NCS000449_IDDE Program_20220718

Illicit Discharge
Detection and
Elimination Plan
DRAFT
Town of Cramerton
MS4 Permit Compliance
Cramerton. North Carolina
July 8, 2022
PST. 1115
CA

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Town of Cramerton I Illicit Discharge Detection and Elimination Plan ���
Introduction
Contents
1
2
3
0
Introduction......................................................................................................................... 1
1.1 Background and Purpose.............................................................................................
1
1.2 Illicit Discharges...........................................................................................................
1
1.3 Non-Stormwater Discharges........................................................................................
2
1.4 Receiving Waters and Impairments.............................................................................
3
StormwaterMap..................................................................................................................
3
2.1 What is an MS4 Outfall?..............................................................................................
3
Illicit Discharge Detection and Elimination Plan Overview ...................................................
4
3.1 Program Legal Authority..............................................................................................
4
IDDEProcess.....................................................................................................................
4
4.1 Community Education and Public Reporting................................................................
4
4.1.1 Dry Weather Screening.........................................................................................
4
4.1.2 Screening Schedule..............................................................................................
5
4.1.3 Hotspot Prioritization.............................................................................................
5
4.1.4 Timing...................................................................................................................5
4.1.5 Safety...................................................................................................................
5
4.2 Dry Weather Screening and Field Equipment Summary ..............................................
6
Section 1: Background Data................................................................................................
6
Section 2: Outfall Description..............................................................................................
6
Section 3: Discharge and indicators....................................................................................
7
Section 4: Overall Preliminary Illicit Discharge Rating.........................................................
8
Section 5: Other Non -Illicit Discharge Concerns..................................................................
8
4.3 Investigation Process...................................................................................................
8
4.3.1 Responsibility........................................................................................................8
4.3.2 Time Frame for Investigation................................................................................
9
4.3.3 Primary Investigation Methodology.......................................................................
9
4.3.4 Alternative Investigation Methodology..................................................................10
4.3.5 Indeterminate Investigations................................................................................10
4.3.6 Documentation.....................................................................................................11
4.4 Illicit Discharge Elimination Process and Enforcement Action.....................................11

Town of Cramerton I Illicit Discharge Detection and Elimination Plan ���
Introduction
4.4.1 Responsibility.......................................................................................................11
4.4.2 Structural Issues..................................................................................................11
4.4.3 Operational Deficiencies......................................................................................11
4.4.4 Follow-up Investigations......................................................................................12
4.4.5 Enforcement Actions and Documentation............................................................12
4.5 Employee Training......................................................................................................13
4.6 Program Evaluation and IDDE Manual Updates.........................................................13
Tables
Table 1 Dry -weather discharge sampling parameters...............................................................10
Appendices
Appendix A - Stormwater Outfall Inspection Forms
Appendix B - Stormwater Outfall Inspection Forms
Appendix C - Legal Authority (IDDE Bylaw)
Appendix D - IDDE Employee Training Record

Town of Cramerton I Illicit Discharge Detection and Elimination Plan ���
Introduction
1 Introduction
1.1 Background and Purpose
The Town of Cramerton has developed this Illicit Discharge Detection and Elimination (IDDE)
Manual as part of compliance with the United States Environmental Protection Agency's (EPA's)
Phase II National Pollutant Discharge Elimination System (NPDES) program for Municipal
Separate Storm Sewer Systems (MS4) in North Carolina. The EPA has delegated
administration of the NPDES program in the state of North Carolina to the North Carolina
Department of Environmental Quality (NCDEQ). The Town of Cramerton under Individual
Permit No. NCS000449 discharges stormwater runoff from their MS4. The NPDES program
requires regulated operators of MS4s to obtain a permit to discharge stormwater runoff from
their MS4 and establishes conditions they must meet to reduce the impacts of stormwater
discharges. One of these conditions requires regulated communities to develop an IDDE
Program to investigate and eliminate illicit discharges to the MS4. This manual describes the
Town of Cramerton's IDDE minimum control measure. which is detailed in the Town's
Stormwater Management Plan (SWMP). This manual outlines the procedures to detect and
eliminate illicit discharges to the Town's MS4 and waterways to improve water quality and meet
the Federal Phase II stormwater requirements.
1.2 Illicit Discharges
The term "illicit discharge" is defined in EPA's Phase II storm water regulations as "any
discharge to a municipal separate storm sewer that is not composed entirely of storm water,
except discharges pursuant to an NPDES permit and discharges resulting from fire -fighting
activities." An illicit discharge is any unauthorized flow of non-stormwater pollutants into the MS4
system via overland flow, direct connection, infiltration, or direct dumping. Illicit discharges can
be the result of aging infrastructure, industrial, commercial and/or residential practices, or a
specific spill event.
Illicit discharges may be categorized as direct or indirect
(a) Examples of direct illicit discharges:
• sanitary wastewater piping that is directly connected from a home to the storm
sewer
• materials (e.g., used motor oil) that have been dumped illegally into a storm drain
catch basin
• a shop floor drain that is connected to the storm sewer
• a cross -connection between the municipal sewer and storm sewer systems
• roof drains, property perimeter drains, sump pumps, connected to the storm
sewer
• private pipes discharging chlorinated water from pools to MS4 system
(b) Examples of indirect illicit discharges:
an old and damaged sanitary sewer line that is leaking fluids into a cracked storm
sewer line
a failing septic system that is leaking into a cracked storm sewer line or causing
surface discharge into the storm sewer

