20_IDDE Program

Illicit Discharge Detection and Elimination Program

Stormwater Division
1103 S. Mebane St.
Burlington, NC 27377
www.BurlingtonNC.gov
1/16/2013
IDDE Program
This document explains the procedures implemented to
effectively identify and eliminate illicit discharges within the
jurisdictional limits of the City of Burlington.

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Contents
Program Summary ........................................................................................................................................ 3
Purpose ......................................................................................................................................................... 3
Authority ....................................................................................................................................................... 3
Program Implementation Authority ......................................................................................................... 3
Right to Enter Property for Inspection ...................................................................................................... 3
Right to Sample and Test .......................................................................................................................... 3
Definitions ..................................................................................................................................................... 4
Illicit Discharges......................................................................................................................................... 4
Illicit Connections ...................................................................................................................................... 4
Identifying Illicit Discharges .......................................................................................................................... 5
Tip Initiated Investigations ........................................................................................................................ 5
City Initiated Investigations ...................................................................................................................... 5
High Priority Maps ................................................................................................................................ 5
Dry Weather Flows................................................................................................................................ 5
Water Quality Monitoring ..................................................................................................................... 5
Field Testing Investigations ....................................................................................................................... 5
Tracing Illicit Discharges ................................................................................................................................ 5
Removing Illicit Discharges ........................................................................................................................... 6
Notice of Violation .................................................................................................................................... 6
1. Written Notice .............................................................................................................................. 6
2. Establish Deadline for Compliance ............................................................................................... 6
3. Failure to Comply .......................................................................................................................... 6
Standard Operating Procedures ................................................................................................................... 6
COB IDDE TII .............................................................................................................................................. 7
COB IDDE CII-HPM ..................................................................................................................................... 9
COB IDDE CII-DWF ..................................................................................................................................... 9
COB IDDE CII-WQM ................................................................................................................................... 9
COB IDDE FTI ........................................................................................................................................... 11
COB IDDE TID........................................................................................................................................... 11
COB IDDE RID-NOV .................................................................................................................................. 12
Appendix A (City of Burlington IDDE Investigation Form) .......................................................................... 15

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Program Summary
The City of Burlington’s Illicit Discharge Detection and Elimination (IDDE) Program is implemented by the
Stormwater Division. This program is required by the City’s Municipal Separate Storm Sewer System
(MS4) Permit issued by NCDENR. The program approach is explained in Chapter 7 of the City’s
Stormwater Management Plan while authority to enforce the program is expounded upon in Section 7
of the City’s Stormwater Ordinance.
The Division employs a two-pronged approach in order to fully implement the IDDE program. The first,
a more passive approach, provides citizens, other departments, or agencies, the ability to identify and
inform the City of possible violations. To encourage reporting, the City promotes the Connecting
Burlington Communities (CBC) program which allows for those submitting the report to remain
anonymous or track the progression of submitted tips. Alternatively, concerns can be reported by calling
the City or via email. Despite the method of delivery, the Stormwater Division investigates possible
violations within 24 hours of notification.
The second approach is a proactive tactic. This approach involves staff actively seeking and searching
out illicit discharges within the City’s jurisdiction. This program involves staff walking streams looking
for illicit discharges and dry weather flows and sampling of water quality parameters at strategic
locations throughout the City. Discrepancies or indications of possible violations are investigated to
determine the source of the concern. If it is concluded a violation exists, the Division requires the
property owner to remove the source of the discharge and mitigate identified impacts.

Purpose
The purpose of this program is to protect, maintain and enhance the public health, safety, environment
and general welfare via elimination of illicit discharges into the City’s municipal separate stormwater
system.

Authority
Program Implementation Authority
Section 1-102 of the City’s Stormwater Ordinance establishes the authority by which the Stormwater
Division implements the IDDE Program. Authority to enforce this program includes all areas within the
city limits of the City of Burlington.
Right to Enter Property for Inspection
Section 7-701 (E) (1) of the Stormwater Ordinance grants staff the right to enter private property to
complete the necessary inspection for proper program implementation. If a property owner refuses
entry, the City may seek assistance from any court of competent jurisdiction in obtaining such entry.
Right to Sample and Test
Section 7-701 (E) (2) of the Stormwater Ordinance clarifies that City staff may take any samples and
perform any testing deemed necessary to aid in the pursuit of implementing this program.

