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Illicit Discharge Detection and Elimination (IDDE) Plan

June 28, 2019

This template was compiled by VHB for use by members of the Cape Cod Stormwater Managers Group as part of a 604(b) Grant funded by the Massachusetts Department of Environmental Protection. This template was developed by modifying a template created by the Central

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Massachusetts Regional Stormwater Coalition (CMRSWC) and Fuss & O’Neill and integrated with content from the Buzzards Bay Action Committee’s Stormwater Collaborative Stormwater Monitory Guidelines and Barnstable County Water Quality Laboratory.

Table of Contents

Illicit Discharge Detection and Elimination Plan

1 Introduction 11.1 MS4 Program 1

1.2 Illicit Discharges 11.3 Allowable Non-Stormwater Discharges 2

1.4 Receiving Waters and Impairments 21.5 IDDE Program Goals, Framework, and Timeline 3

2 Authority and Statement of IDDE Responsibilities 5

2.1 Legal Authority52.2 Statement of Responsibilities 5

3 Stormwater System Mapping 73.1 Phase I Mapping 73.2 Phase II Mapping 8

3.3 Additional Recommended Mapping Elements 8

4 Sanitary Sewer Overflows (SSOs)10

5 Assessment and Priority Ranking of Outfalls 12

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5.1 Outfall Catchment Delineations 125.2 Outfall and Interconnection Inventory and Initial

Ranking 12

6 Illicit Discharge Detection and Elimination Program 16

6.1 Dry Weather Outfall Screening and Sampling 166.2 Catchment Investigations18

6.3 Wet Weather Outfall Sampling 216.4 Source Isolation and Confirmation 22

6.5 Illicit Discharge Removal 246.6 Ongoing Screening 25

7 Field Screening and Sampling Procedures 26

7.1 Dry Weather Screening/Sampling Procedures 267.2 Catchment Investigation Procedures 32

7.3 Wet Weather Sampling Procedures 347.4 Field Work Safety Procedures 34

7.5 Field Equipment 37

8 Training 409 Progress Reporting 40

TablesIllicit Discharge Detection and Elimination Plan ii

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Table 1-1. Impaired Waters3Table 1-2. TMDL IDDE-Related Requirements 3

Table 4-1. SSO Inventory 11Table 6-1. Benchmark Field Measurements for Select

Parameters 17Table 6-2. Outfall Catchment System Vulnerability

Factor (SVF) Inventory20Table 7-1. Sampling Parameters and Analysis Methods

30Table 7-2. Required Analytical Methods, Detection

Limits, Hold Times, and Preservatives 31Table 7-3. Standard Operating Safety Procedures 34

Table 7-4. Field Equipment – Outfall Screening and Sampling 38

FiguresFigure 1-1. IDDE Investigation Procedure Framework…………………………………………………………………………..4

Figure 1-2. IDDE Program Implementation Timeline……………………………………………………………………………4

Appendices

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Appendix A – Legal Authority (IDDE Bylaw or Other Regulatory Mechanism)

Appendix B – Storm System Mapping

Appendix C – Field Forms, Sample Bottle Labels, and Chain of Custody Forms

Appendix D – Water Quality Analysis Instructions, User’s Manuals and Standard Operating Procedures

Appendix E – IDDE Employee Training Record

Appendix F – Source Isolation and Confirmation Methods: Instructions, Manuals, and SOPs

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1 IntroductionInstructions: Throughout this document, the symbol ‘##’ has been used to represent locations where community or site-specific information is required.

1.1 MS4 ProgramThis Illicit Discharge Detection and Elimination (IDDE) Plan has been developed by ##MUNICIPALITY to address the requirements of the United States Environmental Protection Agency’s (USEPA’s) 2016 National Pollutant Discharge Elimination System (NPDES) General Permit for Stormwater Discharges from Small Municipal Separate Storm Sewer Systems (MS4) in Massachusetts, hereafter referred to as the “2016 Massachusetts MS4 Permit” or “MS4 Permit.”

The 2016 Massachusetts MS4 Permit requires that each permittee, or regulated community, address six Minimum Control Measures. These measures include the following:

1. Public Education and Outreach2. Public Involvement and Participation3. Illicit Discharge Detection and Elimination Program4. Construction Site Stormwater Runoff Control5. Stormwater Management in New Development and Redevelopment (Post

Construction Stormwater Management); and6. Good Housekeeping and Pollution Prevention for Permittee Owned Operations.

Under Minimum Control Measure 3, the permittee is required to implement an IDDE program to systematically find and eliminate sources of non-stormwater discharges to its municipal separate storm sewer system and implement procedures to prevent such discharges. The IDDE program must also be recorded in a written (hardcopy or electronic) document. This IDDE Plan has been prepared to address this requirement.

1.2 Illicit DischargesAn “illicit discharge” is any discharge to a drainage system that is not composed entirely of stormwater, with the exception of discharges pursuant to a NPDES permit

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(other than the NPDES permit for discharges from the MS4) and discharges resulting from fire-fighting activities.

Illicit discharges may take a variety of forms. Illicit discharges may enter the drainage system through direct or indirect connections. Direct connections may be relatively obvious, such as cross-connections of sewer services to the storm drain system. Indirect illicit discharges may be more difficult to detect or address, such as failing septic systems that discharge untreated sewage to a ditch within the MS4, or a sump pump that discharges contaminated water on an intermittent basis.

Some illicit discharges are intentional, such as dumping used oil (or other pollutants) into catch basins, a resident or contractor illegally tapping a new sewer lateral into a storm drain pipe to avoid the costs of a sewer connection fee and service, and illegal dumping of yard wastes into surface waters.

Some illicit discharges are related to the unsuitability of original infrastructure to the modern regulatory environment. Examples of illicit discharges in this category include connected floor drains in old buildings, as well as sanitary sewer overflows that enter the drainage system. Sump pumps legally connected to the storm drain system may be used inappropriately, such as for the disposal of floor washwater or old household products, in many cases due to a lack of understanding on the part of the homeowner.

1.3 Allowable Non-Stormwater DischargesThe following categories of non-storm water discharges are allowed under the 2016 MS4 Permit unless the permittee, EPA or Massachusetts Department of Environmental Protection (MassDEP) identifies any category or individual discharge of non-stormwater discharge as a significant contributor of pollutants to the MS4:

Water line flushing Landscape irrigation Diverted stream flows Rising ground water Uncontaminated ground water

infiltration (as defined at 40 CFR 35.2005(20))

Uncontaminated pumped groundwater

Discharge from potable water sources

Foundation drains Air conditioning condensation Irrigation water, springs


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Water from crawl space pumps Footing drains Lawn watering Individual resident car washing

De-chlorinated swimming pool discharges

Street wash waters Residential building wash waters

without detergents

If these discharges are identified as significant contributors to the MS4, they must be considered an “illicit discharge” and addressed in this IDDE Plan (i.e., control these sources so they are no longer significant contributors of pollutants, and/or eliminate them entirely).

1.4 Receiving Waters and ImpairmentsTable 1-1 lists the “impaired waters” within the boundaries of ##MUNICIPALITY’s regulated area based on the ##YEAR Massachusetts Integrated List of Waters produced by MassDEP every two years. Impaired waters are water bodies that do not meet water quality standards for one or more designated use(s) such as recreation or aquatic habitat. Table 1-2 lists IDDE-related requirements for water bodies with total maximum daily loads (TMDLs).

Instructions: Refer to MassDEP’s website for most recent Integrated List of Waters (CWA Sections 303d, 305B, and 314): http://www.mass.gov/eea/agencies/massdep/water/watersheds/total-maximum-daily-loads-tmdls.html. Towns can update information in Table 1-1 and Table 1-2 below with information from the Notice of Intent (NOI).

Table 1-1. Impaired Waters

##MUNICIPALITY, MassachusettsWater Body Name Segment ID Categor

y Impairment(s) Associated Approved TMDL


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http://www.mass.gov/eea/agencies/massdep/water/watersheds/total-maximum-daily-loads-tmdls.html

Category 4a Waters – impaired water bodies with a completed Total Maximum Daily Load (TMDL).

Category 4c Waters – impaired water bodies where the impairment is not caused by a pollutant. No TMDL required.

Category 5 Waters – impaired water bodies that require a TMDL.

“Approved TMDLs” are those that have been approved by EPA as of the date of issuance of the 2016 MS4 Permit.

Instructions: Review the impaired waters and approved TMDLs and describe below any IDDE-related requirements identified in the specific TMDLs for those waterbodies. Information can be provided in Table 1-2 below or by other means. Remove table if not applicable.

Table 1-2. TMDL IDDE-Related Requirements

##MUNICIPALITY, Massachusetts

Water Body Name Associated Approved TMDL TMDL IDDDE-Related Requirement(s)


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1.5 IDDE Program Goals, Framework, and TimelineThe goals of the IDDE program are to find and eliminate illicit discharges to municipal separate storm sewer system and to prevent illicit discharges from happening in the future. The program consists of the following major components as outlined in the MS4 Permit:

Legal authority and regulatory mechanism to prohibit illicit discharges and enforce this prohibition

Storm system mapping Inventory and ranking of outfalls Dry weather outfall screening Catchment investigations Identification/confirmation of illicit sources Illicit discharge removal Follow-up screening Employee training.

The IDDE investigation procedure framework is shown in Figure 1-1. The required timeline for implementing the IDDE program is shown in Figure 1-2.

Figure 1-1. IDDE Investigation Procedure Framework


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Figure 1-2. IDDE Program Implementation Timeline

2 Authority and Statement of IDDE Responsibilities

2.1 Legal AuthorityInstructions: Use the following language if your municipality already has an illicit discharge bylaw, or other regulatory mechanism in place, as required by the 2003 MS4 Permit. Towns should include reference to their bylaw here and/or use the Cape Cod IDDE bylaw template to do so.

The ##MUNICIPALITY has adopted a ##NAME OF BYLAW (##REVISION DATE). A copy of the ##NAME OF BYLAW is provided in Appendix A. The ##NAME OF BYLAW provides the ##MUNICIPALITY with adequate legal authority to:


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Prohibit illicit discharges Investigate suspected illicit discharges Eliminate illicit discharges, including discharges from properties not owned by or

controlled by the MS4 that discharge into the MS4 system Implement appropriate enforcement procedures and actions.

The ##MUNICIPALITY will review its current ##NAME OF BYLAW and related land use regulations and policies for consistency with the 2016 MS4 Permit.

Instructions: Use the following language if your municipality has not adopted an illicit discharge bylaw or other regulatory mechanism in place, as required by the 2003 MS4 Permit.

The ##MUNICIPALITY will adopt a bylaw or other regulatory mechanism to provide the ##MUNICIPALITY with adequate legal authority to:

Prohibit illicit discharges Investigate suspected illicit discharges Eliminate illicit discharges, including discharges from properties not owned by or

controlled by the MS4 that discharge into the MS4 system Implement appropriate enforcement procedures and actions.

Instructions: Use the following language ONLY if your municipality is a new permittee under the 2016 permit. Otherwise, delete.

The bylaw or other regulatory mechanism will meet the requirements of the 2016 MS4 Permit and will be in place within 3 years of the permit effective date (July 1, 2021).