Town of Cramerton i Illicit Discharge Detection and Elimination Plan ���
Introduction
• overland flow discharging contaminated water into the MS4 system
The frequency of illicit discharges typically falls within the following three classifications, as
defined by EPA (CWP, 2004):
• Continuous: Discharges occur most or all of the time, are usually easier to detect, and
typically produce the greatest pollutant load
• Intermittent: Discharges occur over a shorter period of time (e.g., a few hours per day,
a few times per year). Because they are infrequent, intermittent discharges are hard to
detect, but can still represent a serious water quality problem, depending on their flow
type
• Transitory: Discharges occur rarely, usually in response to a singular event such as an
industrial spill, ruptured tank, sewer break, transport accident, or illegal dumping
episode. These discharges are hard to detect with routine monitoring, but can exert
severe water quality problems on downstream receiving waters
Understanding the frequency of an illicit discharge can help in detecting and eliminating illicit
discharges by allowing inspectors to guide the scope of the investigation and identify the
source.
1.3 Non-Stormwater Discharges
Non-stormwater discharges into the MS4 are generally not authorized and are considered illicit
unless the EPA or NCDEQ have identified the category or individual discharge as an
insignificant contributor to pollutants in the MS4. Discharges considered to be significant
sources of pollutants as well as any other non-stormwater discharges into the MS4 such as
sanitary connections to storm sewers, illegal dumping, and spills that enter the sewer are
considered illicit. According to EPA's Phase II storm water regulations, an IDDE program need
only address the following categories of non -storm water discharges if the operator of a small
MS4 identifies them as significant contributors of pollutants to the MS4:
• water line flushing
• landscape irrigation
• diverted stream flows
• rising ground waters
• uncontaminated ground water
infiltration
• uncontaminated pumped ground
water
• discharges from potable water
sources
• foundation drains
• air conditioning condensation
• irrigation water
• springs
• water from crawl space pumps
• footing drains
• lawn watering
• individual residential car washing
• flows from riparian habitats and
wetlands
• dechlorinated swimming pool
discharges
• street wash water
• flows from firefighting activities

Town of Cramerton I Illicit Discharge Detection and Elimination Plan ���
Stormwater Map
1.4 Receiving Waters and Impairments
The NPDES Permit includes additional requirements for MS4 discharges to any impaired
waterway with approved Total Maximum Daily Load (TMDL). The Town shall generally tailor its
BMPs to enhance water quality recovery strategies and reduce pollutants of concern that have
the potential to be discharged from the Town's MS4s. As part of the IDDE program, the Town
provides particular attention to the pollutants of concern for approved TMDLs. The procedures
in this Manual account for distinctions in illicit discharges that may be contributing pollutants of
concern to these impairments. The impaired waterbodies and approved TMDLs for the
permitting area can be found in the Town of Cramerton's SWMP.
2 Stormwater Map
A major component of the Town of Cramerton's IDDE program is the stormwater map.
Maintaining an accurate map of the stormwater system allows the Town to be able to effectively
trace and locate the source of suspected illicit discharges. The Town of Cramerton's storm
sewer system maps are maintained by the Town in a Geographical Information System (GIS)
format. The Town utilized the online mapping GIS system, as the primary platform for mapping
and maintaining records of the stormwater system. The Town has updated the maps with storm
inventory data collected from field survey both in 2008 and 2020. The Town has mapped the
stormwater infrastructure, including storm drain structures and storm drainpipes.
When new development is built, the Town receives the as -built information in a format such that
the information can be uploaded into the GIS. The Town will update the map continuously as
new development or storm drain systems are built or identified. The Town will also annually
maintain and update the stormwater map, ensuring all new developments, existing storm
systems, flow directions and MS4 outfalls are current. The Town staff can utilize information
such as flow direction, pipe slope, inverts and locations to track illicit discharges and citizen
reports. When outfall screenings are performed, they can be tracked using the GIS maps.
The Town currently utilizes consultants to collect and update the information from existing
development and infrastructure. The Town's online stormwater map shows the storm drainage
system, identified outfalls and receiving streams. The mapping is continuously updated as new
outfalls are identified in order to improve the accuracy of the stormwater map. Updated storm
sewer system maps, including the addition of new or reclassified (e.g., industrial to non-
industrial) outfalls can be found on the Town's GIS website
(https://cramerton.maps.arcqis.com/apps/mapviewer/index.htmI?webmap=12b4e7ec960f4a449
4cfefed68aada59).
2.1 What is an MS4 Outfall?
An MS4 outfall is any point where a separate storm sewer system owner or operated by the
Town of Cramerton discharges either to a surface water of North Carolina or to another MS4.
Outfalls include discharges from pipes, ditches, swales, and other points of concentrated flow.