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Definitions
Illicit Discharges
Illicit discharges are defined in Sections 7-701 (A) of the Stormwater Ordinance. Illicit discharges are
identified as any discharges that are NOT one of the following:
1. Water line flushing;
2. Landscape irrigation;
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. Irrigation water;
11. Springs;
12. Water from crawl space pumps;
13. Footing drains;
14. Lawn watering;
15. Individual residential car washing;
16. Flows from riparian habitats and wetlands;
17. Dechlorinated swimming pool discharges;
18. Street wash water; and
19. Flows from emergency firefighting.
20. Other non-stormwater discharges for which a valid NPDES discharge permit has been approved
and issued by the State of North Carolina, and provided that any such discharges to the
municipal separate storm sewer system shall be authorized by the City of Burlington.
Explicitly prohibited discharges include, but are not limited to, oil, anti-freeze, chemicals, animal waste,
paints, garbage, and litter.
Illicit Connections
Illicit connections are defined in Sections 7-701 (B) (1) of the Stormwater Ordinance. Illicit connections
are connections to a stormwater conveyance or stormwater conveyance system that allow the discharge
of non-stormwater, other than the exclusions described as an allowable discharge above, are unlawful.
Prohibited connections include, but are not limited to: floor drains, waste water from washing machines
or sanitary sewers, wash water from commercial vehicle washing or steam cleaning, and waste water
from septic systems.

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Identifying Illicit Discharges
This IDDE Program is designed to meet or exceed the requirements as set forth in the City of
Burlington’s MS4 Permit.
Tip Initiated Investigations
The City
City Initiated Investigations
The City
High Priority Maps
The City
Dry Weather Flows
The City
Water Quality Monitoring
The City
Field Testing Investigations
The City
Tracing Illicit Discharges
The City
1. Field Observation
2. HACH and YSI Portable Meter
3. Grab Samples
4. GIS
5. Citizen Interaction

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Removing Illicit Discharges
The City
1. Informal Directive
2. Housekeeping Notification
3. Loss of City Services
4. Notice of Violation

Notice of Violation
The City
1. Written Notice
2. Establish Deadline for Compliance
3. Failure to Comply
4. Recommendation for Enforcement

Standard Operating Procedures
COB IDDE TII
COB IDDE CII-HPM
COB IDDE CII-DWF
COB IDDE CII-WQM
COB IDDE FTI
COB IDDE TID
COB IDDE RID-NOV

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Standard Operating Procedure Narrative
The City of Burlington has continued to provide Illicit Discharge Detection and Elimination services
within the ETJ as to protect water quality prior to adoption of the NPDES program by the EPA. Presently
the stormwater division continues these efforts to investigate illicit discharges, provide dry weather
screening and eliminate unauthorized connections per the current NPDES permit conditions. This
document is an effort to formalize administrative procedures and ensure the IDDE program continues to
be implemented in the most efficient manner possible.
COB IDDE TII (City of Burlington Tip Initiated Investigation)
The City of Burlington operates a CBC Hotline that citizens can contact the City by phone or through the
internet to report possible discharges or suspicious connections to the MS4. Upon notification by a
citizen or other concerned party the TII is logged into the City’s MS4 database. This assigns the TII a
work order number and therefore allows the event to be documented. The response and reporting
flowchart shows the typical process for resolving this type of IDDE.

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COB IDDE TII Response and Reporting Flowchart

Suspected Illicit
Discharge Observed
by Citizen
Call or Email the City
via CBC Tipline or
[e-mail]
ington.com
Respond
Immediately to
Verify
Hazardous Discharge
Determination
Contact the Alamance
County Emergency
Management
& City of Burlington
Fire Dept
Contact Property
Owner and Elimnate
the Hazardous
Discharge from the
MS4
Input Task/Work Order
in MS4 Database &
Finalize Enforcement
Action as Necessary
Non-Hazardous
Illicit-Discharge
Determination
Contact Property
Owner and Elimnate
the NonHazardous
Discharge from the
MS4
Input Task/Work Order
in MS4 Database &
Finalize Enforcement
Action as Necessary
Non-Illicit Discharge
Determination
Non-Illicit Discharges
are documented but
no further Staff Time
Allocated
Input Task/Work Order
in MS4 Database &
Issue Notification to
Responsible Party(s)

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COB IDDE CII (City of Burlington Initiated Investigations)
The City of Burlington shall perform unprompted investigation of the MS4 for illicit discharges. This can
be accomplished through municipal staff awareness during the course of day to day activities. However
the City will implement three categories of outfall investigation that are separate from the TII program.
These activities are summarized in the following sections and also follow a response and reporting
flowchart.