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2.2 Statement of ResponsibilitiesThe ##AGENCY OR DEPARTMENT is the lead municipal agency or department responsible for implementing the IDDE program pursuant to the provisions of the ##NAME OF BYLAW. Other agencies or departments with responsibility for aspects of the program include:

Instructions: List other municipal agencies or departments with responsibility for aspects of the IDDE program. Describe the process for coordination and data sharing between these agencies and departments.

The CMRSWC “Communicating IDDE Responsibilities” document provides suggested language for municipal job descriptions and IDDE program responsibilities.

http://www.centralmastormwater.org/pages/CRSC_documents/CMRSWC_IDDE%20Communication%20Packet.pdf

Department of Public Works - ##RESPONSIBILITIES Highway Department - ##RESPONSIBILITIES Sewer Department - ##RESPONSIBILITIES Building Inspector and/or Code Enforcement Officer - ##RESPONSIBILITIES Licensed Plumbing Inspector - ##RESPONSIBILITIES Health Department - ##RESPONSIBILITIES Engineering Department - ##RESPONSIBILITIES Conservation Agent - ##RESPONSIBILITIES Conservation Commission - ##RESPONSIBILITIES Planning Board Chairperson - ##RESPONSIBILITIES Board of Selectmen - ##RESPONSIBILITIES Town Administrator and/or Mayor - ##RESPONSIBILITIES


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3 Stormwater System MappingThe ##MUNICIPALITY originally developed mapping of its stormwater system to meet the mapping requirements of the 2003 MS4 Permit. A copy of the existing storm system map is provided in Appendix B. The 2016 MS4 Permit requires a more detailed storm system map than was required by the 2003 MS4 Permit. The revised mapping is intended to facilitate the identification of key infrastructure, factors influencing proper system operation, and the potential for illicit discharges.

The 2016 MS4 Permit requires the storm system map to be updated in two phases as outlined below. The ##AGENCY OR DEPARTMENT is responsible for updating the stormwater system mapping pursuant to the 2016 MS4 Permit. The ##MUNICIPALITY will report on the progress towards completion of the storm system map in each annual report. Updates to the stormwater mapping will be included in Appendix B.

3.1 Phase I MappingPhase I mapping must be completed within two (2) years of the effective date of the permit (by July 1, 2020) and include the following information:

Outfalls and receiving waters (previously required by the MS4-2003 permit) Open channel conveyances (swales, ditches, etc.) Interconnections with other MS4s and other storm sewer systems Municipally owned stormwater treatment structures Water bodies identified by name and indication of all use impairments as

identified on the most recent EPA approved Massachusetts Integrated List of Waters report

Initial catchment delineations. Topographic contours and drainage system information may be used to produce initial catchment delineations.

The ##MUNICIPALITY has completed the following updates to its stormwater mapping to meet the Phase I requirements:


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Instructions: List all of the mapping elements that have been included in your municipality’s storm system mapping and the dates they were added or most recently updated:

Outfalls and receiving waters (previously required by the MS4-2003 permit) Open channel conveyances (swales, ditches, etc.) Interconnections with other MS4s and other storm sewer systems Municipally owned stormwater treatment structures Water bodies identified by name and indication of all use impairments as

identified on the most recent EPA approved Massachusetts Integrated List of Waters report

Initial catchment delineations. Any available system data and topographic information may be used to produce initial catchment delineations

The ##MUNICIPALITY will update its stormwater mapping by July 1, 2020 to include the remaining Phase I information.

Instructions: Include the latest version of the storm system map and future updates to the map in Appendix B or provide a link for online viewing.

3.2 Phase II MappingPhase II mapping must be completed within ten (10) years of the effective date of the permit (by July 1, 2028) and include the following information:

Outfall spatial location (latitude and longitude with a minimum accuracy of +/-30 feet)

Pipes Manholes Catch basins Refined catchment delineations. Catchment delineations must be updated to

reflect information collected during catchment investigations. Municipal Sanitary Sewer system (if available) Municipal combined sewer system (if applicable).


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The ##MUNICIPALITY has completed the following updates to its stormwater mapping to meet the Phase II requirements:

Instructions: List all mapping elements that have been included in the municipality’s Phase II storm system mapping and the dates they were added or most recently updated:

Outfall spatial location (latitude and longitude with a minimum accuracy of +/-30 feet)

Pipes Manholes Catch basins Refined catchment delineations. Catchment delineations shall be updated to

reflect information collected during catchment investigations. Municipal Sanitary Sewer system (if available) Municipal combined sewer system (if applicable)

The ##MUNICIPALITY will update its stormwater mapping by July 1, 2028 to include the remaining following Phase II information.

Instructions: Include the latest version of the storm system map and future updates to the map in Appendix B or provide a link for online viewing.

3.3 Additional Recommended Mapping ElementsAlthough not a requirement of the 2016 MS4 Permit, the ##MUNICIPALITY ##HAS/WILL include the following recommended elements in its storm system mapping:

Instructions: The 2016 MS4 Permit recommends but does not require the following elements to be included in the storm system map, as information becomes available. Delete all mapping elements that do not apply, and list and/or describe other related map elements relevant to the municipality’s system mapping that have been included, or will be included, in the system mapping.


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Storm sewer material, size (pipe diameter), age Sanitary sewer system material, size (pipe diameter), age Privately owned stormwater treatment structures Where a municipal sanitary sewer system exists, properties known or suspected

to be served by a septic system, especially in high density urban areas Area where the permittee’s MS4 has received or could receive flow from septic

system discharges Seasonal high water table elevations impacting sanitary alignments Topography Orthophotography Alignments, dates and representation of work completed of past illicit discharge

investigations Locations of suspected confirmed and corrected illicit discharges with dates and

flow estimates.


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4 Sanitary Sewer Overflows (SSOs)The 2016 MS4 Permit requires municipalities to prohibit illicit discharges, including sanitary sewer overflows (SSOs), to the separate storm sewer system. SSOs are discharges of untreated sanitary wastewater from a municipal sanitary sewer that can contaminate surface waters, cause serious water quality problems and property damage, and threaten public health. SSOs can be caused by blockages, line breaks, sewer defects that allow stormwater and groundwater to overload the system, power failures, improper sewer design, and vandalism.

The ##MUNICIPALITY has completed an inventory of SSOs that have discharged to the MS4 within the five (5) years prior to the effective date of the 2016 MS4 Permit, based on review of available documentation pertaining to SSOs (Table 4-1). The inventory includes all SSOs that occurred during wet or dry weather resulting from inadequate conveyance capacities or where interconnectivity of the storm and sanitary sewer infrastructure allows for transfer of flow between systems.

Upon detection of an SSO, the ##MUNICIPALITY will eliminate it as expeditiously as possible and take interim measures to minimize the discharge of pollutants to and from its MS4 until the SSO is eliminated. Upon becoming aware of an SSO to the MS4, the ##MUNICIPALITY will provide oral notice to EPA within 24 hours and written notice to EPA and MassDEP within five (5) days of becoming aware of the SSO occurrence.

The inventory in Table 4-1 will be updated by the ##AGENCY OR DEPARTMENT when new SSOs are detected. The SSO inventory will be included in the annual report, including the status of mitigation and corrective measures to address each identified SSO.

SSO ReportingAn overflow or bypass must be reported within 24 hours by phone to MassDEP, EPA, and other relevant parties. ##MUNICIPALITY will follow up from the verbal notification with a written report following MassDEP's Sanitary Sewer Overflow (SSO)/Bypass notification form within 5 calendar days of the time ##MUNICIPALITY becomes aware of the overflow, bypass, or backup.

DEP 24-hour Emergency Line 1-888-304-1133


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DEP Northeast Region

(978) 694-3215

205B Lowell Street

Wilmington, MA 01887

DEP Central Region

(508) 792-7650

8 New Bond Street

Worcester, MA 01606

DEP Southeast Region

(508) 946-2750

20 Riverside Drive

Lakeville, MA 02347

DEP Western Region

(413) 784-1100

436 Dwight Street

Springfield, MA 01103

EPA New England

(617) 918-1510

5 Post Office Square

Boston, MA 02109


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Instructions: Complete this SSO inventory for all Sanitary Sewer Overflows (SSOs) that have discharged to the MS4 within the five (5) years prior to the effective date of the 2016 MS4 Permit. This inventory must be completed within one (1) year of the effective date of the permit. The table should be updated with information on new SSOs that are detected.

Table 4-3. SSO Inventory


Revision Date: ##DATE OF LAST UPDATE

SSO Location1 Discharge Statement2

Date3

Time Start3

Time End3

Estimated Volume4

Description5 Mitigation Completed6

Mitigation Planned7

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1 Location (approximate street crossing/address and receiving water, if any)2 A clear statement of whether the discharge entered a surface water directly or entered the MS43 Date(s) and time(s) of each known SSO occurrence (i.e., beginning and end of any known discharge)4 Estimated volume(s) of the occurrence5 Description of the occurrence indicating known or suspected cause(s)6 Mitigation and corrective measures completed with dates implemented7 Mitigation and corrective measures planned with implementation schedules


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5 Assessment and Priority Ranking of Outfalls

The 2016 MS4 Permit requires an assessment and priority ranking of outfalls in terms of their potential to have illicit discharges and SSOs and the related public health significance. The ranking helps determine the priority order for performing IDDE investigations and meeting permit milestones.

5.1 Outfall Catchment DelineationsA catchment is the area that drains to an individual outfall1 or interconnection.2 The catchments for each of the MS4 outfalls will be delineated to define contributing areas for investigation of potential sources of illicit discharges. Catchments are typically delineated based on topographic contours and mapped drainage infrastructure, where available. As described in Section 3, initial catchment delineations will be completed as part of the Phase I mapping, and refined catchment delineations will be completed as part of the Phase II mapping to reflect information collected during catchment investigations

5.2 Outfall and Interconnection Inventory and Initial RankingThe ##AGENCY OR DEPARTMENT will complete an initial outfall and interconnection inventory and priority ranking to assess illicit discharge potential based on existing information. The initial inventory and ranking will be completed within one (1) year from the effective date of the permit. An updated inventory and ranking will be provided in each annual report thereafter. The inventory will be updated annually to include data collected in connection with dry weather screening and other relevant inspections.

The outfall and interconnection inventory will identify each outfall and interconnection discharging from the MS4, record its location and condition, and provide a framework for tracking inspections, screenings and other IDDE program activities.

1 Outfall means a point source as defined by 40 CFR § 122.2 as the point where the municipal separate storm sewer discharges to waters of the United States. An outfall does not include open conveyances connecting two municipal separate storm sewers or pipes, tunnels or other conveyances that connect segments of the same stream or other waters of the United States and that are used to convey waters of the United States. Culverts longer than a simple road crossing shall be included in the inventory unless the permittee can confirm that they are free of any connections and simply convey waters of the United States.

