NCS000426_Hickory IDDE Plan_20220722

CITY OF HICKORY
Illicit Discharge Detection and Elimination Plan
Standard Operating Procedures
Stormwater Management Division
June 25, 2022
ILI- -
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Page 1 1 ILLICIT DISCHARGE DETECTION AND ELIMINATION PLAN I CITY OF HICKORY

Illicit Discharge Detection, Elimination Program,
& Standard Operating Procedures
TABLE OF CONTENTS
INTRODUCTION & OVERVIEW
IDDEProgram Purpose.......................................................................... 3
IDDE Program Responsibility & Contact Information..................................3
Adaptive IDDE Program Management Strategy..........................................3
IDDE Program Components.................................................................... 4
IDDE Program Tracking Database............................................................4
IDDE Program Legal Authority.................................................................4
ILLICIT DISCHARGE DETECTION & RESPONSE
Identifying an Illicit Discharge(ID)............................................................8
Field Observations, Notifications, and/or Complaints.................................10
Spills....................................................................................................11
Spill Response Report Form...................................................................
12
Dry -Weather Screening of MS4 Outfalls....................................................13
StreamSampling...................................................................................
14
Documenting an Illicit Discharge.............................................................
15
MS4 Outfall Visual Field Inspection Worksheet..........................................16
ILLICIT DISCHARGE EDUCATION & SITE INSPECTION PROGRAMS
IDDE Program Training for City Employees ..............................................
18
IDDE Public Education for City Residents.................................................18
Used Oil & Household Hazardous Waste Program .....................................
18
Coordination with County Health Department for On -Site Wastewater Treatment
Program...............................................................................................
18
IDDE Education & Inspection Program for Potential Pollutant Generators....
19
SUMMARY PLAN STEPS FOR IDDE PROGRAM IMPLEMENTATION.............20
Page 12 ILLICIT DISCHARGE DETECTION AND ELIMINATION PLAN I CITY OF HICKORY

IDDE Program Purpose
The purpose of the Illicit Discharge Detection & Elimination (IDDE) Program is to identify, detect, and eliminate any
and all non-stormwater discharges from the City of Hickory Municipal Separate Storm Sewer System (MS4). In
addition to the involvement of each City staff member, it is recognized that public education and public involvement
in pollution identification, detection, and prevention are key elements of a successful IDDE program for the City of
Hickory.
The IDDE program is required in the City of Hickory's National Pollutant Discharge Elimination System (NPDES)
Phase II stormwater discharge permit issued by the State of North Carolina Division of Water Quality (NCDWQ).
The City Stormwater Administrator will lead implementation of the IDDE program to help ensure that any identified
illicit discharges and improper disposals are addressed in a timely and effective manner to reduce potential impacts
on surface water quality.
Importantly, the IDDE program helps protect public and environmental health through elimination of illicit discharges
to local receiving streams, some of which drain into sources of public drinking water supply.
IDDE Program Responsibility & Contact Information
Calls to City Hall or the City's Public Works regarding potential illicit discharges, water pollution, and/or water quality
problems are to be directed to the City Stormwater Administrator. The City Stormwater Administrator has the lead
responsibility for Hickory's IDDE Program development, administration, and implementation. Contact information
is as follows:
Jason White, Stormwater Engineer, Tel [phone]
[e-mail]
City of Hickory
76 N Center ST
Hickory, North Carolina 28601
Adaptive IDDE Program Management Strategy
The City of Hickory recognizes that its IDDE Program may be revised and adapted over time based upon actual
findings, determinations, and lessons learned during the first and subsequent NPDES Phase II permit cycles.
Therefore, the IDDE Program and Standard Operating Procedure (SOP) Document herein may be revised as
necessary based upon findings and needs. Any revisions to the IDDE Program will be reported and justified to the
NC DWQ during annual reports and subsequent permit renewal applications.
Page 13 ILLICIT DISCHARGE DETECTION AND ELIMINATION PLAN I CITY OF HICKORY