Town of Cramerton I Illicit Discharge Detection and Elimination Plan ���
Illicit Discharge Detection and Elimination Plan
3 Illicit Discharge Detection and Elimination Plan
Overview
3.1 Program Legal Authority
The legal authority for prohibiting and mitigating illicit discharges and connections within the
Town of Cramerton lies with the Gaston County Stormwater Ordinance, which is adopted by the
Town via resolution. Gaston County maintains the ordinance that is compliant with NPDES MS4
Stormwater program requirements. While the IDDE ordinance lies with Gaston County and is
adopted by the Town, it is the responsibility of the Town to ensure permit compliance is being
met and the Planning Director has been designated as the permit responsible staff member for
the IDDE program. Article II Section 19 of the Gaston County Stormwater Ordinance establishes
the legal authority adopted by the Town to establish an illicit discharge program, such that "no
person shall cause or allow the discharge, emission, disposal, pouring or pumping directly or
indirectly to any storm water conveyance, waters of the state, or upon the land in a manner and
amount that the substance is likely to reach a storm water conveyance or the waters of the
state, any liquid, solid, gas or other substance, other than stormwater".
4 IDDE Process
4.1 Community Education and Public Reporting
The Town maintains an array of avenues through its public education program to educate the
public on the hazards associated with stormwater pollution, illicit discharges, illegal dumping,
and improper disposal of waste, appropriate practices to prevent stormwater pollution, penalties
for violation, contact information for reporting potential illicit discharge. The Town will maintain
this program which satisfies the education requirements for the IDDE program. The Town also
maintains a website with a dedicated stormwater page for public education on general
stormwater awareness illicit discharges and pollution prevention. The Town also maintains a
dedicated stormwater hotline where citizens can report discharges in the community.
When a potential illicit discharge incident is reported, the incident information will be referred to
the Planning Director for documentation using the Illicit Discharge Tracking Record database
and follow-up procedures will be initiated. The responding staff will either follow the investigation
procedures in Section 4 of this manual to identify the source of the problem or, if the source is
known, the discharge elimination procedures outlined in Section 4.4 will apply. The Town
through is public education and public involvement programs, encourages citizens to identify
and report discharges and/or illegal dumping activities. In addition, the Town will distribute
information about the IDDE program through mass emails, educational materials, social media,
and the Town's website.
4.1.1 Dry Weather Screening
Dry -weather field screening of stormwater outfalls is an effective method of detecting illicit
discharges to the stormwater system. The Town of Cramerton maintains a dataset of its MS4

0 Town of Cramerton I Illicit Discharge Detection and Elimination Plan ���
IDDE Process
outfalls that discharge to receiving water bodies including the South Fork Catawba River, and
Duharts Creek. This list is subject to updates as new development and redevelopment occur.
The MS4 Permit requires routine inspections of the Town's outfalls during dry weather to detect
potential illicit discharges to the stormwater system. The mapped outfall and receiving water
bodies are shown in the Town's online stormwater map. The Map is available in a GIS online
interface which is used to track the dry weather screening efforts.
4.1.2 Screening Schedule
The Town will utilize a quintant system, that divides the Town limits into five different quintants.
The Town will inspect all outfalls in a single different quintant annually (20 percent of outfalls),
keeping track of the inspected outfalls in the GIS map database. This will allow the Town to at
least screen all outfall once within the permit cycle as required by the permit.
4.1.3 Hotspot Prioritization
The Town will also identify hotspots areas based on land use, historical data regarding previous
suspected illicit discharges, age of infrastructure, and proximity to sensitive or impaired water
bodies. These areas will be annually updated as the illicit discharge and detection program
identifies illicit discharges and chronic violators. The Town will prioritize outfall inspections in
quintants with identified hotspot areas and chronic violators. The Town will also conduct as
needed and non -routine outfall inspections for chronic violators.
4.1.4 Timing
Timing is important when conducting dry -weather outfall screenings to detect dry -weather flows
during time periods when potential pollutants are not obscured or diluted by stormwater. The
following guidelines should be considered when scheduling screenings:
• Conduct screenings at least 48 hours after a runoff producing rain event
• Submerged lakeside outfalls should be screened during normal or low flow conditions.
These outfalls might require the use of a boat. The Town will prioritize these outfalls in
the fall season between September to November.
• Remote outfalls may be more accessible during times of low vegetation (late fall to early
spring)
• Conduct screening during times of low groundwater levels (e.g., avoid time periods when
the ground is saturated by extended rainfall or snowmelt)
4.1.5 Safety
There is inherent risk involved with any field work. All field team and investigation staff are
responsible for being actively involved in hazard analysis and risk reduction procedures.
Potential hazards should be identified and assessed to determine measures to eliminate or
minimize risk before each field activity. Common hazards that should be considered may
include working in waterways, sun/heat/cold exposure, slips/trips/falls, and biological hazards
such as poison ivy, poison oak, ticks, or snakes.
Basic personal protective equipment (PPE) may include boots, thick layered clothing,
gloves, and eye protection.