2 Interconnection means the point (excluding sheet flow over impervious surfaces) where the permittee’s MS4 discharges to another MS4 or other storm sewer system, through which the discharge is conveyed to waters of the United States or to another storm sewer system and eventually to a water of the United States.Illicit Discharge Detection and Elimination Plan

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Outfalls and interconnections will be classified into one of the following categories:

1. Problem Outfalls: Outfalls/interconnections with known or suspected contributions of illicit discharges based on existing information shall be designated as Problem Outfalls. This shall include any outfalls/interconnections where previous screening indicates likely sewer input. Likely sewer input indicators are any of the following:

Olfactory or visual evidence of sewage, Ammonia ≥ 0.5 mg/L, surfactants ≥ 0.25 mg/L, and bacteria levels

greater than the water quality criteria applicable to the receiving water, or

Ammonia ≥ 0.5 mg/L, surfactants ≥ 0.25 mg/L, and detectable levels of chlorine.

Dry weather screening and sampling, as described in Section 6 of this IDDE Plan and Part 2.3.4.7.b of the MS4 Permit, is not required for Problem Outfalls.

2. High Priority Outfalls: Outfalls/interconnections that have not been classified as Problem Outfalls and that are:

Discharging to an area of concern to public health due to proximity of public beaches, recreational areas, drinking water supplies or shellfish beds

Determined by the permittee as high priority based on the characteristics listed below or other available information.

3. Low Priority Outfalls: Outfalls/interconnections determined by the permittee as low priority based on the characteristics listed below or other available information.

4. Excluded outfalls: Outfalls/interconnections with no potential for illicit discharges may be excluded from the IDDE program. This category is limited to roadway drainage in undeveloped areas with no dwellings and no sanitary sewers; drainage for athletic fields, parks or undeveloped green space and associated parking without services; cross-country drainage alignments (that neither cross nor are in proximity to sanitary sewer alignments) through undeveloped land.


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Outfalls will be ranked into the above priority categories (except for excluded outfalls, which may be excluded from the IDDE program) based on the following characteristics of the defined initial catchment areas, where information is available. The characteristics below present provide an overview; details are provided in Table 5-1. Additional relevant characteristics, including location-specific characteristics, may be considered but must be documented in this IDDE Plan.

Instructions: Delete the following characteristics where data is not available or that do not apply, and list and/or describe other relevant characteristics used to initially rank outfalls. Towns should update the "Additional Characteristics” category below as applicable.

Previous screening results – previous screening/sampling results indicate likely sewer input (see criteria above for Problem Outfalls).

Past discharge complaints and reports.

Discharging to Area of Concern to Public Health – outfalls or interconnections that discharge to public beaches, recreational areas, drinking water supplies and/or shellfish beds

Impaired Waterbodies – discharges to waters impaired for bacteria according to the most recent 303(d) list.

TMDL Watershed – discharges to waters with an approved TMDL where illicit discharges may contribute to the pollutant of concern.

Density of generating sites within Catchment – Generating sites are those places, including institutional, municipal, commercial, or industrial sites, with a potential to generate pollutants that could contribute to illicit discharges, based on land use codes or local knowledge.

Culverted streams – Any river or stream that is culverted for distances greater than a simple roadway crossing may have a high illicit discharge potential.

Additional Characteristics – as defined by the permittee and may include age of infrastructure, historic combined sewer systems, age of surrounding septic systems, recent septic to sewer conversion areas

Table 5-1 provides a sample format for an outfall inventory and priority ranking matrix.


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Instructions: Complete this outfall inventory and initial priority ranking (or similar spreadsheet) based on existing information and the catchment characteristics described in this section of the IDDE Plan. Numeric scores can be adjusted based on community- and site-specific factors. This inventory and initial priority ranking must be completed within one (1) year of the effective date of the permit. Towns should update the "Additional Characteristics” category below as applicable.


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Table 5-4. Outfall Inventory and Priority Ranking Matrix


Outfall ID Receiving Water

Previous Screening

Results Indicate Likely Sewer

Input1

Reports or Complaints of Potential Illicit Discharges?2

Discharging to Area of Concern

to Public Health?3

Receiving Water Quality 4 TMDL Watershed5

Density of Generating Sites within Catchment6

Culverted Streams?7 Additional Characteristics8 Score Priority Ranking

Information SourceOutfall

inspections and sample results

Town/Agency Records a b c d Impaired

Waters List MassDEP Land Use/GIS Maps, GIS and Storm System Maps Other

Scoring Criteria

Yes = 40 (Problem Outfall)

No = 0

Yes = 40 (Problem Outfall)

No = 0

Yes = 6

No = 0

Bacteria = 6

Other = 2

None = 0

Yes = 2

No = 0High = 3

Medium = 2

Low = 0

Yes = 3

No = 0TBD

Problem = ≥40

High Priority = ≥6

Low Priority = <6

Sample 1 XYZ River 40 40 6 6 0 0 2 0 2 0 None 96 Problem

Sample 2 XYZ Lake 0 0 0 0 6 0 6 0 3 0 None 15 High Priority

Sample 3 XYZ Stream 0 0 6 6 0 0 0 3 0 0 None 15 High Priority

Sample 4 XYZ River 0 0 0 0 0 0 2 0 2 0 None 4 Low Priority

Scoring Criteria:

1 Previous screening results indicate likely sewer input if any of the following are true:

Olfactory or visual evidence of sewage, Ammonia ≥ 0.5 mg/L, surfactants ≥ 0.25 mg/L, and bacteria levels greater than the water quality criteria applicable to the receiving water, or Ammonia ≥ 0.5 mg/L, surfactants ≥ 0.25 mg/L, and detectable levels of chlorine

2 Previous reports of dumping, failing septic systems, odors, or other indications of potential illicit discharges.

3 Outfalls/interconnections that discharge to or in the vicinity of any of the following areas, as determined via GIS evaluation of the following datalayers. Note: Discharges to an area of concern to public health will automatically be considered High Priority.

a. Public Beaches: https://docs.digital.mass.gov/dataset/massgis-data-marine-beachesb. Recreational Areas (note: query layer for only PRIM_PURP = “R” to only review areas protected for recreation primarily): https://docs.digital.mass.gov/dataset/massgis-data-protected-and-recreational-openspacec. Drinking Water Supplies: https://docs.digital.mass.gov/dataset/massgis-data-public-water-suppliesd. Shellfish Beds: https://docs.digital.mass.gov/dataset/massgis-data-designated-shellfish-growing-areas

4 Receiving water quality based on latest version of MassDEP Integrated List of Waters: https://www.mass.gov/lists/integrated-lists-of-waters-related-reports

Bacteria: Discharges to waters or their tributaries listed as impaired for bacteria (Category 4a or 5 Waters). This may include waters impaired for Fecal Coliform or Escherichia coli.o Note: Discharges to bacteria impaired waters will automatically be considered High Priority, based on guidance provided in Appendix H of the 2016 Permit


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https://www.mass.gov/lists/integrated-lists-of-waters-related-reports

https://docs.digital.mass.gov/dataset/massgis-data-designated-shellfish-growing-areas

https://docs.digital.mass.gov/dataset/massgis-data-public-water-supplies

https://docs.digital.mass.gov/dataset/massgis-data-protected-and-recreational-openspace

https://docs.digital.mass.gov/dataset/massgis-data-marine-beaches

Other: Discharges to waters or their tributaries listed as impaired for pollutants other than bacteria (Category 4a or 5 Waters). This does not include waters impaired for non-pollutants. None: Discharges to waters or their tributaries with no water quality impairments (Category 2 or 3 Waters)

5Discharges to waters with an approved TMDL where illicit discharges have the potential to contain the pollutant identified as the cause of the impairment. Listing of approved TMDLs can be found here: https://www.mass.gov/lists/total-maximum-daily-loads-by-watershed

6 Density of generating sites based on MassGIS Land Use layer: https://docs.digital.mass.gov/dataset/massgis-data-land-use-2005

High Density: Catchment area contains any of the following Land Use Codes = 10, Multi-Family Residential; 11, High Density Residential; 15, Commercial; 16, Industrial; 17, Transitional; 18, Transportation; 19, Waste Disposal; 31, Urban Public/Institutional; 36, Nursery; 39, Junkyard

o Note: Discharges with known sites with the high potential to generate pollutants that could contribute to illicit discharges within its catchment area should be included in this category. Examples include by are not limited to: car dealers, car washes, gas stations, garden centers, and industrial manufacturing areas.

Medium Density: 50% or more of catchment area is made of up of Land Use Codes = 5, Mining; 7, Participation Recreation; 8, Spectator Recreation; 9, Water-Based Recreation; 12, Medium Density Residential; 13, Low Density Residential; 26, Golf Course; 29, Marina Low Density: 50% or more of catchment area is made of up of Land Use Codes = 1, Cropland; 2, Pasture; 3, Forest; 4, Non-Forested Wetland; 6, Open Land; 14, Saltwater Wetland, 20, Water; 23, Cranberry Bog; 24, Powerline/Utility; 25, Saltwater Sandy Beach; 34,

Cemetery; 35, Orchard; 37, Forested Wetland; 38, Very Low Density Residential; 40, Brushland/Successional 7 Any river or stream that is culverted for distance greater than a simple roadway crossing (where information exists).

8 Additional Characteristics to be defined by the permittee. May be removed if data on additional characteristics are not available. Examples of additional characteristics include:

Age of infrastructure Historic combined sewer systems Age of surrounding septic systems Recent septic to sewer conversion areas


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https://docs.digital.mass.gov/dataset/massgis-data-land-use-2005

https://www.mass.gov/lists/total-maximum-daily-loads-by-watershed

6 Illicit Discharge Detection and Elimination Program

This section outlines the IDDE program to be implemented by ##MUNICIPALITY to comply with the 2016 MS4 Permit. This section reflects the requirements and timelines outlined in Sections 2.3.4.7 and 2.3.4.8 of the Permit. Field procedures are outlined in Section 7 of this document, including Field Work Safety Procedures in Section 7.4.

6.1 Dry Weather Outfall Screening and SamplingDry weather flow is a common indicator of potential illicit connections. The MS4 Permit requires all outfalls/interconnections (excluding Problem and excluded Outfalls) to be inspected for the presence of dry weather flow by three (3) years of the effective date of the permit (July 1, 2021). The ##AGENCY OR DEPARTMENT is responsible for conducting dry weather outfall screening, starting with High Priority outfalls, followed by Low Priority outfalls, based on the initial priority rankings described in the previous section.

In dry weather circumstances, the expected outcome is the storm drain systems will be dry (no flow). All No Flow observations must be documented. If water is flowing within a storm drain system during dry weather, the site must be monitored as indicated in the instructions outlined in Section 7.1.

All data collected as part of the dry weather outfall screenings will be recorded and reported in each annual report.

When flow is observed, samples shall be collected and analyzed for the following parameters:

ammonia, chlorine, conductivity, salinity, E. coli (freshwater receiving water) or enterococcus (saline or brackish receiving

water), surfactants (such as MBAS), temperature, and pollutants of concern (as indicated in the most recent 303(d) list)


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Section 7 provides detailed procedures for collecting and analyzing samples for the parameters listed above, including equipment to be used for each (provided in Table 7-1).

Previous outfall screening/sampling conducted under the 2003 MS4 Permit may be used to satisfy the dry weather outfall/screening requirements of the 2016 MS4 Permit only if the previous screening and sampling was substantially equivalent to that required by the 2016 MS4 Permit, including the list of analytes outlined in Section 2.3.4.7.b.iii.4 of the 2016 permit. The following sections include general information on dry weather screening and sampling, with more specific field work information presented in Section 7.