The IDDE Program goal is to find and remove non-stormwater discharges to the (MS4)
and receiving streams. Requirements for the IDDE Program include:
• Develop an inventory and map of Hickory's storm sewer outfalls
• Develop local ordinance and legal authority to prohibit illicit discharges
• Develop a plan and process to detect and eliminate pollution
• Train and involve City of Hickory staff, and
• Educate and involve citizens with public outreach and enforcement of ordinances.
IDDE Program Components
The Hickory IDDE Program includes the following components:
1) Local ordinance prohibiting illicit discharges to the storm sewer and receiving surface waters within the
jurisdiction of Hickory
2) An inventory and map of Hickory's MS4 outfalls and receiving surface waters
3) A plan and process to identify, detect, and eliminate illicit discharges
4) Integrated spill response procedures
5) IDDE training for City administrators and staff
6) Public education, public outreach, and public involvement to enhance IDDE program effectiveness
IDDE Program Tracking Database
The City of Hickory will develop and maintain an IDDE Program Database to log, track, and resolve illicit discharges
and illicit connections. The IDDE database will also document the results of dry weather outfall screening activities,
spills and follow-up activities, findings from on-site/facility inspections, enforcement actions, City employee IDDE
training programs, and IDDE public education and public involvement activities.
Hardcopy and electronic files will be developed and maintained by the City as appropriate.
IDDE Program Legal Authority
The City of Hickory has adopted adequate legal authority to implement and enforce the IDDE Program through our
Phase II Stormwater Ordinance.
ILLICIT DISCHARGES AND CONNECTIONS
(A) Illicit Discharges
No person shall cause or allow the discharge, emission, disposal, pouring, or pumping directly or indirectly to any
stormwater conveyance, the waters of the State, or upon the land in manner and amount that the substance is likely
to reach a stormwater conveyance or the waters of the State, any liquid, solid, gas, or other substance, other than
stormwater; provided that non-stormwater discharges associated with the following activities are allowed and
provided that they do not significantly impact water quality:
Page 14 ILLICIT DISCHARGE DETECTION AND ELIMINATION PLAN I CITY OF HICKORY

(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) Foundation drains;
(8) Air conditioning condensation;
(9) Irrigation water;
(10) Springs;
(11) Water from crawl space pumps;
(12) Footing drains;
(13) Lawn watering;
(14) Individual residential car washing;
(15) Flows from riparian habitats and wetlands;
(16) Dechlorinated swimming pool discharges;
(17) Street wash water; and
(18) 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 Hickory.
Prohibited substances include but are not limited to: fuel, oil, anti -freeze, chemicals, animal waste, paints, garbage,
and litter.
(B) Illicit Connections
(1) Connections to a stormwater conveyance or stormwater conveyance system that allow the discharge of non-
stormwater, other than the exclusions described in subsection (A) 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.
(2) Where such connections exist in violation of this section and said connections were made prior to the
adoption of this provision or any other ordinance prohibiting such connections, the property owner or the person
using said connection shall remove the connection within one year following the effective date of this ordinance.
However, the one-year grace period shall not apply to connections which may result in the discharge of hazardous
materials or other discharges which pose an immediate threat to health and safety, or are likely to result in
immediate injury and harm to real or personal property, natural resources, wildlife, or habitat.
(3) Where it is determined that said connection:
A. May result in the discharge of hazardous materials or may pose an immediate threat to health and safety, or
is likely to result in immediate injury and harm to real or personal property, natural resources, wildlife, or habitat, or
Page 15 ILLICIT DISCHARGE DETECTION AND ELIMINATION PLAN I CITY OF HICKORY