CII-HPM (High Priority Maps)
The City of Burlington stormwater division has developed a high priority watershed map in which
outfalls of concern have been identified. These outfalls will be monitored and sampled on a quarterly
interval and evidence of an illicit discharge will require staff to perform a CII. An outfall on the HPM
map might routinely discharge from an allowable source. Only through periodic visual and analytical
testing can an allowable source be identified as not illicit. Evidence of an illicit discharge will require
staff to follow the response and reporting flow chart for a CII.
CII-DWF (Dry Weather Flow)
The City of Burlington is continuously monitoring for dry weather flows during periods of little rainfall.
Upon detection of a dry weather flow staff will investigate the dry weather flow using the CII flowchart
and if the discharge is considered illicit remove it from the system. Unlike the TII and other CII methods
a dry weather flow is often detected following a 72 hour period of little or no precipitation. Evidence of
an illicit discharge will require staff to utilize any and all methods deemed necessary to eliminate the
discharge.
CII-WQM (Water Quality Monitoring)
At present time the city is currently monitoring 20 distinct locations for the following parameters:
Dissolved Oxygen (DO), Specific Conductivity (SP), Temperature, PH, and Turbidity (NTU). These sites
are visited monthly to perform sampling and during this activity evidence of an illicit discharge could be
detected. Large deviations in normal baseline sampling data or visual observations could trigger an illicit
discharge investigation and staff would follow the CII response and reporting flowchart. A suspected
discharge remains illicit until either eliminated or determined to be allowable per the permitted
discharges in the City’s NPDES permit.

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COB IDDE CII Response and Reporting Flowchart

Suspected Illicit
Discharge
Observed/Detected
by City Staff
Hazardous Discharge
Determination
Contact the Alamance
County Emergency
Management
& City of Burlington Fire
Dept
Elimnate the Hazardous
Discharge from the MS4
Input Task/Work Order
in MS4 Database &
Finalize Enforcement
Action to Responsible
Party(s)
Non-Hazardous
Illicit-Discharge
Determination
Elimnate the Non-
Hazardous Discharge
from the MS4
Input Task/Work Order
in MS4 Database & Issue
Notification to
Responsible Party(s)
Non-Illicit Discharge
Determination
Non-Illicit Discharges
are Documented but no
further Staff Time
Allocated
Input Task/Work Order
in MS4 Database & Issue
Notification to
Responsible Party(s)

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COB IDDE FTI (Field Testing Investigations)
The City of Burlington stormwater division staff performs the field testing investigations by
traveling from site to site along a stretch of stream where potential pollution problems have
been reported or identified. At each investigation site, physical site data and descriptions as
well as physiochemical data is collected and recorded on a City of Burlington IDDE Investigation
form (Appendix A). The initial physiochemical data collected is as follows:

Physiochemical Findings (use handheld probes)
Area of Concern Normal Range
Device: Hach, YSI
Temperature:
Within 2.8 C of
ambient ☐ Ok ☐ Not within acceptable range
pH: 7.0-8.6 (6-9 Standard) ☐ Ok ☐ Not within acceptable range
DO: > 5 mg/L ☐ Ok ☐ Not within acceptable range
Conductivity <300 µs/cm ☐ Ok ☐ Not within acceptable range
Turbidity <25 NTU (50 Standard) ☐ Ok ☐ Not within acceptable range

Using the data collected and comparing it to the “Normal Range”, a determination can be made
as to the next steps in the investigation.
Tracing Illicit Discharges
City personnel can utilize a variety of techniques or technology to trace an illicit discharge to the source.
No one technique is preferred nor does the City restrict the resourcefulness of staff to find the source of
the discharge. Staff will begin to record the methods utilized in the worksheet TII/CII field data
worksheet so the division can track the most efficient method. Some examples could include things
such as: dye testing, video surveillance/camera truck, delineation of drainage area, GIS/GPS survey of
existing storm drainage system. No specific process is deemed mandatory as any and all methods can
be utilized to remove the illicit discharge from the MS4. Some examples of techniques and tools utilized:
• Field Observation - Visually identify a discharge due to discoloration, smells or odors, or
evidence of foreign material or sheen in the outfall. This can be expanded to include a detection
of these parameters in the open channel not directly attributed with an outfall.