Dry Weather ConditionsDry weather outfall screening and sampling may occur when no more than 0.1 inches of rainfall has occurred in the previous 24-hour period and no significant snow melt is occurring. For purposes of determining dry weather conditions, program staff will use precipitation data from ##NAME OF WEATHER STATION. If ##NAME OF WEATHER STATION is not available or not reporting current weather data, then ##NAME OF WEATHER STATION will be used as a back-up.

Note: Because rainfall events can be localized, Field Team Leaders can also determine a monitoring event provided there is adequate notification to the ## STORMWATER PROGAM SUPERVISOR and the parameters regarding weather and tides are met.

Instructions: Choose a local weather station and back-up station(s) as necessary. At least one back-up station is recommended. Towns should select the closest weather station. The Weather Underground website serves as a good resource:

https://www.wunderground.com/weatherstation/overview.asp

Interpreting Outfall Sampling ResultsOutfall analytical data from dry weather sampling can be used to help identify the major type or source of discharge. Table 6-1 shows values identified by the U.S. EPA and the Center for Watershed Protection as typical screening values for select parameters. These represent the typical concentration (or value) of each parameter expected to be found in stormwater. Screening values that exceed these benchmarks may be indicative of pollution and/or illicit discharges.Illicit Discharge Detection and Elimination Plan

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https://www.wunderground.com/weatherstation/overview.asp

Table 6-1. Benchmark Field Measurements for Select Parameters

Analyte or Parameter Benchmark

Ammonia >0.5 mg/L

Conductivity >2,000 μS/cm

Surfactants >0.25 mg/L

Chlorine >0.02 mg/L

(detectable levels per the 2016 MS4 Permit)

Indicator Bacteria3:

E.coli

Enterococcus

E.coli: the geometric mean of the five most recent samples taken during the same bathing season shall not exceed 126 colonies per 100 ml and no single sample taken during the bathing season shall exceed 235 colonies per 100 ml

Enterococcus: the geometric mean of the five most recent samples taken during the same bathing season shall not exceed 33 colonies per 100 ml and no single sample taken during the bathing season shall exceed 61 colonies per 100 ml

Follow-up Ranking of Outfalls and InterconnectionsThe ##MUNICIPALITY will update and re-prioritize the initial outfall and interconnection rankings based on information gathered during dry weather screening. The rankings will be updated periodically as dry weather screening information becomes available but will be completed within three (3) years of the effective date of the permit (July 1, 2021).

Outfalls/interconnections where relevant information was found indicating sewer input to the MS4 or sampling results indicating sewer input are highly likely to contain illicit discharges from sanitary sources. Such outfalls/interconnections will be ranked at the

3 Massachusetts Water Quality Standards: http://www.mass.gov/eea/docs/dep/service/regulations/314cmr04.pdf Illicit Discharge Detection and Elimination Plan

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http://www.mass.gov/eea/docs/dep/service/regulations/314cmr04.pdf

top of the High Priority Outfalls category for catchment investigation. Other outfalls and interconnections may be re-ranked based on any new information from the dry weather screening.

6.2 Catchment InvestigationsThe MS4 permit requires catchment investigations for each outfall (except excluded ones). Any outfall with the potential for illicit discharges is defined as a problem outfall. Catchment investigations for problem outfalls are required to be completed within seven years of the permit effective date (June 30, 2025). All other outfalls need to have catchment investigations completed within 10 years of the permit effective date (June 30, 2028).

Catchment investigation techniques include but are not limited to review of maps, historic plans, and records; manhole observation; dry and wet weather sampling; video inspection; smoke testing; and dye testing. This section outlines a systematic procedure to investigate outfall catchments to trace the source of potential illicit discharges. All data collected as part of the catchment investigations will be recorded and reported in each annual report.

System Vulnerability FactorsThe ##AGENCY OR DEPARTMENT will review relevant mapping and historic plans and records to identify areas within the catchment with higher potential for illicit connections. The following information will be reviewed:

Plans related to the construction of the drainage network Plans related to the construction of the sewer drainage network Prior work on storm drains or sewer lines Board of Health or other municipal data on septic systems Complaint records related to SSOs Septic system breakouts.

Based on the review of this information, the presence of any of the following System Vulnerability Factors (SVFs) will be identified for each catchment:


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History of SSOs, including, but not limited to, those resulting from wet weather, high water table, or fat/oil/grease blockages

Common or twin-invert manholes serving storm and sanitary sewer alignments Common trench construction serving both storm and sanitary sewer alignments Crossings of storm and sanitary sewer alignments where the sanitary system is

shallower than the storm drain system Sanitary sewer alignments known or suspected to have been constructed with an

underdrain system Inadequate sanitary sewer level of service (LOS) resulting in regular surcharging,

customer back-ups, or frequent customer complaints Areas formerly served by combined sewer systems Sanitary sewer infrastructure defects such as leaking service laterals, cracked,

broken, or offset sanitary infrastructure, directly piped connections between storm drain and sanitary sewer infrastructure, or other vulnerability factors identified through Inflow/Infiltration Analyses, Sanitary Sewer Evaluation Surveys, or other infrastructure investigations

Sewer pump/lift stations, siphons, or known sanitary sewer restrictions where power/equipment failures or blockages could readily result in SSOs

Any sanitary sewer and storm drain infrastructure greater than 40 years old Widespread code-required septic system upgrades required at property transfers

(indicative of inadequate soils, water table separation, or other physical constraints of the area rather that poor owner maintenance)

History of multiple Board of Health actions addressing widespread septic system failures (indicative of inadequate soils, water table separation, or other physical constraints of the area rather that poor owner maintenance).

An SVF inventory will be documented for each catchment (see Table 6-2), retained as part of this IDDE Plan, and included in the annual report.

Table 6-2. Outfall Catchment System Vulnerability Factor (SVF) Inventory




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Instructions: Complete this System Vulnerability Factor tracking form or similar spreadsheet for all catchments being investigated (catchments of Problem, High-, and Low-Priority Outfalls).

History of

2

Common or Twin Invert Manholes

3

Common Trench Construction

4

Storm/Sanitary Crossings (Sanitary Above)

5

Sanitary Lines with Underdrains

6

Inadequate Sanitary Level of Service

7

Areas Formerly Served by Combined Sewers

8

Sanitary Infrastructure Defects

9

SSO Potential in Event of System Failures

Yes/No Yes/No Yes/No Yes/No Yes/No Yes/No Yes/No Yes/No

Presence/Absence Evaluation Criteria:

1. History of SSOs, including, but not limited to, those resulting from wet weather, high water table, or fat/oil/grease blockages

2. Common or twin-invert manholes serving storm and sanitary sewer alignments 3. Common trench construction serving both storm and sanitary sewer alignments 4. Crossings of storm and sanitary sewer alignments where the sanitary system is

shallower than the storm drain system 5. Sanitary sewer alignments known or suspected to have been constructed with an

underdrain system6. Inadequate sanitary sewer level of service (LOS) resulting in regular surcharging,

customer back-ups, or frequent customer complaints7. Areas formerly served by combined sewer systemsIllicit Discharge Detection and Elimination Plan

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8. Sanitary sewer infrastructure defects such as leaking service laterals, cracked, broken, or offset sanitary infrastructure, directly piped connections between storm drain and sanitary sewer infrastructure, or other vulnerability factors identified through Inflow/Infiltration Analyses, Sanitary Sewer Evaluation Surveys, or other infrastructure investigations

9. Sewer pump/lift stations, siphons, or known sanitary sewer restrictions where power/equipment failures or blockages could readily result in SSOs

10. Any sanitary sewer and storm drain infrastructure greater than 40 years old11. Widespread code-required septic system upgrades required at property transfers

(indicative of inadequate soils, water table separation, or other physical constraints of the area rather that poor owner maintenance)

12. History of multiple Board of Health actions addressing widespread septic system failures (indicative of inadequate soils, water table separation, or other physical constraints of the area rather that poor owner maintenance)


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Dry Weather Manhole InspectionsThe ## MUNICIPALITY will implement a dry weather storm drain network investigation that involves systematically and progressively observing, sampling and evaluating key junction manholes in the MS4 to determine the approximate location of suspected illicit discharges or SSOs.

The ##AGENCY OR DEPARTMENT will be responsible for implementing the dry weather manhole inspection program and making updates as necessary. Infrastructure information will be incorporated into the storm system map, and catchment delineations will be refined based on the field investigation, where necessary. The SVF inventory will also be updated based on information obtained during the field investigations, where necessary.

Field manhole inspection procedures are outlined in Section 7.2 of this plan.

6.3 Wet Weather Outfall SamplingWhere a minimum of one (1) System Vulnerability Factor (SVF) is identified based on previous information or the catchment investigation, a wet weather investigation must also be conducted at the associated outfall. Wet weather sampling at required outfalls must be completed within 10 years of the permit effective date (June 30, 2028). The ##AGENCY OR DEPARTMENT will be responsible for implementing the wet weather outfall sampling program and making updates as necessary.

Outfalls will be inspected and sampled under wet weather conditions, to the extent necessary, to determine whether wet weather-induced high flows in sanitary sewers or high groundwater in areas served by septic systems result in discharges of sanitary flow to the MS4.

At least one wet weather sample will be collected at the outfall for the same parameters required during dry weather screening (See Section 7).


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Wet Weather ConditionsWet weather sampling will occur during or after a storm event of sufficient depth or intensity to produce a stormwater discharge at the outfall. There is no specific rainfall amount that will trigger sampling, although minimum storm event intensities that are likely to trigger sanitary sewer interconnections are preferred. To the extent feasible, sampling should occur during the spring (March through June) when groundwater levels are relatively high. Additional information on Cape Cod groundwater levels can be obtained from the USGS (https://groundwaterwatch.usgs.gov/countymap.asp?sa=MA&cc=001) and Cape Cod Commission (www.capecodcommission.org).

Follow up Wet Weather Investigations If wet weather outfall sampling indicates a potential illicit discharge, then additional wet weather source sampling will be performed, as warranted, or source isolation and confirmation procedures will be followed as described in Section 6.4.

If wet weather outfall sampling does not identify evidence of illicit discharges, and no evidence of an illicit discharge is found during dry weather manhole inspections, catchment investigations will be considered complete.

6.4 Source Isolation and Confirmation Instructions: Include all relevant SOPs for specific tools such as dye testing and smoke testing, in Appendix F.