B. Was made in violation of any applicable regulation or ordinance, other than this section;
The City of Hickory Stormwater Administrator shall designate the time within which the connection shall be removed.
In setting the time limit for compliance, the City Stormwater Administrator shall take into consideration:
1. The quantity and complexity of the work,
2. The consequences of delay,
3. The potential harm to the environment, to the public health, and to public and private property, and
4. The cost of remedying the damage.
(C) Spills
Spills or leaks of polluting substances released, discharged to, or having the potential to be released or discharged
to the stormwater conveyance system, shall be contained, controlled, collected, and properly disposed. All affected
areas shall be restored to their preexisting condition.
Persons in control of the polluting substances immediately prior to their release or discharge, and persons owning
property on which the substances were released or discharged, shall immediately notify the City of Hickory Fire
Department of the release or discharge, as well as making any required notifications under state and federal law.
Notification shall not relieve any person of any expenses related to the restoration, loss, damage, or any other
liability which may be incurred as a result of said spill or leak, nor shall such notification relieve any person from
other liability which may be imposed by State or other law.
(D) Nuisance
Illicit discharges and illicit connections which exist within the City of Hickory are hereby found, deemed, and
declared to be dangerous or prejudiced to the public health or public safety and are found, deemed, and declared to
be public nuisances. Such public nuisances shall be abated in accordance with the procedures set forth in section
(Chapter 20, City Code of Ordinances).
(E) Right -Of -Entry
(1) The City Stormwater Administrator or designee shall have right -of -entry on or upon the property of any person
subject to this ordinance and any permit/document issued hereunder. The City Stormwater Administrator or
designee shall be provided ready access to all parts of the premises for the purposes of inspection, monitoring,
sampling, inventory, records examination and copying, and the performance of any other duties necessary to
determine compliance with this ordinance.
(2) There a person has security measures in force which require proper identification and clearance before entry
into its premises, the person shall make necessary arrangements with its security guards so that, upon presentation
of suitable identification, the City Stormwater Administrator or designee will be permitted to enter without delay for
the purposes of performing specific responsibilities.
(3) The City Stormwater Administrator or designee shall have the right to set up on the person's property such
devices as are necessary to conduct sampling and/or metering of the person's operations.
(4) Any temporary or permanent obstruction to safe and easy access to the areas to be inspected and/or
monitored shall be removed promptly by the person at the written or verbal request of the City Stormwater
Administrator or designee. The costs of clearing such access shall be borne by the person.
(5) The City Stormwater Administrator or designee may inspect the facilities of any user in order to ensure
compliance with the ordinance. Such inspection shall be made with the consent of the owner, manager, or signatory
official. If such consent is refused the City Stormwater Administrator or designee may seek issuance of an
administrative search warrant.
Page 16 ILLICIT DISCHARGE DETECTION AND ELIMINATION PLAN I CITY OF HICKORY

(F) Enforcement
(1) Any person who is found responsible for an illicit connection shall receive a notice of violation when the
connection is discovered. If the connection has not been removed in accordance with the timeframe established in
Section B of this ordinance, the City Stormwater Administrator or designee may enter the property and take
measures necessary to remove the connection and perform whatever clean-up or abatement is necessary. If the
person fails to remove the connection in the time prescribed, the City may petition the Superior Court of Justice, for
the issuance of an injunction to compel removal and payment; however, removal of the illicit connection shall be
immediate upon the determination of the City Stormwater Administrator that the connection poses an imminent
threat to public health.
(2) If any person who previously has been found to have an illicit connection reconnects to the municipal separate
storm sewer, he shall be assessed a civil penalty not to exceed $5,000. The penalty shall increase by twenty-five
percent (25%) of the previous penalty amount for every subsequent illicit connection made by the same person. The
penalty shall be additional to the cost of cleanup and abatement. If the person has or is required to have a
stormwater discharge permit from the State of North Carolina, the City Stormwater Administrator shall alert the
appropriate state authorities of the violation. In determining the amount of the penalty the City Stormwater
Administrator or designee shall consider the following:
(A) The degree and extent of the harm to natural resources, to the public health, or to public or private property
resulting from the violation;
(B) The duration and gravity of the violation;
(C) The effect on ground or surface water quality;
(D) The cost of rectifying the damage;
(E) The amount of money saved by noncompliance;
(F) Whether the violation was committed willfully or intentionally;
(G) The prior record of the violator in complying or failing to comply with the City stormwater management
program, and;
(H) The costs of enforcement to the City of Hickory.
Page 17 ILLICIT DISCHARGE DETECTION AND ELIMINATION PLAN I CITY OF HICKORY