Town of Cramerton I Illicit Discharge Detection and Elimination Plan ���
IDDE Process
• Additional PPE may be seasonal, such as sunscreen, snake chaps, etc., or personally
modified for an individual with a higher risk.
• A first aid kit and fully charged cell phone should be maintained within the field team at
all times.
• Teams should be aware of the closest emergency facilities depending on where they are
working within the Town.
4.2 Dry Weather Screening and Field Equipment Summary
During outfall screening, field crews will visually inspect each outfall and the immediate
surrounding area, photograph the current conditions, and complete a Dry -Weather Outfall
Screening Form provided in Appendix B. Special attention will be paid to outfalls that are flowing
when no rain has occurred within the previous 48 hours and/or outfalls where non-stormwater
characteristics (e.g., clarity, odor, debris) are observed. When the screening of an outfall
indicates a potential illicit discharge, the Planning Director will be notified within one business
day so an investigation, as described in Section 4.6, can be performed. Any identified spills or
conditions that represent a serious threat to personnel/citizen safety or infrastructure damage
will be immediately reported to the Town's Fire Department.
The Dry -Weather Outfall Screening Form includes the following seven sections to be
completed with each outfall screening:
Section 1: Background Data — This section requires general information regarding when and
where the screening was performed, historical rainfall data, reference to photographs taken, and
a description of contributing drainage area land uses.
• The Outfall ID can be found in the stormwater drainage system maps in Appendix A of
this manual.
• The data on time since last rainfall can be obtained from USGS data or online weather
websites and can also be reported based on physical observation in the community
• Take at least one photograph of the outfall for documentation purposes. Note the
Camera ID and Photo IDs on the form.
• Drainage basin characterization (i.e., industrial/non-industrial) can be identified through
operator knowledge or by reviewing the stormwater drainage system maps in
Appendix A
Section 2: Outfall Description — This section requires a description and dimensions of the
outfall and a determination if flow is present during the inspection. Guidance for completing
Section 2 includes:
• The cross -sectional shape of the outfall structure will determine the dimensions required.
If the shape is abnormal, provide a sketch in the available area of the dimension column
and label the measured dimensions.
• If the outfall is obstructed with sediment, photograph the obstruction and attempt to
measure the depth of sediment.

Town of Cramerton i Illicit Discharge Detection and Elimination Plan ���
IDDE Process
• The identification of flow is important as flow during dry weather would indicate a non-
stormwater discharge. If a pipe is partially submerged in water, and it is difficult to
identify dry -weather flow, a nearby leaf or blade of grass can be dropped onto the water
surface near the outfall. Travel of the object on the surface can help indicate if flow is
discharging from the outfall.
• Dimensions that cannot be safely measured should be estimated.
• A description of the condition of the outfall with the option to select poor or fair or good
as the observed condition.
• Upon completion of this section, if flow is present, continue to Section 3 of the form.
However, if no flow is present, skip to Section 4 of the form.
Section 3: Discharge and indicators — This section requires the inspector to estimate the
quantity of discharge from the outfall at the time of inspection and requires the documentation of
seven indicators for flowing outfalls — odor, color, clarity, floatables, abnormal vegetation, and
conveyance benthic growth. These indicators are important in detecting the most severe or
obvious discharges. The severity of each indicator is rated on a scale from zero to three.
Guidance for completing Section 3 includes:
• Flow Volume estimate: The amount of flow is estimated by visual observation assigned
to one of three options namely, trickle, moderate, and substantial.
• Odor observation: A severity score of 0 means that no odor is present; a score of 1
means the odor is faint or it is unclear if the odor is coming from the stream or other
object in the area; a score of 2 indicates a moderate odor within the pipe; and a score of
3 is assigned if the odor is so strong that it is detected at a considerable distance from
the outfall.
• Color and Clarity observation: Color and clarity are evaluated by physical observation of
the discharge, and a severity score of 0 means that no color and clarity concern is
present; a score of 1 means the color or clarity concern is faint; a score of 2 indicates a
moderate color and clarity concern; and a score of 3 is assigned if the color and clarity
concern is strong.
• Floatables observation: Sewage, oil sheens, and suds are all examples of floatable
indicators. Floatables that appear to be sewage are assigned a severity score of 3.
Surface oil sheens are ranked based on their thickness and coverage. Note that natural
sheens created by in -stream biological processes can form a sheet -like film that cracks if
disturbed and are not solely an indicator of an illicit discharge. Suds are rated based on
their foaminess. A severity score of 3 is designated for thick foam that travels many feet
before breaking up. Suds that break up quickly may simply reflect water turbulence and
may not necessarily have an illicit origin. Suds that are accompanied by a strong organic
or sewage -like odor may indicate a sanitary sewer leak or connection, whereas suds
with a fragrant odor may indicate the presence of wash waters. The scoring ranges from
zero to three depending on the severity of floatables observed. Note that trash and
debris are generally not considered illicit discharge concerns and should not be
documented as floatables. Trash should be noted in Section 5 of the form.