The CMRSWC “Locating Illicit Discharges SOP” provides suggested language for a source isolation and confirmation program.

http://centralmastormwater.org/Pages/crsc_toolbox/Locating%20Illicit%20Discharges%20SOP%20and%20Form_FINAL.pdf

Sample Smoke Testing SOP: ftp://ftp.ocfl.net/divisions/Utilities/pub/C%20I%20P/Specifications/Smoke%20Testing%20SOP.pdf

Sample Dye Testing SOP:

http://www.oseh.umich.edu/pdf/guideline/dye_testing_guideline.pdf


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http://www.oseh.umich.edu/pdf/guideline/dye_testing_guideline.pdf

ftp://ftp.ocfl.net/divisions/Utilities/pub/C%20I%20P/Specifications/Smoke%20Testing%20SOP.pdf

ftp://ftp.ocfl.net/divisions/Utilities/pub/C%20I%20P/Specifications/Smoke%20Testing%20SOP.pdf



http://www.capecodcommission.org/

https://groundwaterwatch.usgs.gov/countymap.asp?sa=MA&cc=001

https://groundwaterwatch.usgs.gov/countymap.asp?sa=MA&cc=001

Once the source of an illicit discharge is approximated between two manholes, more detailed investigation techniques will be used to isolate and confirm the source of the illicit discharge. The following methods may be used in isolating and confirming the source of illicit discharges

Sandbagging Smoke Testing Dye Testing CCTV/Video Inspections Optical Brightener Monitoring IDDE Canines

These methods are described in the sections below. Instructions and Standard Operating Procedures (SOPs) for these and other IDDE methods are provided in Appendix F.

Public notification is an important aspect of a detailed source investigation program. Prior to smoke testing, dye testing, or TV inspections, the ##AGENCY OR DEPARTMENT will notify property owners in the affected area. Smoke testing notification will include ##ROBOCALLS, ##HANGING NOTIFICATIONS, ## EMAIL for single family homes, businesses and building lobbies for multi-family dwellings.

SandbaggingThis technique can be particularly useful when attempting to isolate intermittent illicit discharges or those with very little perceptible flow. The technique involves placing sandbags or similar barriers (e.g., caulking, weirs/plates, or other temporary barriers) within outlets to manholes to form a temporary dam that collects any intermittent flows that may occur. Sandbags are typically left in place for 48 hours and should only be installed when dry weather is forecast. If flow has collected behind the sandbags/barriers after 48 hours, it can be assessed using visual observations or by sampling. If no flow collects behind the sandbag, the upstream pipe network can be ruled out as a source of the intermittent discharge. Finding appropriate durations of dry weather and the need for multiple trips to each manhole makes this method both time-consuming and somewhat limiting.


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Smoke TestingSmoke testing involves injecting non-toxic smoke into drain lines and noting the emergence of smoke from sanitary sewer vents in illegally connected buildings or from cracks and leaks in the system itself. Typically, a smoke bomb or smoke generator is used to inject the smoke into the system at a catch basin or manhole and air is then forced through the system. Test personnel are place in areas where there are suspected illegal connections or cracks/leaks, noting any escape of smoke (indicating an illicit connection or damaged storm drain infrastructure). It is important when using this technique to make proper notifications to area residents and business owners as well as local police and fire departments.

If the initial test of the storm drain system is unsuccessful then a more thorough smoke-test of the sanitary sewer lines can also be performed. Unlike storm drain smoke tests, buildings that do not emit smoke during sanitary sewer smoke tests may have problem connections and may also have sewer gas venting inside, which is hazardous.

It should be noted that smoke may cause minor irritation of respiratory passages. Residents with respiratory conditions may need to be monitored or evacuated from the area of testing altogether to ensure safety during testing.

Dye TestingDye testing involves flushing non-toxic dye into plumbing fixtures such as toilets, showers, and sinks and observing nearby storm drains and sewer manholes as well as stormwater outfalls for the presence of the dye. Similar to smoke testing, it is important to inform local residents and business owners. Police, fire, and local public health staff should also be notified prior to testing in preparation of responding to citizen phone calls concerning the dye and their presence in local surface waters.

A team of two or more people is needed to perform dye testing (ideally, all with two-way radios). One person is inside the building, while the others are stationed at the appropriate storm sewer and sanitary sewer manholes (which should be opened) and/or outfalls. The person inside the building adds dye into a plumbing fixture (i.e., toilet or sink) and runs a sufficient amount of water to move the dye through the plumbing system. The person inside the building then radios to the outside crew that the dye has been dropped, and the outside crew watches for the dye in the storm sewer and sanitary sewer, recording the presence or absence of the dye. The test can be relatively quick (about 30 minutes per test), effective (results are usually definitive), and


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inexpensive. Dye testing is best used when the likely source of an illicit discharge has been narrowed down to a few specific houses or businesses.

CCTV/Video InspectionAnother method of source isolation involves the use of mobile video cameras that are guided remotely through stormwater drain lines to observe possible illicit discharges. IDDE program staff can review the videos and note any visible illicit discharges. While this tool is both effective and usually definitive, it can be costly and time consuming when compared to other source isolation techniques.

Optical Brightener MonitoringOptical brighteners are fluorescent dyes that are used in detergents and paper products to enhance their appearance. The presence of optical brighteners in surface waters or dry weather discharges suggests there is a possible illicit discharge or insufficient removal through adsorption in nearby septic systems or wastewater treatment. Optical brightener monitoring can be done in two ways. The most common, and least expensive, methodology involves placing a cotton pad in a wire cage and securing it in a pipe, manhole, catch basin, or inlet to capture intermittent dry weather flows. The pad is retrieved at a later date and placed under UV light to determine the presence/absence of brighteners during the monitoring period. A second methodology uses handheld fluorometers to detect optical brighteners in water sample collected from outfalls or ambient surface waters. Use of a fluorometer, while more quantitative, is typically more costly and is not as effective at isolating intermittent discharges as other source isolation techniques.

IDDE CaninesDogs specifically trained to smell human related sewage are becoming a cost-effective way to isolate and identify sources of illicit discharges. While not widespread at the moment, the use of IDDE canines is growing as is their accuracy. The use of IDDE canines is not recommended as a standalone practice for source identification; rather it is recommended as a tool to supplement other conventional methods, such as dye testing, in order to fully verify sources of illicit discharges.

6.5 Illicit Discharge RemovalWhen the specific source of an illicit discharge is identified, the ##MUNICIPALITY will exercise its authority as necessary to require its removal. The annual report will include the status of IDDE investigation and removal activities including the following information for each confirmed source:


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The location of the discharge and its source(s) A description of the discharge The method of discovery Date of discovery Date of elimination, mitigation or enforcement action OR planned corrective

measures and a schedule for completing the illicit discharge removal Estimate of the volume of flow removed.

Confirmatory Outfall Screening Within one (1) year of removal of all identified illicit discharges within a catchment area, confirmatory outfall or interconnection screening will be conducted. The confirmatory screening will be conducted in dry weather unless System Vulnerability Factors have been identified, in which case both dry weather and wet weather confirmatory screening will be conducted. If confirmatory screening indicates evidence of additional illicit discharges, the catchment will be scheduled for additional investigation.

6.6 Ongoing ScreeningUpon completion of all catchment investigations and illicit discharge removal and confirmation (if necessary), each outfall or interconnection will be re-prioritized for screening and scheduled for ongoing screening once every five (5) years. Ongoing screening will consist of dry weather screening and sampling consistent with the procedures described in Section 7 of this plan. Ongoing wet weather screening and sampling will also be conducted at outfalls where wet weather screening was required due to System Vulnerability Factors (Section 6.2) and will be conducted in accordance with the procedures described in Section 7. All sampling results will be reported in the annual report.


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7 Field Screening and Sampling ProceduresThis section outlines specific field procedures to be followed during IDDE sampling, screening, and investigation work required by the MS4 Permit, as described in the previous sections. Closely following these procedures is important for the collection of consistent and high-quality data. Additionally, this section outlines necessary equipment and safety considerations for field work.

7.1 Dry Weather Screening/Sampling ProceduresInstructions: The dry weather screening and sampling procedures described in this section are based on the requirements outlined in the 2016 MS4 Permit. The CMRSWC “SOP1: Dry Weather Outfall Inspection” provides additional suggestions for carrying out a screening/sampling program. http://centralmastormwater.org/Pages/crsc_toolbox/Dry%20Outfall%20Inspection%20SOP%20and%20Form_Final.pdf

Municipalities should include example Sample Labels, Field Sheets and Chain of Custody forms in the appendices of the IDDE Plan. Additional guidance is provided in each appendix.

Pre-Sampling Procedure1. Ice: Prepare a freezer “ice pack,” and store it in your freezer.2. Paperwork/Data Entry: Fill out as much of the data sheet as possible prior to

leaving vehicle at each station, including date and location. A sample inspection form is provided in Appendix C

3. Equipment Check: Check through your storage bin/equipment to be sure that you have everything and that it is all in good working order (e.g. test your flashlight). See Table 7.4 for a checklist of equipment.

4. Equipment Calibration: Calibrate Conductivity/Salinity/Temperature/pH meter(s) every three weeks (see below). If meters have not been used in a while, fill meter cup with de-ionized water, put meter electrodes in cup, allow to soak for 2 minutes. Calibration instructions are included in Appendix D.

Sampling ProcedureThe dry weather outfall inspection and sampling procedure consists of the following general steps. A sample inspection form is provided in Appendix C.

1. Identify outfall(s) to be screened/sampled based on initial outfall inventory and priority ranking.


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http://centralmastormwater.org/Pages/crsc_toolbox/Dry%20Outfall%20Inspection%20SOP%20and%20Form_Final.pdf

http://centralmastormwater.org/Pages/crsc_toolbox/Dry%20Outfall%20Inspection%20SOP%20and%20Form_Final.pdf

2. Acquire the necessary staff, mapping, and field equipment (see Table 7.4 for list of potential field equipment).

3. Using paper maps and/or tablet, carefully determine the location of the Facility ID for the discharge pipe to be sampled. Take notes on condition and maintenance requirements of discharge location, and any access or parking requirements. Take notes regarding observations (trash, waste products, unusual color or sheen) or smells. Observe discharge and tide, make estimate of tidal condition (high, mid, low). In the event that an outfall is submerged, either partially or completely, or inaccessible, field staff will proceed to the first accessible upstream manhole (MH) for the observation and sampling and report the location with the screening results. If the storm drain system does not have MHs, go to the first upstream catch basin (CB) or structure. Use Outfall Notes as a guide for deciding the correct MH or CB. If a monitoring site is in inaccessible, the Field Team should make a note as to the reason. Examples: embankment too steep, fenced private property, excessive brush, unable to remove cover or grate, sediment in sump. Obstructions that can be removed, but require additional tools or support (brush, covers, grates, sediment) should be removed by the DPW before the next monitoring event. If discharge pipe is partially blocked with sediment or land that can be easily removed, remove blockage and let stormwater flow out for a few minutes before taking samples.

4. Field staff will continue to the next upstream structure until there is no longer an influence from the receiving water on the visual inspection or sampling.

5. Begin filling out Water Quality Sampling Sheet, Confirm Facility ID on Sampling Sheet with Location Map. Fill out as much of the information as possible before beginning sampling. Draw a Sketch Location. Each Sampling Sheet must have a Station Sketch to determine the location of the actual monitoring site (CBs and MHs can have more than one pipe associated with them).