Identifying an Illicit Discharge (ID)
The determination of an Illicit Discharge (ID) is made by the City Stormwater Administrator or designee based upon
the routine, intentional, non -intentional, or habitual nature of the person or practice creating the incident or other
determinations as needed. In general, an ID is any non-stormwater discharge with the following exceptions:
(1) Water line flushing;
(2) Landscape irrigation;
(3) Diverted stream flows;
(4) Rising ground waters;
(5) Uncontaminated ground water infiltration;
(6) Uncontaminated pumped ground water;
(7) Foundation drains;
(8) Air conditioning condensation;
(9) Irrigation water;
(10) Springs;
(11) Water from crawl space pumps;
(12) Footing drains;
(13) Lawn watering;
(14) Individual residential car washing;
(15) Flows from riparian habitats and wetlands;
(16) Dechlorinated swimming pool discharges;
(17) Street wash water; and
(18) 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 Hickory.
Typical IDs include but are not limited to:
• Oil and grease
• Gasoline
• Anti -freeze
• Chemicals
• Paints
• Solvents
• Animal waste
• Cooking oils
• Dumping of grass/lawn clippings and/or leaf litter
Page 18 ILLICIT DISCHARGE DETECTION AND ELIMINATION PLAN I CITY OF HICKORY

• Laundry wash water
• Sanitary sewer direct discharges to storm sewers and streams
• Sanitary sewer system leakages and overflows
• Leaking septic fields
• Residual waste from concrete mixing
• Floor and shop drains connected to the storm sewer system
• Leaking solid waste dumpsters
• Commercial pressure washing
• Chlorinated swimming pool discharges
• Garbage, and
• Litter
An ID may generally be discovered in one of the following ways:
• Field observations, notifications, and/or complaints (from citizens or staff)
• Dry weather screening at MS4 outfalls
• Spills
• Sampling
• On-site/facility inspections
• Special studies (such as stormwater system field inventory and mapping)
Page 19 ILLICIT DISCHARGE DETECTION AND ELIMINATION PLAN I CITY OF HICKORY

Field Observations. Notifications. and/or Comalaints
The City Stormwater Administrator and/or Staff may notice potential problems as they conduct routine site
inspections, perform maintenance work or repairs, or perform other field -based activities. Information may also
come as a complaint from residents, businesses, or other concerned parties. The City Stormwater Administrator or
designee will determine the nature of the complaint and conduct a full investigation. (Note: If the complaint call is
regarding a spill, then the steps for handling a spill in the following section need to be followed.)
Incidences can range widely in nature, but generally the investigation entails determining the nature of the complaint
and whether there is a discharge to the receiving stream and/or impact to water quality. If a discharge or noted
impact is deemed legitimate, the responsible individual or party is tracked down, the discharge or problem resolved,
and the responsible party educated on the nature of the violation. The original caller is also informed of what actions
took place to remedy the situation.
Investigation of suspicious discharges will be made by visual inspection and/or testing of discharges within the storm
drainage system upstream of the suspicious discharge. Other options that may be considered in locating illicit
discharges or illicit connections include televising the storm sewer or dye testing facilities in the area where there is
a discharge. Letters may also be sent to residents and businesses alerting them to the problem that is under
investigation to solicit their assistance in finding the source.
In general, the following steps should be followed:
1. The City Stormwater Administrator or designee assigned to the incident may print a drainage system inventory
map of the area(s) surrounding the ID (or potential ID). City personnel or other involved parties may also have
other information pertinent to the case. From the information gathered, in particular the stormwater system
mapping, the probable path of the ID will be determined and the field investigation will promptly follow.
2. In the field, the City Stormwater Administrator or designee will initially track the ID through the stormwater
conveyance system via visual inspection and investigation.
• Note: The potential ID may or may not have reached a City MS4 outfall.
3. If the source of the problem is not readily identified through a visual inspection, the City may conduct and/or
organize other tracking methods, such as dye testing, smoke testing, system televising procedures, etc.
4. When the source is determined, the responsible person or party will be identified, if possible.
5. The Stormwater Administrator will interview involved parties, document and photograph any pertinent findings,
and ensure that the responsible party (if one can be identified) is educated so that the ID incident is not
repeated.
6. The responsible party must take appropriate corrective action for ID clean-up. Correction action could be
cleaning it up directly or contracting with an environmental cleaning service to clean up the impacted area.
7. If enforcement is necessary, the enforcement guidance and criteria in the IDDE ordinance should be followed.
Page 1 10 ILLICIT DISCHARGE DETECTION AND ELIMINATION PLAN I CITY OF HICKORY