• HACH and YSI Portable Meter- Staff has portable water quality monitoring equipment available
to deploy into the effluent stream and capture DO,SP,PH, Temperature, or Turbidity. Often a
large variation from one of these parameters can indicate the need to further investigate the
discharge. This equipment is often used in the initial investigation during a TII or CII event.

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• Grab Samples- In the event no distinct variation is identified with the use of the portable meters
staff should further investigate the discharge by collecting a grab sample. These samples should
be coordinated with either the City’s lab at Belmont Avenue [phone] or a qualified third
party testing lab. Currently the city utilizes Meritech, Inc. at [phone] who can also test
for additional parameters the City’s lab cannot.

• GIS- Geographic Information Systems used to map the City’s infrastructure can be a valuable
tool for staff to further identify the outfall location and further trace the source of a suspected
discharge. Presently the City’s storm drainage system and interconnected network of outfalls is
mapped as part of the City’s Stormwater Management Program. Often maps can be printed and
the use of GPS to log and track illicit discharges can be implemented.

• Citizen Interaction – Often a discharge has been seen by someone during periods of dry
weather. The City operates the CBC Hotline for citizens to report signs of an illicit discharge, but
there are occasions where people close to a discharge identified by the City can help determine
both how long the discharge has been occurring and where it might have originated.
Removing Illicit Discharges
The purpose of any municipal illicit discharge detection and elimination program is to remove any and
all unauthorized discharges from the MS4. This process usually begins with detection through a CII
activity or is reported as a result of a TII. Eliminating an illicit discharge can be accomplished through
various City approved methods as indicated below:
• Informal Directive- In some cases the source of the illicit discharge might be an unknowing
property owner or business. This can be some of the easiest to correct but may involve
extensive follow-up. A valve might be turned or a connection eliminated but in all cases the
source should be re-inspected periodically to verify elimination.

• Housekeeping Notification- There is the possibility an illicit discharge is a temporary or
infrequent occurrence. Spillage or the storage of a material close to a drain may result in a one-
time discharge. These Housekeeping type discharges will require both re-inspection and also
the use of the Education and Outreach MCM to prevent continued occurrence.

• Loss of City Services- Often an illicit discharge is enhanced by availability of water to a property.
A pollution source or unauthorized material is transported by the water provided to the
property through its water distribution system. Staff can terminate water service to the
property in an effort to have the property owner implement corrective actions.

• Notice of Violation- A typical type of action for most municipal code violations, Staff can choose
to issue a Notice of Violation (NOV) in which the property owner or business is given a period of
time to remedy the illicit discharge or connection and could face financial penalties depending
on the severity of the matter or length of time to comply.

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Notice of Violations
The City of Burlington has the authority under Section 1-102 to take all necessary steps to both
eliminate an illicit discharge and in some instances institute financial penalties to those who knowingly
violate the City of Burlington Stormwater Ordinance. Notice of Violations will need to follow a simple
step by step process to ensure that proper notification is established and assessment of penalties
remains viable to the division. These steps are detailed as such:
• Written Notice- All illicit discharge investigations, regardless if they are TII or CII, events will
need to be documented in the MS4 database. All incidents must include a written letter or
report that is sent to the primary land owner or the entity in control of said process contributing
to the discharge. In the notice there should be a clear indication of what measures are needed
to comply.

• Deadline for Compliance- The written notice detailed in the aforementioned topic must include
a clear indication of where on the property the source of the illicit discharge is and detail the
corrective actions expected to resolve the issue. In some cases the resolution may not be easily
discernible by municipal staff. In all cases the illicit discharge must be eliminated and Staff can
simply direct the controlling party to resolve the issue within a specified timeframe.

• Failure to Comply- All correspondence should be sent registered mail and clearly identify both
the ordinance and the stipulate penalties that could occur for failure to take corrective actions.
Procedures for resolving the NOV should include a written response and a request for re-
inspection by City Stormwater staff.

• Recommendation for Enforcement- In the event the illicit discharge cannot be eliminated due
to lack of action by the parties involved the Staff will submit the case to the Stormwater
Administrator for enforcement. Penalties for non-compliance will be determined or calculated
back to the date the discharge was first detected and will accrue until the issue is resolved.

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Appendix A
City of Burlington IDDE Investigation Form