6. Conduct the outfall inspection during dry weather. If sampling at a MH or CB:a. Mark and photograph the outfallb. Public Works staff should remove cover or grate and place off to the side

(see Section 7.4: Field Work Safety Procedures). Using flashlight, look inside MH (but do not place head inside MH), make notes regarding condition of MH (presence of sump, presence of sediment, functioning, cracks, etc.) in comment section. If available use carpenter’s ruler or measuring device to approximate the amount of sediment in sump, make notation in comment section and then rinse ruler off.

c. Record the inspection information and outfall characteristics (using paper forms or digital form using a tablet or similar device) (see form in Appendix C). Draw sketch of inlet pipes entering MH or CB both from other MHs or CBs and location of discharge pipe. Label pipes on sketch in accordance with Instructions for Sampling Form page 17). Note if the


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pipes are free-flowing, partially-submerged or submerged. If Free-flowing, estimate how much of the pipe is flowing (<1/10, 1/4, 1/2, 3/4, or full).

d. Look for and record visual/olfactory evidence of pollutants in flowing outfalls including odor, color, turbidity, and floatable matter (suds, bubbles, excrement, toilet paper or sanitary products). Also observe outfalls for deposits and stains, vegetation, and damage to outfall structures.

e. If no flow is observed , but evidence of illicit flow exists (illicit discharges are often intermittent or transitory), revisit the outfall during dry weather within one week of the initial observation, if practicable, to perform a second dry weather screening and sample any observed flow. Other techniques can be used to detect intermittent or transitory flows including conducting inspections during evenings or weekends and using optical brighteners. If flow is observed, sample and test the flow following the procedures described in the following steps:

i. Fill out all sample information on sample bottles, container labels, and field sheets (see Appendix C for Sample Labels and Field Sheets). Make sure Sample ID on containers is the same as the Sample ID on Sampling Sheet. Sample information should also clearly indicate which structure the sample is being collected at.

ii. Place labels onto the 100ml (bacteria) and 500ml containers and label tape on the 125ml contain. No labeling or sample marking shall be applied to lids, only to the body of the sampling container.

iii. Put on protective gloves (nitrile/latex/other) before sampling.iv. Sample Collection: Start each sample collection with a sterile

100ml bottle (for bacteria). Make sure not to touch bottle opening or inside cap lid during sample collection. If cap needs to be on the ground during sample, make sure it is placed cap up and preferably on a solid surface (rock, sand, road surface, etc.) and out of rain.

v. Collect sample with dipper or directly in sample containers. If possible, collect water from the flow directly in the sample bottle. Be careful not to disturb sediments. If easily accessible, collect sample from the discharge pipe (or roadcut or flowing inlet pipes in CB or MH) directly into the 100ml bottle. If submerged or partially submerged pipes appear to be flowing, take a sample as close to the pipe as possible.

vi. If flowing inlet pipes are not easily accessible (MH or CB only), use sample pole (dipper or other device) and 100ml bottle to collect samples. Triple rinse the device with distilled water and then in water to be sampled (not for bacteria sampling). Place bottle into


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holder attached to bottom of pole and uncap. Lower pole into MH or CB, trying not to touch sides of MH or CB. If contact with MH or CB wall cannot be avoided, make a note in the comment section.

vii. To collect from a free-flowing pipe, tilt the bottle towards the water while avoiding collecting any "sump water" (NOTE: if sump water cannot be avoided, make a note in the comment section). To collect from a submerged or partially submerges pipe, tilt the bottle and collect sample as close to the pipe as possible. Even though the assumption is the sample will contain sump water, make a note in the comment section that the sample is a mixture of pipe and sump water.

viii. Once the 100ml bottle is filled bring the bottle to the surface, replace lid and put in cooler. Then fill the 125ml (clean) container, use the water in this bottle for on-site field testing. Tests should be done in this order Conductivity/Temperature/Salinity/pH, and then Ammonia and Chlorine. Once Field Tests are completed cap bottle and place in cooler for offsite testing. Collect any other laboratory analysis samples in a clean 500 ml bottle, cap and place in cooler. Use test strips, test kits, and field meters (rinse similar to dipper) for most parameters (see Table 7-1 and Table 7-2).

ix. If more than 1 free-flowing inlet pipe in CB or MH, repeat steps above for each flowing inlet pipe. Use a new sterile container for bacteria and a clean 125ml and 500ml bottle for each pipe. Collect samples from all free-flowing inlet pipes (stations on Sampling Sheet) found in MHs or CBs. Fill all the bottles and containers and complete all the field tests (conductivity/temperature/salinity, pH, and ammonia) for each station within the MH or CB before starting the next station in the same MH or CB.

x. Place laboratory samples on ice for analysis of bacteria and pollutants of concern.

xi. Fill out chain-of-custody form (Appendix C) for laboratory samples, record Time Depart on Sampling Sheet.

xii. Deliver samples to Barnstable County Water Quality Laboratory, 3195 Main Street, Barnstable, MA 02630.

xiii. Dispose of used test strips and test kit ampules properly.xiv. Decontaminate all testing personnel and equipment.

7. Input results from screening and sampling into spreadsheet/database. Include pertinent information in the outfall/interconnection inventory and priority ranking.

8. Include all screening data in the annual report.


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General ProceduresInstructions: Towns should make this and following sections more specific based on use of paper, tablet, or other means of data recording, staff responsibilities, procedures, equipment, and any other details.

Recording Data and Chain of Custody: All data and field observations are recorded on ##water quality sampling sheet or tablet##. The sampling sheet will be printed on waterproof paper making it easier to record data during rainy weather. Once monitoring is completed, all sampling sheets will be signed by the Field Team Leader (Chain of Custody) and given to the ##STORMWATER PROGRAM SUPERVISOR. The ## STORMWATER PROGRAM SUPERVISOR will also sign the sampling sheets when samples are taken from the Field Team Leaders. If feasible, copies will be made of the sampling sheets before the samples are transported to the Barnstable County Laboratory. Once the samples are delivered to the lab, the sampling sheet or a Chain of Custody Form supplied by the laboratory will be signed by lab personnel with a copy remaining with the lab. The original sampling sheet and the Chain of Custody Form will be returned to the Town. The conducted offsite testing will be recorded on the original sampling sheet, which will then be filed at the Town office as part of the permanent record for the individual monitored site.

Bottles and Laboratory Containers: Organize sample bottles and laboratory containers. For each sampling site, there should be a minimum of two containers or bottles, a 100 ml container for bacteria and a 125 ml container for in-the-field and office testing. Additional 500 ml bottles may also be utilized at the discretion of the sampler (discharges flowing into impaired waters requiring pollutant of concern samples). Attach a sampling label to all bottles and containers requiring laboratory analysis (100 and 500ml). To the "in-the-field/office" containers (125ml), affix a piece of labeling tape to the container and label with the Sample ID. A sample container label is included in Appendix C.

Use a sharpie permanent marker to label all appropriate information Identify the correct laboratory analysis for the individual containers/bottles, the 100ml is for bacteria, the 500 ml is for all others. Be sure that the location from which the sample is being collected matches the identification on the bottle (i.e. don’t grab the wrong bottle when you are out sampling.).

Each sampled discharge pipe, inlet pipe or sump sample will involve at least 2 bottles, one sterile 100 ml bottle for bacteria (lab analysis) and one 125 ml container (for on-site


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and off-site testing). The Field Teams must use a sterile 100 ml bottle at each discharge pipe, inlet pipe and or sump. These bottles should not be reused. At the discretion of the sampler, additional samples for laboratory analysis may also be collected (500 ml bottles). Duplicate samples are recommended for each site.

All meters (Conductivity, pH) must be rinsed three times with de-ionized water, wiped dry and capped between uses.

All samplers must wear clean nitrile gloves prior to collecting samples. The gloves must be changed for each new sample taken. Place used gloves in trash bag.

Sample Collection and AnalysisIf flow is present during a dry weather outfall inspection, a sample will be collected and analyzed for the required permit parameters listed in Table 7-1.4

Field test kits or field instrumentation are permitted for all parameters except indicator bacteria and any pollutants of concern. Field kits need to have appropriate detection limits and ranges. Table 7-1 lists various field test kits and field instruments that can be used for outfall sampling associated with the 2016 MS4 Permit parameters, with the exceptions of indicator bacteria and any pollutants of concern. Analytic procedures and user’s manuals for field test kits and field instrumentation are provided in Appendix D.

Table 7-5. Sampling Parameters and Analysis Methods

Analyte or Parameter

Instrumentation (Portable Meter) Field Test Kit

Ammonia CHEMetrics™ V-2000 ColorimeterHach™ DR/890 Colorimeter

Hach™ Pocket Colorimeter™ II

CHEMetrics™ K-1410

CHEMetrics™ K-1510 (series)

Hach™ NI-SA

Hach™ Ammonia Test Strips

4 Other potentially useful parameters, although not required by the MS4 Permit, include fluoride (indicator of potable water sources in areas where water supplies are fluoridated), potassium (high levels may indicate the presence of sanitary wastewater), and optical brighteners (indicative of laundry detergents).Illicit Discharge Detection and Elimination Plan

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Surfactants (Detergents)

CHEMetrics™ I-2017 CHEMetrics™ K-9400 and K-9404 Hach™ DE-2

Chlorine CHEMetrics™ V-2000, K-2513

Hach™ Pocket Colorimeter™ II

Hach™ Ammonia Test Strips

CHEMetrics I-2001

Conductivity CHEMetrics™ I-1200YSI Pro30YSI EC300AOakton 450

Pocket Pro™+ Multi 2

Exstick II

Oakton PCTSTestr 50

NA

Temperature YSI Pro30YSI EC300AOakton 450


Exstick II

Oakton PCTSTestr 50

NA

Salinity YSI Pro30YSI EC300AOakton 450


Exstick II

Oakton PCTSTestr 50

NA

pH YSI Pro30YSI EC300AOakton 450


NA


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Hach™ Pocket Pro pH Tester

Indicator Bacteria:

E. coli (freshwater) or Enterococcus (saline water)

EPA certified laboratory procedure (40 CFR § 136)

NA

Pollutants of Concern1

EPA certified laboratory procedure (40 CFR § 136)

NA

1 Where the discharge is directly into a water quality limited water or a water subject to an approved TMDL, the sample must be analyzed for the pollutant(s) of concern identified as the cause of the water quality impairment.

Testing for indicator bacteria and any pollutants of concern must be conducted using analytical methods and procedures found in 40 CFR § 136.5 Samples for laboratory analysis must also be stored and preserved in accordance with procedures found in 40 CFR § 136. Table 7-2 lists analytical methods, detection limits, hold times, and preservatives for laboratory analysis of dry weather sampling parameters.