Spills
Important Note — the City Stormwater Administrator or designee role in emergency spills is limited to that of
a secondary responder. Primary responders will be the City of Hickory Fire Department, HAZMAT Team,
County Emergency Management, and/or the County Health Department.
In no case shall the City Stormwater Administrator participate in emergency and/or hazardous response
activities or functions that are beyond the scope, training, certification, and/or responsibility of the City
Stormwater Administrator.
When an emergency response group such as the City Fire Department at the scene of a spill alerts the City
Stormwater Administrator or designee of an incident, the Stormwater Administrator will appropriately assist the Fire
Chief, HAZMAT team member, County Health Employee, and/or other person working on the incident.
Where required, the key role of the Stormwater Administrator in case of a spill, is to help advise the primary
responders (Fire, HAZMAT, other) regarding connectivity of the local storm sewer system and stream network.
Additionally, the City Stormwater Administrator will follow up with clean-up companies, the responding fire chief, and
others to see that effects of the spill were adequately mitigated and that any issues have been resolved.
The City Stormwater Administrator may also act as a liaison between different parties, if necessary, to ensure full
cooperation with all involved groups.
Procedures for spills are generally as follows:
1. When a significant spill occurs within City limits, the appropriate emergency responder will be the primary
responder for the incident. The Catawba County Health Department will also be contacted as appropriate.
2. The limited role of the City Stormwater Administrator as a secondary responder will be to assist the primary
responder(s) with any needed information or support (such as stormwater conveyance or stream system
maps, land use information, etc.) and to follow up with any groups involved to ensure that the discharge is
eliminated and clean-up is completed. The Stormwater Administrator will also document the case for City
NPDES Phase II stormwater program files/records.
• A spill response report form is provided on the following page.
3. To the extent practicable and where safe to do so, the City Stormwater Administrator or designee will
conduct a field investigation of the spill at the scene and interview involved parties such as primary
responders, business owners, property owners, and local residents. The spill will be photo- documented and
pertinent information will be recorded.
• At a minimum, appropriate summary information will be obtained from the primary responder(s).
4. After the spill incident, the City Stormwater Administrator will take steps to educate responsible parties and
will issue any necessary Notice of Violation (NOV) letters in accordance with the City stormwater policy and
ordinances. It may be necessary to perform research on the involved party (or parties) to ascertain whether
there have been previous NOVs or issues in the past, as this may determine the level of action taken against
the noncompliant party.
• If enforcement is necessary, the procedures in the ordinance should be followed.
5. Additional inspections may be needed to ensure that the responsible party has taken the appropriate steps
to clean up the spill. In addition, it may be necessary to have the facility or party implement changes to its
operating procedures in order to prevent future incidences.
Page 1 11 ILLICIT DISCHARGE DETECTION AND ELIMINATION PLAN I CITY OF HICKORY

HICKORY
�fe. wo Cry SPILL RESPONSE REPORT FORM
Location of incident:
Did spill reach the MS4
and/or receiving
stream?
YES
NO _
If YES, which stream/watershed?
Date of incident:
City Stormwater
Investigator:
Time of incident:
Weather at time of
incident:
Who reported spill?
Time spill reported?
Description of spill/incident:
Follow up actions:
1. Containment -
2. Source Identification -
3. Spilled Substance -
4. Reporting / Notes -
Non -Emergency Responder City Staff present:
Primary Responding Agency or
Agencies Involved
Agency Representative
Contact Info
City Fire Department
HAZMAT Team
County Environmental Health
Emergency Management
_ State Division of Water Quality
Other Agencies:
Page 1 12 ILLICIT DISCHARGE DETECTION AND ELIMINATION PLAN I CITY OF HICKORY