Town of Cramerton I Illicit Discharge Detection and Elimination Plan ���
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Abnormal Vegetation: Inhibited vegetation growth immediately downstream of the outfall
may be an indicator of industrial discharges, whereas excessive vegetation may be an
indicator of a nutrient rich discharge (e.g., sewage, fertilizers, etc.). The scoring ranges
from zero to three depending on the severity of abnormal vegetation observed A severity
score of 0 means that no abnormal vegetation is present; while a score of 3 means that
a major presence of abnormal vegetation was observed.
Conveyance Benthic Growth: Benthic growth on the pipe includes algae, bacteria, and
slime on outfall surfaces may be an indicator of a nutrient rich discharge (e.g., sewage,
fertilizers, etc.). The scoring ranges from zero to three depending on the severity of
benthic growth observed. A severity score of 0 means that no benthic growth is present;
while a score of 3 means that a major presence of benthic growth was observed.
Section 4: Overall Preliminary Illicit Discharge Rating — This section requires an overall illicit
discharge rating of unlikely, potential, suspect, or obvious for the outfall based on the discharge
indicators identified in the preceding sections. This is only an initial assessment of the likelihood
of an illicit discharge and will be used to determine if additional investigation is warranted. The
outfall characterization rating is best judged by the inspector. Rating guidance is provided on the
form to provide consistency; however, the intuition of the inspector should take precedence.
Tips for completing Section 4 include:
• Unlikely: A rating of Unlikely is generally assigned to non -flowing outfalls with no
physical indicators of an illicit discharge in Section 2 or 3.
• Potential: A rating of Potential is generally assigned to flowing or non -flowing outfalls
with presence of one or more physical indicators in Sections 3.
• Suspect: A rating of Suspect is generally assigned to flowing outfalls with high severity,
typically a 3 on the 0 to 3 scale, on one or more physical indicators in Section 3.
• Obvious: A rating of Obvious is generally assigned where there is an illicit discharge that
can be confirmed without sampling or upstream investigation.
Section 5: Other Non -Illicit Discharge Concerns — This section is used to document other
concerns observed at the outfall that are not associated with illicit discharges and may include:
accumulated trash, erosion, sink holes, pipe failure, overgrowing vegetation, and required
infrastructure repairs.
4.3 Investigation Process
Potential illicit discharges can be detected through citizen/staff reporting or outfall inspections as
described in Section 4.2. Once a potential illicit discharge has been detected, it becomes
necessary to conduct an investigation to identify and eliminate the source of the discharge. The
investigation may result in the source being easily identified or it may require a more in-depth
inspection as outlined in this section.
4.3.1 Responsibility
Illicit discharge investigations are the responsibility of the Planning Director. Investigations may
be performed by other Town staff or by consultants hired by the Town. However, all
investigation results will be reviewed and maintained by the Planning Director.

Town of Cramerton i Illicit Discharge Detection and Elimination Plan ���
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4.3.2 Time Frame for Investigation
After a potential, suspected, or obvious illicit discharge has been detected, follow-up
investigations should be prioritized and initiated according to the following guidance:
Priority Level 1 — Initiate investigations within three working days for discharges
suspected of being sanitary sewage, significantly contaminated (e.g., degreasers,
solvents, pesticides, petroleum), or unknown based on the initial observation
Priority Level 2 — Initiate investigations within seven working days for discharges
suspected of being less hazardous to human health and safety (e.g., non -contact cooling
water, wash water, yard waste)
Note that any discharges that represent a serious threat to human health or the environment
should immediately be reported to the Town's Fire Department.
4.3.3 Primary Investigation Methodology
When the source of a suspected illicit discharge cannot be readily identified, additional action is
required. The source of some illicit connections or discharges can be located by systematically
isolating the area from which the polluted discharge originates. This process involves
progressive investigation at manholes and catch basins in the storm drain network to narrow
down the location where the illicit discharge is entering the drainage system. This method is
best used to identify constant or frequent discharge sources such as an illicit connection with
the sanitary sewer system. Field crews should work progressively upstream from the outfall and
inspect stormwater structures (e.g., manholes, catch basins, junctions) looking for the presence
of flow during dry weather, foul odors, colors or stained deposits, oily sheen, floatable materials,
and/or other indicators of the illicit discharge. The observations are continued at each upstream
structure until a structure is found with no evidence of discharge. This indicates the discharge
source is likely located between the structure with no evidence of discharge and the next
downstream structure.
Once the discharge source has been isolated to a specific segment of the stormwater drainage
system, the field crew should inspect the drainage area near the point of entry to identify the
source. The drainage area inspection should include interviewing personnel at nearby facilities
or residences within the vicinity of the drainage area to understand activities and materials used
that may be generating discharges. Special attention should be paid to facilities that use
materials similar to those noted in the discharge or residential locations that show evidence of
illegal dumping (e.g., residences with moves scheduled or a history of multi -family homes policy
violations). For example, if a discharge is detected with an oil sheen and a gasoline odor,
vehicle maintenance facilities would be of more interest than a food service facility. The
stormwater drainage system map should also be cross referenced against the sanitary sewer
map and/or historical as -built drawings of nearby facilities to identify illicit connections with the
sanitary sewer, discharges from industrial processes, or drain inlets located within wash areas.
The source of all confirmed illicit discharges should be photographed and documented as
described in Section 4.4 for future correction.