Table 7-6. Required Analytical Methods, Detection Limits, Hold Times, and Preservatives4


Analytical Method Detection Limit Max. Hold

Time Preservative

Ammonia EPA: 350.2, SM: 4500-NH3C

0.05 mg/L 28 days Cool ≤6°C, H2SO4 to pH <2, No preservative required if analyzed immediately

5 40 CFR § 136: http://www.ecfr.gov/cgi-bin/text-idx?SID=b3b41fdea0b7b0b8cd6c4304d86271b7&mc=true&node=pt40.25.136&rgn=div5Illicit Discharge Detection and Elimination Plan

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http://www.ecfr.gov/cgi-bin/text-idx?SID=b3b41fdea0b7b0b8cd6c4304d86271b7&mc=true&node=pt40.25.136&rgn=div5

http://www.ecfr.gov/cgi-bin/text-idx?SID=b3b41fdea0b7b0b8cd6c4304d86271b7&mc=true&node=pt40.25.136&rgn=div5



Time Preservative

Surfactants SM: 5540-C 0.01 mg/L 48 hours Cool ≤6°C

Chlorine SM: 4500-Cl G 0.02 mg/L Analyze within 15 minutes

None Required

Temperature SM: 2550B NA Immediate None Required

Specific Conductance

EPA: 120.1, SM: 2510B

0.2 µs/cm 28 days Cool ≤6°C

Salinity SM: 2520 - 28 days Cool ≤6°C

Indicator Bacteria:

E.coli

Enterococcus

E.coli

EPA: 1603

SM: 9221B, 9221F , 9223 B

Other: Colilert ®,

Colilert-18®

Enterococcus

EPA: 1600

SM: 9230 C

Other: Enterolert®

E.coli

EPA: 1 cfu/100mL

SM: 2 MPN/100mL

Other: 1 MPN/100mL

Enterococcus

EPA: 1 cfu/100mL

SM: 1 MPN/100mL

Other: 1 MPN/100mL

8 hours

Cool ≤10°C, 0.0008% Na2S2O3

Total Phosphorus

EPA: Manual-365.3, Automated Ascorbic acid digestion-365.1 Rev. 2, ICP/AES4-200.7 Rev. 4.4

EPA: 0.01 mg/L

SM : 0.01 mg/L

28 days Cool ≤6°C, H2SO4 to pH <2


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Time Preservative

SM: 4500-P E-F

Total Nitrogen (Ammonia + Nitrate/Nitrite, methods are for Nitrate-Nitrite and need to be combined with Ammonia listed above.)

EPA: Cadmium reduction (automated)-353.2 Rev. 2.0, SM: 4500-NO3 E-F

EPA: 0.05 mg/L

SM : 0.05 mg/L

28 days Cool ≤6°C, H2SO4 to pH <2

SM = Standard Methods

7.2 Catchment Investigation ProceduresFor all catchments identified for investigation, during dry weather, field crews will systematically inspect key junction manholes for evidence of illicit discharges. This program involves progressive inspection and sampling at manholes in the storm drain network to isolate and eliminate illicit discharges.

Several important terms related to the dry weather manhole inspection program are defined by the MS4 Permit as follows:

Junction Manhole is a manhole or structure with two or more inlets accepting flow from two or more MS4 alignments. Manholes with inlets solely from private storm drains, individual catch basins, or both are not considered junction manholes for these purposes.

Key Junction Manholes are those junction manholes that can represent one or more junction manholes without compromising adequate implementation of the illicit discharge program. Adequate implementation of the illicit discharge program would not be compromised if the exclusion of a particular junction manhole as a key junction manhole would not affect the permittee’s ability to


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determine the possible presence of an upstream illicit discharge. A permittee may exclude a junction manhole located upstream from another located in the immediate vicinity or that is serving a drainage alignment with no potential for illicit connections.

The manhole inspection methodology will be conducted in one of two ways (or a combination of both):

By working progressively up from the outfall and inspecting key junction manholes along the way, or

By working progressively down from the upper parts of the catchment toward the outfall.

For most catchments, manhole inspections will proceed from the outfall moving up into the system.

However, the decision to move up or down the system depends on the nature of the drainage system and the surrounding land use and the availability of information on the catchment and drainage system. Moving up the system can begin immediately when an illicit discharge is detected at an outfall, and only a map of the storm drain system is required. Moving down the system requires more advance preparation and reliable drainage system information on the upstream segments of the storm drain system but may be more efficient if the sources of illicit discharges are believed to be located in the upstream portions of the catchment area. Once a manhole inspection methodology has been selected, investigations will continue systematically through the catchment.

Inspection of key junction manholes will proceed as follows:

1. Manholes will be opened and inspected for visual and olfactory evidence of illicit connections. A sample field inspection form is provided in Appendix C.

2. If flow is observed, a sample will be collected and analyzed at a minimum for ammonia, chlorine, and surfactants. Field kits can be used for these analyses. Sampling and analysis will be in accordance with procedures outlined in Section


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7-1. Additional indicator sampling may assist in determining potential sources (e.g., bacteria for sanitary flows, conductivity to detect tidal backwater, etc.).

3. Where sampling results or visual or olfactory evidence indicate potential illicit discharges or SSOs, the area draining to the junction manhole will be flagged for further upstream manhole investigation and/or isolation and confirmation of sources.

4. Subsequent key junction manhole inspections will proceed until the location of suspected illicit discharges or SSOs can be isolated to a pipe segment between two manholes.

5. If no evidence of an illicit discharge is found, catchment investigations will be considered complete upon completion of key junction manhole sampling.

7.3 Wet Weather Sampling ProceduresFor each catchment where one or more SVF has been identified, outfall sampling during wet weather must be completed. The same procedures for sample collection should be followed as outlined in Section 7.1. During wet weather sampling, flow should always be present. Weather considerations outlined in Section 6.1 should be followed to ensure sampling is conducted during the appropriate conditions to meet MS4 Permit requirements.

7.4 Field Work Safety ProceduresInstructions: Towns should update this information with any town-specific information, such as safety protocols, emergency personnel contact information, and safety trainings. Towns should include information about safety trainings that will be provided for field crews on an annual basis prior to sampling season (spring of each year) and safety reminders (i.e. tail gate sessions) throughout the field season.

The collection of monitoring data, including dry and wet weather data, will be acquired only under safe conditions. Please read the following safety precautions carefully prior to field efforts.

In the event of a medical emergency: Contact appropriate emergency personnel first and/or dial 911.


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Table 7-3. Standard Operating Safety ProceduresHazard Standard Operating Procedure

Heat Stress Wear breathable protective clothing. Take frequent breaks in hot weather and ensure that you have adequate amount of drinking water on hand.

Slips/trips/falls Personnel will wear boots or waders that provide suitable mobility and traction.

Drowning Personnel will not enter fast-flowing water that is greater than knee deep.

Caught-in Mud Personnel will not enter into areas of thick or deep mud along shorelines where it is possible to be stuck. Test all areas with pole/stick prior to entering.

Confined Space Entry

Permitted for Trained Municipal Maintenance staff only. Under no circumstances will untrained municipal staff or any other agency staff, intern or volunteer will enter a confined space. Confined space is a term from labor safety regulations that refers to an area which is enclosed with limited access which make it dangerous. An example is the interior of a storage tank, manhole, culvert, which workers may enter for maintenance, but which is not ordinarily a habitable space.

Insects General Hazards

Personnel will wear long-sleeved shirts and pants during fieldwork. Insect repellant will be applied prior to field work and reapplied as needed throughout duration of work. Mosquitos DEET – recommended mosquito repellent. 50% concentration recommended reapplication as needed.

Wasps & Bees Remain calm; try not to disturb nest areas. If stung, remove stinger with tweezers or other blunt object (such as credit card) against sting site.

Ticks

Wear light-colored protective clothing such as long sleeve pants, shirts & head coverings. Tuck pants into socks and tape at seam to keep ticks away from skin. Use permethrin-based spray onto clothes and shoes to repel ticks (do not apply directly to skin). Do a thorough tick-check following field-based work.

Noxious Plants (poison ivy, poison oak, poison sumac)

Personnel will wear long-sleeved shirts and pants during fieldwork. Use commercially available pre-contact skin protectant towelettes or barrier cream. Exposed skin will be washed as soon as possible with dish soap & water or commercially available post exposure scrub wash products to remove the oil. Use gloves to remove exposed clothes & shoes.


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Hazard Standard Operating Procedure

Seek medical attention if conditions worsen.

Working On, Over, or Near WaterNote: Normal monitoring events may require the use of (knee-high) waders. Any sampling that requires "above the knees" waders or utilization of a boat, is considered hazardous and should not be attempted without the direct supervision and/or approval of the ##STORMWATER PROGRAM SUPERVISOR. If municipal staff or volunteers will be working over or near water where a risk of drowning could occur (per OSHA > 2 feet deep), then employees and volunteers must be provided with and use United States Coast Guard (USCG) approved personal flotation devices (PFDs, i.e., life jackets).

Noise Exposure / Hearing ConservationNote: Normal monitoring events will not require the collection of samples at or near construction sites. If samples are needed on or through a construction site, ##STORMWATER PROGRAM SUPERVISOR will obtain permission from the property owner and/or construction supervisor. When monitoring at or near a construction site, Field Teams must wear appropriate safety gear/ equipment including but not limited to hard hat, safety vest and hearing protection devices (ear plugs and/or muffs).

Weather-Related HazardsIn addition to heat and cold temperatures, weather-related hazards should be anticipated, and appropriate protective measures must be taken. Given the multi-season work schedule and unpredictable New England weather, adverse weather should be anticipated. Field teams should always re-check the weather forecast prior to each sampling event. The following are some possible weather-related hazards and protective measures:

Lightning - Do not work during electrical storms. Stay off high areas (e.g., top of the landfill) and hazardous areas (e.g., on water) that attract lightning.

Hurricane/Tornado/Flash Flooding/Hail/Hazardous Weather-Do not schedule monitoring when weather reports indicate potential high winds, excessive rains, flash flooding, hail, hurricane or tornado warnings or watches. If weather becomes hazardous during monitoring, the Field Team Leader should stop all monitoring activities and send Field Teams to an appropriate safety location.

Reagents for Field Test KitsThe handling of certain reagents may be required for field test kits, such as test kits for Surfactants and the Chlorine colorimeter. When handling and use is required, ensure that the user has reviewed the Safety Data Sheet, is aware of the associated hazards Illicit Discharge Detection and Elimination Plan

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and first aid measures, and that the appropriate personal protective equipment is selected and used.

Roadway Infrastructure Safety AwarenessField Teams may work in areas that are in close proximity to roadways, parking lots, or associated with the highway infrastructure (e.g., bridges, tunnels). Under no circumstances will Field Teams acquire samples within MassDOT road infrastructure without the direct supervision and/or approval of the ##STORMWATER PROGRAM SUPERVISOR .

Monitoring within municipal infrastructure, Field Teams may be exposed to hazards both inside and outside the work zone. Depending on the specific project and work task, this may include the risk of injury from passing motor vehicle traffic as well as the potential risk from the movement of construction vehicles and equipment near the work zones (very rare).

When working alongside of roadways:

1. Locate a safe place to park vehicles for each sampling site.2. If practical, park appropriate municipal maintenance vehicles between on-coming

traffic and work area to serve as a warning barricade.3. Use temporary traffic control devices, such as cones, signage, warning devices,

barricades, and similar whenever necessary based on the type and location of work to be performed, the duration of operations, time of day, the characteristics of the roadway, and/or the volume and speed of traffic.

4. Wear high visibility safety apparel at all times during sampling. This safety apparel must be inspected regularly to ensure that color has not faded and that reflective properties have not been lost.

5. Always use extreme care when sampling at the edge of a roadway or bridge with guard rails, stonewalls, etc. Test railing firmly before leaning out over them.

When working within the road infrastructure (manholes and catch basins):

1. Removal and placement of manhole and catch basin covers is to be considered hazardous and is the responsibility of Trained Municipal Maintenance staff only. Under no circumstance will untrained municipal staff, interns, or volunteers engage in the removal of such covers.