Drv-Weather Screenina of MS4 Outfalls
The purpose of the dry -weather screening program is to identify, track, and eliminate potential IDs from the MS4.
Dry -weather screening focuses on each MS4 outfall within the City of Hickory jurisdiction. If there is a flow present
from a MS4 outfall during dry -weather conditions then the flow is either an appropriate non-stormwater discharge
such as uncontaminated groundwater seepage into the storm sewer system OR a potential illicit discharge. The dry -
weather screening/sampling program will seek to document and classify the nature of discharges from MS4 outfalls
during non -storm event periods. Identification and elimination of any continuous, intermittent, or transitory sewage or
septic system discharges are the highest priority for the program.
Frequency of MS4 Outfall Screenings: The City will seek to perform at least one dry- weather screening on each
MS4 outfall during its initial five-year Phase II permit period. Following the initial screening of each MS4 outfall,
outfalls will be prioritized for subsequent screenings in future permit cycles based on contributory land uses, status
of impaired water bodies, actual findings during the initial screening, and complaints/incidents during the permit
period.
Basic steps in the dry -weather screening of MS4 outfalls will include:
1. Develop an inventory map of MS4 outfalls and streams within Hickory
2. The dry -weather screening process can begin as part of the field inventory for developing the MS4 outfall
mapping
3. Perform a dry -weather condition field inspection of each MS4 outfall
• The best time for dry -weather surveys is generally during leaf -off seasons, but do not limit program
implementation based on season. Always perform dry -weather screenings no earlier than 48 hours following
a rainfall event. Always maintain basic safety and first aid equipment during field inspections. Where
possible, a two -person crew should perform the outfall assessment and screening. Always maintain proper
identification as a City employee or authorized stormwater services contractor.
4. Utilize the Outfall Visual Field Inspection Worksheet to document findings
5. At each MS4 outfall where dry -weather flow is present:
a. Take physical sampling measurements at the outfall
• Typical physical sampling parameters will include temperature, pH, dissolved oxygen, color/turbidity, and
conductivity.
• Physical sampling results may provide an indicator of a potential ID
b. If available and where appropriate, utilize a commercial test kit to check for other potential indicator
parameters
c. Where illicit discharges are suspected and/or seem likely based on physical and/or test kit monitoring
and/or sensory indicators, obtain water sample(s) to be further analyzed at a certified analytical laboratory. If
oil and grease (O&G) or other petroleum -based products are suspected in the dry -weather flow, then obtain
an appropriate separate grab sample for O&G lab analysis
d. Properly label the sample(s) according to the MS4 outfall ID# and/or location
6. Once sampling results are available from physical indicator sampling and/or the lab, a determination of the
potential for an ID from the contributing outfall may be evaluated. Note: Seek to track, isolate, and eliminate
obvious major problems immediately, not waiting for lab results.
7. If an ID is suspected and/or validated from outfall sampling results, track the source of the ID up the
contributory drainage system. Businesses, residential properties, and other upstream facilities may need to
be visited in order to track down and eliminate the ID, as the source may be intermittent or transitory.
8. Prioritize regular MS4 outfall inspection program by actual findings and analysis of contributory land uses
within watershed
Page 1 13 ILLICIT DISCHARGE DETECTION AND ELIMINATION PLAN I CITY OF HICKORY

a. Industrial and commercial land uses are highest priority
b. Institutional, public, and multi -family residential are second tier priority
c. Older single-family residential are third tier priority
d. Newer single-family residential are fourth tier priority
Stream Sampling
During local stream sampling/monitoring (when and where applicable) a site may exhibit action levels for one or
more sampled parameter(s). If a parameter reaches an action level, a follow-up investigation should be initiated. A
second sample may be taken to confirm an exceedance of an action limit. A pipe or ditch that continues to convey
discharge may indicate a possible ID source for the action level parameter(s).
The City Stormwater Administrator (or designated staff) may use the following steps to track down the ID source and
eliminate the water quality issue.
1. The applicable stormwater inventory map(s) may be printed and studied to determine the stormwater
conveyance network.
2. A field study will be conducted of the site, and staff will do an initial scan of the area looking for any outfalls.
Staff will locate all points of discharge into the receiving stream as far upstream of the sampling site as is
feasible or logical.
• It may also be beneficial to talk to local residents and property owners who may be familiar with any site -
specific issues.
3. In order to further pinpoint the area of concern, samples may be taken at each outfall and periodically in the
stream (working from downstream to upstream) to help narrow down the potential ID source. Water samples
will be collected for each parameter that met the action level during ambient monitoring. The sample(s) will
need to be labeled according to the MS4 outfall source. It will be helpful to sketch a map of the site/area of
interest with outfalls noted, or make appropriate notes on the storm system inventory map.
• If the parameter(s) falling into the action category for the site can be sampled using handheld physical
samplers, then collection of water samples may not be needed. The physical parameters can be noted,
saved, and analyzed in the field and/or office as appropriate. Typical physical sampling parameters will
include temperature, pH, dissolved oxygen, turbidity, and conductivity.
4. Once sampling results are available from the lab or physical sampling, a determination of the potential
contributing outfall(s) may be evaluated. In the event that a site exhibits action levels for one or more
parameters, but there are no outfalls to sample, a thorough investigation of the area needs to be conducted,
and additional sampling may be necessary within the stream channel.
5. Businesses and other facilities may also need to be visited in order to track down the action parameter
source, as the source may be intermittent or transitory.
Page 1 14 ILLICIT DISCHARGE DETECTION AND ELIMINATION PLAN I CITY OF HICKORY