Town of Cramerton I Illicit Discharge Detection and Elimination Plan ���
IDDE Process
4.3.4 Alternative Investigation Methodology
The Town relies primarily on physical indicators, interviews, and historical records to identify the
source of potential illicit discharges; however, there are several additional field tests that may be
performed as necessary. Additional field tests include:
• Dye testing
• Smoke testing
• Closed circuit television video inspection
• Discharge sample and analysis
Sampling should include the parameters shown in Table 1 at a minimum but may include others
as deemed necessary.
Table 1 Dry -weather discharge sampling parameters
Parameter
Conductivity
Ammonia
Dissolved Oxygen (DO)
Nitrate
pH
Temperature
Total Dissolved Solids
TMLD Pollutants of Concern
Based on the results of the sampling, the discharge should be determined to be either illicit or
allowable.
• If the sampled parameters are within acceptable ranges, a fluoride sample should be
collected and analyzed at a certified laboratory.
• If the fluoride sample results are in the range of potable water, it indicates that the
discharge source could be some of the sources listed as allowable.
• Allowable results need no further investigation, and the effort is complete.
If a discharge is determined to be illicit, the investigation team will locate the discharge source
and collect additional information for removal and enforcement proceedings.
4.3.5 Indeterminate Investigations
General IDDE guidance recommends that at least three separate attempts be made to identify
the source of an intermittent, non-stormwater discharge. If three attempts have been made and
the non-stormwater discharge has not been detected again within six months of the first
investigation, then the discharge should be documented as "Source not found — discharge has
not reoccurred" in the Illicit Discharge Tracking Form and no further action is required. Non-
stormwater flows that are found to be the result of discharges allowable under the NPDES or
other state permits require no further action and should be documented as "Allowable
discharge".
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4.3.6 Documentation
Recording keeping is an important component of the illicit discharge investigation process. The
Town staff will complete the following tasks after initiating an investigation:
• Enter investigation data into Section 2 of the Illicit Discharge Tracking Form for each
investigative task completed. If multiple attempts and methods are conducted to
investigate a discharge, ensure each attempt is documented with the date. Completion
of the tracking form will document the discharge for elimination and annual reporting as
required by the MS4 permit. An example Illicit Discharge Tracking Form is provided in
Appendix B. The tracking form will be maintained by the Planning Director and kept
electronically on the Town's file server.
• Download digital investigation photographs to an appropriately titled folder on the on the
Town's file server. The photographs will be grouped by permit year and renamed based
on the corresponding Discharge ID in the Illicit Discharge Tracking Form. If multiple
photographs are taken as part of the investigation(s), "-#" will be appended to the end of
the Discharge ID (e.g., 100-1, 100-2, 100-3).
4.4 Illicit Discharge Elimination Process and Enforcement Action
4.4.1 Responsibility
Initiating and verifying the elimination of an illicit discharge is the responsibility of the Town. The
Planning Director will provide educational materials and advocate for funding when needed to
eliminate illicit discharges. Depending on the location and type of discharges, specific
elimination actions may be conducted by other organizations, or by contractors hired by the
Town. Regardless of the entities involved in eliminating an illicit discharge, The Planning
Director is responsible for following -up on the corrective actions to verify the illicit discharge has
been resolved.
4.4.2 Structural Issues
Structural issues will generally require a construction action to eliminate the illicit discharge.
Repair projects for structural issues should be initiated through completion of a service order
request to the Town's work order log. The Planning Director will determine whether the issue
can be addressed with a work order.
Examples of structural issues that may result in illicit discharges include:
• Illicit connections with the sanitary sewer
• Oil/water separators (OWS) pretreating industrial wastewater discharging to the
stormwater drainage system
• Leaking concrete containment berms and/or valves
• High level bypass pipes at sanitary sewer lift stations
4.4.3 Operational Deficiencies
Operational deficiencies can typically be addressed through BMPs such as education,
modification of processes, and/or relocation of the discharge generating activities. Town staff
will work with facility occupants as needed to promote compliance.
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Town of Cramerton I Illicit Discharge Detection and Elimination Plan ���
IDDE Process
Examples of operational deficiencies that may result in illicit discharges include:
• Washing activities in areas that discharge to a storm drain inlet
• Runoff from improperly stored material
• Illegal dumping
• Dumpster leachate
• Improperly managed secondary containment valves
4.4.4 Follow-up Investigations
After a confirmed illicit discharge has been eliminated, Town staff must conduct a follow-up
investigation to verify that the discharge has been eliminated. If the discharge was due to a
structural issue, the field crew should inspect and photograph the location of the repair to
confirm the source has been eliminated. If the discharge was due to an operational deficiency,
the field crew should revisit the entry point of the previous illicit discharge and verify that there
are no indicators of further discharges. Town staff should also interview personnel at the
location associated with the previous discharges to ensure they have proper procedures in
place to prevent future discharges.
4.4.5 Enforcement Actions and Documentation
Illicit discharges to the stormwater system are prohibited by the Gaston County Ordinance
adopted by the Town. After illicit discharges are identified and traced, the sources of the
discharges must be eliminated. The parties responsible for the discharges are notified and
enforcement actions pursuant to the Town's IDDE ordinance policies are taken. Generally, the
Town will follow a three -step enforcement action plan for confirmed illicit discharges; however,
more serious violations or continued, egregious non-compliance may warrant a more
aggressive approach. Actions conducted under each enforcement step include the following:
Step 1: Initial Actions — The Town will notify the violator by written and mailed letter,
describing the location and nature of the illicit discharge, the date it was confirmed, the
required elimination action, and a reasonable timeframe for compliance. Notifications for
illicit discharges occurring in neighborhoods will be sent to the HOA. Step 1 is not meant
to be punitive. It is an opportunity to inform and educate the responsible parties and to
encourage voluntary compliance.
Step 2: Intermediate Actions — If the confirmed illicit discharge has not been eliminated
by the required compliance date or if the illicit discharge is detected a second time at the
location under the responsibility of the same organization at a later date, the Town will
issue a Notice of Violation (NOV) to the parties responsible for illicit discharges with a
second compliance date. To the extent possible, Step 2 is meant to bring about an
immediate stop to activities generating the illicit discharge until such time that
procedures are put in place to prevent future discharges.
Step 3: Final Actions — If the confirmed illicit discharge has not been eliminated by the
second compliance date or if the illicit discharge reoccurs at the facility a third time under
the responsibility of the same organization at a later date, The Town will issue a second
NOV regarding the unresolved issues.
12

