/2021 N/A N/A - Wooten Development CompanyYes No SCM
1/9/2021 1/9/2021 N/A 114 Deer Street Yes No SCM equipment
1/21/2021 1/21/2021 101 109 Milton Street Yes No Nuisance Flooding
2/17/2021 2/17/2021 106 100 Lindsay Street No Yes
3/29/2021 4/14/2021 109 500 Jones Ferry Rd Yes Yes
3/30/2021 3/30/2021 N/A 406 Oak Ave Yes No Nuisance Flooding
4/13/2021 4/13/2021 N/A 105 Robert Hunt Dr.Yes No Culvert repair
4/28/2021 4/29/2021 112 1309 Homestead Rd No Yes
5/11/2021 5/12/2021 113 605 N. Greensboro Rd.No Yes
5/21/2021 5/21/2021 N/A 302 E. Poplar Ave Yes No Yard waste
6/7/2021 6/9/2021 119 513 Cates Farm Rd.No Yes
6/7/2021 6/11/2021 120 Carrboro Plaza No Yes
6/8/2021 6/8/2021 N/A 104 Phipps Yes No Nuisance Flooding
7/9/2021 7/9/2021 121 406 Hogan Woods Circle Yes No Inlet fallen into street
7/28/2021 7/28/2021 N/A N/A - Impervious surface questionsYes No Impervious surface question
7/31/2021 10/18/2021 128 231 Sweet Bay Place Yes Yes
8/3/2021 8/3/2021 N/A 1402 Crawford Dairy Rd Yes No Property Tax Bill
8/3/2021 8/3/2021 N/A 401 Lorraine St.Yes No Vegetation in swale
8/6/2021 8/6/2021 N/A N/A - Billing Yes No Property Tax Bill
8/11/2021 8/11/2021 N/A N/A - David Blevins Claremont South Phase 5Yes No SCM conversion
8/13/2021 8/13/2021 N/A 302 E. Poplar Ave Yes No Yard waste
8/17/2021 8/17/2021 N/A Legends at Lake Hogan Farms Yes No SCM
9/2/2021 9/2/2021 N/A 101 High Street Yes No Drainage question
9/15/2021 9/21/2021 137 114 Bim Street No Yes
9/24/2021 9/24/2021 138 1215 Hillsborough Rd Yes No Firefighting activities
10/7/2021 10/18/2021 145 Wyndham Drive No Yes
10/14/2021 10/18/2021 147 110 E Main Street Yes Yes
11/2/2021 11/2/2021 N/A N/A - SCM question Yes No SCM question
12/7/2021 12/13/2021 153 100 E Main Street No Yes
2021
Event Tracking
Nature of Discharge Results of Investigation Action Taken to Eliminate Discharge Enforcement Actions File Folder Name Reporting Party
Muddy water Muddy discharge due to dewatering on property for construction of an addition.Verbal warning to landscaping company.Verbal warning Staff
Sewage Sewage overflow at a clean out at the rear of property due. NCDEQ is issuing enforcement.Water was shut off to building, plumbers made emergency repairs to restore wastewater service and prevent discharge.Verbal instruction to clean up sewage; referral to NCDEQ20210331_500JonesFerry_sewagePublic
Sewage Sewage overflow at a clean out at the front of the property. Determined that waste was likely not entering Bolin Creek, however the issue needed to be fixed.On 4/29 a plumber was dispatched to the property to repair the sewer line; also applied lime and fresh soil to the waste material to encourage decomposition.None 20210428_1309Homestead_sewageOWASA
Bleach Bleach was being used to clean exterior of building, however all water was being intercepted by vegetation, no enforcement.None None 20210511_605NGreensboro_bleachPublic
Sewage Blockage in drain line caused sewage to exit from cleanout cap, which was potentially damaged by lawn mower.Plumber has unclogged drain, replaced broken cleanout cap, removed organic materials and applied lime to the area.No enforcement.20210607_513CatesFarm_sewagePublic
Grease Hood cleaning company dumped greasy wastewater down roof gutters and entered stormwater system.Restaurant owner instructed to clean up area immediately outside of restaurant, property manager instructed to contract with company to clean stormwater inlets and pipes to SCM, hood cleaning company instructed that this was a violation.Written NOVs for all three parties.20210607_CarrboroPlaza_wastewaterPublic
Paint Investigation stalled - previously thought to be Tar Heel Painters, but additional paint was spilled 8/11/21 and that company was not on scene. It is likely due to a different and currently unknown contractor.Written notice of violation to property owner and Tar Heel Painters, posted sign at inlet, placed door hangers around neighborhood.Written NOV to property owners, mailed to both property address (231 Sweet Bay Place) and mailing address (6418 Raffia Rd. Charlotte, NC 28277). Written NOV to paint company (Tar Heel Painters).20210731_RobersonPlace_paintPublic
Sewage Broken pipe causing sewage to exit from clean out, traveled down to Unnamed Tributary to Morgan CreekOWASA turned off water, plumbers repaired issue, sewage was cleaned up, property owner will apply root prevention chemicalNone20210915_114BimSt_sewageOWASA
Carpet wash water Contacted Stanley Steemer with information about dischargeNone Written NOV to Stanley Steemer20211007_WyndhamDr_carpetwashwaterStaff
Sewage Cleanout blocked, sewage entered various inlets, will be cleaned up by contractorMarked off impacted areas, directed responsible party to have it cleaned upVerbal warning 20211014_110EMain_sewagePublic
Sewage Clog in sewer lateral from 100 E. Main causing backup of sewage in basement of Neal's Deli; sump pump in basement discharging wastewater to street, entering stormwater inlet and exiting to OUT-1501Immediate verbal direction to cease discharge (unplug sump pump); direction to employ sewage cleanup company who can clean up sewage without use of sump pump, clean street area impacted, call DEQ hotline to report wastewater entering surface water, within 24 hours.Written NOVs to property owner and Neal's Deli20211207_100EMain_sewageStaff
2021
Event Tracking
Primary Investigator Subwatershed Receiving Stream Notes
Randy Dodd, Emily CochranLower Bolin CreekBolin Creek
Randy Dodd, Emily CochranMorgan Creek Morgan Creek
Emily Cochran Middle Bolin CreekBolin Creek
Emily Cochran Lower Bolin CreekBolin Creek
Emily Cochran Middle Bolin CreekBolin Creek
Emily Cochran Morgan Creek Toms Creek
Emily Cochran Morgan Creek Morgan Creek
Emily Cochran Morgan Creek UT to Morgan Creek
Emily Cochran Middle Bolin CreekBolin Creek
Emily Cochran Morgan Creek Morgan Creek
Emily Cochran Morgan Creek UT to Morgan Creek
2021