Documenting an Illicit Discharge
Documenting ID investigations and resolutions, especially those resulting in the issuance of an NOV letter, is a
critical step in implementing the IDDE program for the City of Hickory. In addition, ID cases where responsible
parties are assessed fines must have proper documentation in order to decrease the risk of an unsupported claim.
IDs will be photo -documented, and pertinent information will be recorded in the NPDES IDDE Program Database or
other files. The ID Form (see standard form on next page) will be useful for recording data in the field. Any digital
photos will be put into an electronic folder for future reference. NOV letters or other correspondence pertaining to
the ID will be saved in hard copy form in a folder to be filed in the City Stormwater Office.
The City Stormwater Administrator (and staff) will make every effort to conscientiously document, record, and
maintain pertinent information related to IDDE program implementation and enforcement.
Page 1 15 ILLICIT DISCHARGE DETECTION AND ELIMINATION PLAN I CITY OF HICKORY

HICKORY
MS4 Outfall Visual Field Inspection Worksheet
Background
MS4 Permittee: City of Hickory, NC Date of Inspection: Time of Inspection:
Evaluator: Predominant Watershed Land use:
Outfall Location: (Latitude) (Longitude)/ (Address)
Date Outfall Last Inspected by Permittee: Days Since Last Rainfall: Inches:
Photos Taken? Yes No Photo #s:
Outfall Description
End of Pipe Diameter
(inches):
Open Channel? Yes No
Outfall Submerged:
Yes No
If Yes, in:
❑ Water
Pipe Material:
❑ Concrete
❑ Metal
❑ Plastic
❑ Other:
Pipe Condition:
❑ Good
❑ Fair
❑ Poor
Describe:
Shape:
❑ Circular
❑ Elliptical
❑ Box
❑ Other:
❑ Fully
❑ Partially
❑ Sediment
❑ Fully
❑ Partially
Visual Observations
Flow Present: Yes No
Flow Color:
Debris in Pipe
Flow Odor:
Flow Volume:
❑
Clear
❑
None
❑
None
❑
Muddy
❑
Sediment
❑
Petroleum
❑ Low
❑
Milky or cloudy
❑
Trash
❑
Sewage/rotten eggs
❑ Moderate
❑
Sheen
❑
Other:
❑
Other:
❑ Heavy
❑
Soapy foam
❑ Intermittent
❑
Other:
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Debris Around Outfall:
❑ None
❑ Sediment
❑ Trash
❑ Other:
Staining and Scum
Present:
❑ None
❑ Red/Orange
❑ White
❑ Green algae
Special Notes:
Summary Findings from Investigation:
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IDDE Program Training for City Employees
In addition to ongoing coordination with the Stormwater Administrator, the City has obtained and utilizes a video to
help train municipal employees to identify and eliminate illicit discharges. The video is shown to all new employees
during their job orientation and a refresher is given to full-time and part-time employees with field -based
responsibilities on a regular basis (at least once every two years).
IDDE Public Education for City Residents
The City will distribute brochures to households on stormwater pollution prevention that includes illicit discharge
issues. A storm drain marking program is also in place. The City will continue to integrate the illicit discharge
program into its overall stormwater public education and public involvement activities.
The City will partner with the Western Piedmont Council of Government (WPCOG) along with community volunteers
to regularly clean up sections of local streams as well as be on the lookout for potential IDDEs. The City recognizes
that the most successful IDDE program for Hickory must and will involve the education, awareness, and involvement
of each member of the community.
Used Oil & Household Hazardous Waste Program
Catawba County operates the Household Hazardous Waste (HHW) program. Residents and businesses will be
encouraged to utilize the HHW facility when applicable. The City of Hickory does collect motor oil and antifreeze
from a manned transfer station facility.
Coordination with County Health Department for
On -Site Wastewater Treatment Program
Catawba County Health Department has authority over on -site wastewater treatment systems within Catawba
County including the City of Hickory. The City will coordinate with the County Health Department to obtain a
database and to track the implementation and operation of on -site wastewater systems within Hickory. It is
recognized by the City that leaking or failing septic systems are an illicit discharge.
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IDDE Education & Inspection Program for Potential Pollutant Generators