Town of Cramerton i Illicit Discharge Detection and Elimination Plan ���
IDDE Process
Town staff has the enforcement authority to issue NOVs and to enter private property in these
situations. The Town will also coordinate with other utility staff to manage discharges caused by
issues like sewer or water line leaks. These enforcement actions complete the dry -weather
screening process.
Results and conclusions should be properly documented for future screenings and program
evaluation. Documentation information are entered into Section 3 and 4 of the Illicit Discharge
Tracking Record for each elimination and follow-up task completed. Completion of the tracking
form will document the closure of the investigation for annual reporting as required by the
permit. An example Illicit Discharge Tracking Record is provided in Appendix B, and the
Planning Director maintains an electronic copy. Download digital photographs of the follow-up
investigation are also added to the Town's file server. The photographs will be grouped by
permit year and renamed based on the corresponding Discharge ID in the Illicit Discharge
Tracking Record. If multiple photographs are taken for the same record, "-#" will be appended to
the end of the Discharge ID (e.g. 100-1, 100-2, 100-3). Each enforcement letter issued to
violating parties are also digitally saved in the Town's file server, and the submittal date of the
enforcement letters are documented in the "Corrective Action to be Taken" field in Section 2 of
the Illicit Discharge Tracking Record. All correspondence between the Town and violating
parties regarding the resolution of the illicit discharge are saved in the Town's file server.
4.5 Employee Training
The Planning Director is responsible for arranging IDDE training for Town staff. The training will
focus on City policy and procedures related to illicit discharge detection, reporting, and
elimination. Field and Maintenance staff be trained in visual screening techniques to watch for
evidence of illicit discharges or unusual flows from the storm drain systems. The training will
include specifics of how to utilize the Town's IDDE procedures Manual. The Town will conduct
this training annually for all municipal employees with the potential to come across illicit
discharges. The Planning Director will record the employees present at the training in the
employee training log (Appendix D)
4.6 Program Evaluation and IDDE Manual Updates
Regular review of the IDDE Manual and the procedures is important in order for the Town to
have an up-to-date standard to use for assessing the overall effectiveness of the IDDE Program
for compliance with Individual Permit No. NCS000449. The Town's IDDE Plan outlines the
procedures for the IDDE program evaluation and assessment (refer to the IDDE Plan). The
Town will perform this evaluation annually. Evaluation procedures will include documentation of
actions taken to locate and eliminate illicit discharges. Evaluation documentation will include, as
applicable, the number of outfalls inspected or maintained, complaints taken and investigated,
and numbers of discharges eliminated. The following steps for assessing the effectiveness of
the Town's IDDE program will be included:
• Evaluate the number of possible illicit discharges that were detected using different
detection methods, to help determine which detection methods are most effective.
• Evaluate the number of discharges and/or quantity of discharges eliminated using
different possible enforcement and compliance measures.
13

Town of Cramerton I Illicit Discharge Detection and Elimination Plan ���
IDDE Process
• Evaluate how public education efforts are resolving trends in types of illicit discharges,
sources, and violators
• Evaluate procedures for improving efficiency and feasibility. Questions to answer
include:
o How much staff time and expense did it take to achieve a given result?
o Were difficulties encountered? What were they, and how much of a problem did
they present?
o Improved Level of Service?
o Effect on Budget
14

Town of Cramerton I Illicit Discharge Detection and Elimination Plan ���
Appendix A - Stormwater Outfall Inspection Forms
Appendix A - Stormwater
Outfall Inspection Forms

Town of Cramerton I Illicit Discharge Detection and Elimination Plan ���
Appendix A - Stormwater Outfall Inspection Forms
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Town of Cramerton I Illicit Discharge Detection and Elimination Plan ���
Appendix B - Stormwater Outfall Inspection Forms
Appendix B - Stormwater
Outfall Inspection Forms

Town of Cramerton I Illicit Discharge Detection and Elimination Plan ���
Appendix B - Stormwater Outfall Inspection Forms
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Town of Cramerton I Illicit Discharge Detection and Elimination Plan ���
Appendix B - Stormwater Outfall Inspection Forms
CAP
IDDE Tracking Record
Section 1. Detection
Section 2. Investigation
Section 3. Elimination
Section 4. Follow -Up
Date
Reported or
Identified
Reported/
Identified by:
Location of Discharge
Description of Discharge
Additional
Investigation
Required?
Date(s) of
Investigation
Results of Investigation
Corrective Action to be
Taken
Scheduled
Date of
Corrective
Action
Description of Corrective Action
Taken
Date
Corrected
Date of
Verification
Discharge
ID No.
Enter date
discharge
was
reported
or
identified
Provide name
and contact
number of
reporting
personnel
Provide address, Outfall
ID, nearby landmark, etc.
Provide description of the
potential illicit discharge (e.g.,
dumping, wash water, suds,
oil, etc.). Include
characterization from Section 6
of the outfall inspection form if
applicable.transitory)?
(Yes/No)
Enter date
of
investigation
Describe investigation results.
Was the source found? Was
his an illicit discharge? What is
he source. What is the
frequency of the discharge
(continuous, intermittent, or
Specify what will be done to
eliminate the illicit discharge
and by whom
Enter the
estimated
date for
completion
of
corrective
actions
How was the illicit discharge
resolved?
Enter date
of
resolution
Enter date of
follow-up
investigation
to verify illicit
discharge has
been
eliminated
Additional Notes