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2. Use extreme caution when removing manhole and catch basin covers as they are they are very heavy and require a pick or lifting device. Wear heavy-duty gloves and hard-toed boots to protect fingers and toes. Make sure on-coming traffic has plenty of visual warnings and traffic cones/ signs to alert drivers of crew members on and along the roadway.

3. When lifting a manhole or catch basin covers always use proper lifting techniques when in the field. Never lift more than you are capable of lifting. Follow the lifting techniques below:

a. First, test the weight of the load by tipping it. If in doubt, ask for help. Do not attempt to lift a heavy load alone.

b. Take a good stance. Plant your feet firmly with legs apart, one foot farther back than the other. Make sure you stand on a level area with no slippery spots or loose gravel, etc.

c. Get a firm grip. Use as much of your hands as possible, not just your fingers.

d. Keep your back straight, almost vertical. Bend at the hips if you bend.e. Hold load close to your body. Keep the weight of your body over your feet

for good balance.f. Use large leg muscles to lift. Push up with the foot positioned in the rear

as you start to lift.g. Lift steadily and smoothly. Avoid quick, jerky movements.h. Avoid twisting motions. Turn the forward foot and point it in the direction

of the eventual movement.i. Never try to lift more than you are accustomed to.j. Always get help when you have to lift bulky loads.

7.5 Field EquipmentInstructions: Towns should update this field equipment list as applicable. In particular, if towns are using tablets for data entry (recommended), some of the paper supplies are likely not necessary. If tablets are not being used, the paper supplies and associated tools (e.g., clipboard) will be necessary.

Table 7-4 lists field equipment commonly used for outfall screening and sampling.


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Table 7-4. Field Equipment – Outfall Screening and Sampling

Testing Equipment

Check

Equipment Use/Notes

ammonia test strips (or kits) Have extra kits on hand to sample more outfalls than are anticipated to be screened in a single day

chlorine test strips (or kits) Have extra kits on hand to sample more outfalls than are anticipated to be screened in a single day

conductivity, salinity, pH and temperature meter (sonde)

Hand held meter, if available, for testing for various water quality parameters such as ammonia, surfactants and chlorine and if needed, for sampling conductivity, temperature, pH

Sampling Equipment

Check

Equipment Use/Notes

map with sampling location and Facility ID's (if not using tablet)

For orientation

GPS receiver (tablet or handheld GPS) For taking spatial location data

clipboard (if not using tablet) For organization of field sheets and writing surface

100 ml pre-labeled laboratory bacteria sample bottles (bacteria)

Make sure all sample containers are clean. Keep extra sample containers on hand at all times. Make sure there are proper sample

500 ml pre-labeled laboratory bacteria sample bottles (other laboratory analysis)


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containers for what is being sampled for (i.e., bacteria requires sterile containers).

125 ml pre-labeled laboratory sample bottles (for on-site testing and BBAC off-site testing)

additional sample containers as needed

data sheet and chain of custody forms Field sheets for both dry weather inspection and dry weather sampling should be available with extras. Chain of custody form is needed to ensure proper handling of all samples

de-ionized water or laboratory purified water in squeeze bottle and extra squeeze bottles as necessary

For sample procedures

pens, pencils, and/or permanent markers For proper labeling

label tape For labeling sample containers

sampling pole, dipper, sampling cage, and/or hand-held vacuum pump

For accessing hard to reach outfalls and manholes

disinfecting (wet) wipes and/or hand sanitizer Disinfectant/decontaminant

Sample Transport

Check

Equipment Use/Notes

coolers For transporting samples to the laboratory

frozen blue ice

Tools

Check

Equipment Use/Notes

flashlight and/or headlamp with extra batteries For looking in outfalls or manholes, helpful in early mornings as well

manhole hook (from local DPW) For opening manholes


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measuring tape and/or carpenters ruler Measuring distances and depth of flow

shovel (from local DPW) For opening, propping, prying as needed

pry bar or pick For opening catch basins and manholes when necessary

sandbags For damming low flows in order to take samples

small Mallet or Hammer Helping to free stuck manhole and catch basin covers

utility Knife Multiple uses

safety glasses

Personal Protective Equipment (PPE)

safety vests

rubber knee boots and/or waders for accessing shallow streams/areas

safety (traffic) cones safety

Other

Check

Equipment Use/Notes

bug spray (the CDC recommends products with: DEET (exposed skin and clothing) or Permethrin (on clothing)

Protection

poison ivy wash (e.g., Tecnu, Zanfel) Protection (especially if allergic to poison ivy)

water (drinking water quality) For drinking, washing as needed

digital camera (smartphone or tablet) For documenting field conditions at time of inspection


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field log books Documentation

nitrile gloves To protect the sampler as well as the sample from contamination

paper towels Cleaning

sealable bags Miscellaneous storage, organization

8 TrainingAnnual IDDE training will be made available to all employees involved in the IDDE program. This training will at a minimum include information on how to identify illicit discharges and SSOs and may also include additional training specific to the functions of particular personnel and their function within the framework of the IDDE program. Training records will be maintained in Appendix E. The frequency and type of training will be included in the annual report.

9 Progress ReportingThe progress and success of the IDDE program will be evaluated on an annual basis. The evaluation will be documented in the annual report and will include the following indicators of program progress:

Number of SSOs and illicit discharges identified and removed Number and percent of total outfall catchments served by the MS4 evaluated

using the catchment investigation procedure Number of dry weather outfall inspections/screenings Number of wet weather outfall inspections/sampling events Number of enforcement notices issued All dry weather and wet weather screening and sampling results Estimate of the volume of sewage removed, as applicable Number of employees trained annually.


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The success of the IDDE program will be measured by the IDDE activities completed within the required permit timelines.


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Appendix A

Legal Authority (IDDE Bylaw or Other Regulatory Mechanism)

Instructions: Include a copy of the municipal by-law or other regulatory mechanism that gives the municipality the authority to regulate illicit discharges. See Section 1. Towns can use Cape Cod IDDE bylaw template for guidance.


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Appendix B

Storm System Mapping

Instructions: Include a copy of the municipality’s storm system mapping that illustrates compliance with Phase I and II of the permit mapping requirements.

Phase I Mapping Requirements:

- Outfalls and receiving waters (previously required by the 2003 MA-MS4 permit)

- Open channel conveyances (swales, ditches, etc.)

- Interconnections with other MS4s and other storm sewer systems

- Municipally owned stormwater treatment structures

- Water bodies identified by name and indication of all use impairments as identified on the most recent EPA approved Massachusetts Integrated List of Waters report

Phase II Mapping Requirements:

- Outfall spatial location (latitude and longitude with a minimum accuracy of +/- 30 feet.)

- PipesIllicit Discharge Detection and Elimination Plan

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- Manholes

- Catch Basins

- Refined catchment delineations. Catchment delineations shall be updated to reflect information collected during catchment investigations

- Municipal Sanitary Sewer system (if available)

- Municipal combined sewer system (if applicable)


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Appendix C

Field Forms, Sample Bottle Labels, and Chain of Custody Forms

Instructions: Include copies of the following field sampling documents:

- Dry weather outfall inspection/sampling form

- Wet weather outfall inspection/sampling form

- Manhole inspection form

- Example sample labels (provided by laboratory)

- Example chain-of-custody form(s) (provided by laboratory(s))

Some examples from the Barnstable County Laboratory are included on the following pages. Towns should add to and/or update as needed.


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Sample Bottle Label


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##TOWN Water Quality Sampling Program Sample

Date/Time: ___________________ Sample ID: _________

Sample Type: W or D

Laboratory Analysis: _____________

Preservative _____________________

Collected By: ________________________

Barnstable County Laboratory Bottle Label


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Sample Inspection FormIDDE Outfall Screening Form

Date of Inspection: Date of Last Storm:

Start Time: End Time:

Inspector Name:

Type of Inspection: ☐ Dry Weather ☐ Wet Weather

Structure Found: ☐ Yes ☐ No

Outfall Condition:

Outfall Condition: ☐ Good: Inspect Within 2 Years

☐ Fair: Inspect Within 1 Year ☐ Failing: Requires Immediate Action

☐ Poor: Requires Maintenance ☐ Unknown

Sedimentation: ☐ No Sedimentation ☐ Slight Sedimentation ☐ High Sedimentation

IDDE Class: ☐ Potential ☐ Obvious ☐ Unlikely

Reason for Illicit Suspicion:

Visual Inspection:

Staining: ☐ No Staining ☐ Some Staining ☐ Significant Staining

Scour Protection Condition: ☐ Good: Inspect Within 2 Years

☐ Fair: Inspect Within 1 Year ☐ Failing: Requires Immediate Action

☐ Poor: Requires Maintenance ☐ Unknown

Vegetative Growth:

☐ None ☐ < 25% Vegetated ☐ < 50% Vegetated

☐ 50% Vegetated ☐ > 50% Vegetated ☐ 100% Vegetated

Flow: ☐ Yes ☐ No Flow Clarity: ☐ Clear ☐ Cloudy ☐ Opaque

Color of Flow: Illicit Discharge Detection and Elimination Plan

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☐ N/A ☐ Clear ☐ Tea/Coffee ☐ Clear Black ☐ Orange-Red

☐ Tan to Light Brown ☐ Milky/Dirty Dishwater Gray ☐ Milky White ☐ White Crusty Deposits

☐ Greenish-Bluish ☐ Blue ☐ Purple ☐ Dark Red ☐ Other (describe in notes)

Floatables: ☐ Yes ☐ No Sewage, Sheens & Scum: ☐ Yes ☐ No

Odor: ☐ None ☐ Rotten Eggs/Hydrogen Sulfide ☐ Musty Odor ☐ Sharp, Pungent Odor

☐ Sweet, Fruit ☐ Gasoline, Petroleum ☐ Chlorine ☐ Other (describe in notes)

Water Quality Sampling

Temperature (deg C): Conductivity (micro-Siemens/cm):

pH: Salinity (ppm):

Ammonia (mg/L): Chlorine (mg/L):

Surfactants (mg/L):

Additional Parameters Screened:

Sample for Lab Collected: ☐ Yes ☐ No

Lab Sample 1 Test: Lab Sample 1 Results:



Notes:


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Barnstable County Laboratory Chain of Custody Form


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Appendix D

Water Quality Analysis Instructions, User’s Manuals and Standard Operating Procedures

Instructions: Include copies of water quality analysis instructions, procedures, and SOPs for all sample parameters and all meters or field test kits that are used for analysis. This includes the manufacturer’s instructions for how to use field test kits as well as the manufacturer’s instructions or user’s manual for any field instrumentation, including calibration. Towns should include equipment-specific information for the equipment they select. The Buzzards Bay Action Committee (BBAC) can provide information on equipment.

Barnstable County Lab can provide information on SOPs for lab analysis, as necessary.


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Appendix E

IDDE Employee Training Record

Instructions: Use the table provided in the plan, a spreadsheet, or other training log to document annual training for employees involved in the IDDE program.


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Illicit Discharge Detection and Elimination (IDDE)Employee Training Record


Date of Training:

Duration of Training:

Name Title Signature


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Name Title Signature


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Appendix F

Source Isolation and Confirmation Methods: Instructions, Manuals, and SOPs

Instructions: Provide manufacturer instructions, manuals and procedures and any in-house SOPs used to perform source isolation and confirmation for illicit discharges.


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