The goal of this particular IDDE program is to identify and educate potential polluters before there is a problem,
thereby preventing illicit discharges, illicit connections and improper disposals to the stormwater conveyance and
stream system. More specifically, this group incorporates local commercial, industrial, public, and institutional
facilities. This education and inspection program is designed to raise awareness among the commercial and
industrial community about water quality concerns, non -point source pollution, and other stormwater issues.
This proactive site inspection program will be further developed and implemented as the baseline dry -weather
screening program commences.
The following steps will be taken for each group of potential pollutant generators:
1. Identify various potential pollutant generator facilities in Hickory.
2. Acquire business name, SIC codes for industry, NPDES permitted facilities, and related organizational
contact information.
3. Develop and organize information in IDDE Program database.
4. Produce or obtain industry -specific educational materials (i.e., from EPA website) and a corresponding
information letter. The information letter will refer to the City Stormwater ordinance and the upcoming field
inspection(s) to ensure the application of stormwater pollution prevention practices.
5. Mail correspondence letter and educational material, as applicable, to identified businesses.
6. Train staff (or contractors) for targeted education and inspection efforts.
7. Implement on -site inspection program.
8. Regularly evaluate program and alter as needed.
9. Produce annual report summarizing activities, highlighting successes, and lessons learned.
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Summary Plan Steps for IDDE Program Implementation
1. City develops a system and database to log, investigate, track, and resolve complaints (i.e., the IDDE Program
Manual and Program Database)
2.The legal basis for defining and eliminating illicit discharges will be reviewed and adopted by City Council through
means of an ordinance
3.The municipal separate storm sewer system (MS4) outfall map will be completed and updated by the City, as
appropriate
4.City employees will be trained to be observant for illicit discharges, and informed of proper inspection procedures
for surveying for illicit discharges, and about the program available to report their findings
5. City will continue to integrate IDDE messages into the stormwater public education and public involvement
program
6.City will coordinate with County Health regarding location of on -site wastewater treatment systems within Hickory
(i.e., obtain on -site wastewater treatment system database)
7. City will coordinate with City/County Utilities for data layers/database showing sanitary sewer lines, sewer
manholes, lift stations, etc. within Hickory
8.City will identify and contract with a local certified laboratory for water sample analysis, as required
9.City will purchase physical water sampling equipment and field water test kits, as required
10.City will perform the initial dry -weather screening for each MS4 outfall within Hickory. (Note: The initial visual
screening has begun as part of the MS4 outfall inventory project.)
11. A visual dry -weather screening of 100% of the outfalls within the jurisdiction of Hickory will be completed within
the first five-year permit period. Where an illicit discharge is suspected, samples will be collected and analyzed, as
appropriate
12. City will track and resolve any illicit discharges or connections identified
13. A list of any illicit discharges and connections and correction status will be prepared and maintained by the City
14. Outfalls in the City community will be prioritized for future regular visual screening based on contributory land
uses, location of sewer systems and on -site systems, complaints, initial dry -weather screening results, and impaired
water status
15.The on-site/facility inspection program for potential pollutant generators will be further developed and
implementation will begin
16.Completed and ongoing activities related to the IDDE program will be tracked and documented. Annual NPDES
Phase II program reports will include summary findings and resolutions from the IDDE plan
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