DRY -WEATHER OUTFALLSCREENING FORM
Section 1: Background Data
Installation:
Outfall ID:
Date:
Time (Military):
Completed by:
Days since last rain:
Potential gauge Site Information
Site Name: Rain gage at Duharts Creek Near
Site Number: 351452081055245
Cramerton, NC
Camera ID:
Photo IDs:
Land Use in Drainage Area (Check
all that apply):
❑ Industrial
❑ Open Space
❑ Training
❑ Institutional (e.g., school, hospital)
❑ Residential
Other:
❑ Commercial
Section 2: Outfall Description
STRUCTURE
TYPE
MATERIAL
SHAPE
DIMENSIONS
(INCHES)SUBMERGED
❑ Pipe
❑ RCP CMP
Geometry:
Number of
Diameter/Dimensions:
In water:
❑ PVC HDPE
❑ Circular
Barrels:
❑ No
❑ Steel
❑ Elliptical
❑ Single
❑ Partially
❑ Other:
❑ Box
❑ Double
❑ Fully
❑ Other:
❑ Triple
❑ Other:
With Sediment:
❑ No
❑ Partially
❑ Full
❑ Channel
❑ Concrete
❑ Trapezoid
Depth:
❑ Earthen
❑ Parabolic
Top Width:
❑ Riprap
❑ Other:
Bottom Width: _
❑ Other:
Outfall
❑ Poor ❑ Fair ❑ Good
Condition
Description of
Outfall
Condition
Flow Present?
❑ Yes ❑ No If No, Skip to Section 4
Section 3: Discharge and Indicators
FIELD DATA FOR FLOWING
OUTFALLS
Flow
❑ Trickle -i Moderate -i Substantial
Description
if present

DRY -WEATHER OUTFALL SCREENING FORM
Section 3: Discharge and Indicators
INDICATOR
DESCRIPTION
RELATIVE SEVERITY INDEX 0-3
Odor
❑ Sewage _jRancid/Sour _j Petroleum/gas
❑ 1 — Faint;
❑ 3 - Noticeable
❑ Sulfide -1 Other:
❑ 0 -None
origin not
El 2 -Easildetected
y
from a
obvious
distance
Color
❑ Brown ❑ Gray ❑ Yellow
❑Green � Orange Red
❑ 0 -Clear
❑ 1 -Faint colors
❑ 2 -Clearly visible
❑ 3 -Clearly
in
in
visible in
❑ Other:
sample bottle
sample bottle
outfall flow
Clarity
See severity
❑ 0 - Clear
❑ 1 - Slight
❑ 2 - Cloudy
❑ 3 - Opaque
index
cloudiness
Floatables'
❑ Sewage (e.g., toilet paper) ❑ Suds
❑ 3 - Some;
(Does not include trash)
❑ Petroleum (oil sheen)-] Other:
❑ 0 - None
❑ 1 - Few/slight;
❑ 2 -Some;
indications of
origin clear
origin not
obvious
origin (e.g.,
(e.g-,
obvious oil
possible suds
sheen,
or oil sheen)
suds or
floating
sanitary
materials
Abnormal Vegetation
See severity index
❑ 0 - None
❑ 1 - Few/slight
❑ 2 - More
❑ 3- Substantial
Conveyance Benthic
See severity index
0 - None
1 - Few/slight
2 - More
❑ 3- Substantial
G rowth
Section 4: Overall Preliminary Illicit Discharge Rating
❑ Unlikely: Non -flowing outfalls with no indicators in Section 5. ❑ Suspect: Flowing outfalls with one or more high severity indicators in
Section 4.
❑ Potential: Flowing or non -flowing outfalls with one or more indicators in
Sections 4 or 5. ❑ Obvious: Illicit discharge can be confirmed without sampling or upstream
investigation
Section 5: Any Non -Illicit Discharge Concerns (e.g., trash or needed infrastructure repairs, take photos, and indicate photo ID)?

Town of Cramerton I Illicit Discharge Detection and Elimination Plan ���
Appendix C - Legal Authority (IDDE Bylaw)
Appendix C -Legal Authority
(IDDE Bylaw)

Town of Cramerton I Illicit Discharge Detection and Elimination Plan ���
Appendix C - Legal Authority (IDDE Bylaw)
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Town of Cramerton I Illicit Discharge Detection and Elimination Plan
Appendix D - IDDE Employee Training Record
FN
Appendix D - IDDE Employee
Training Record

Town of Cramerton I Illicit Discharge Detection and Elimination Plan
Appendix D - IDDE Employee Training Record
IDDE Employee Training Record
FR
Name Role Training Date Signature

FN
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Charlotte, NC 28202-2075
704.338.6700
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