MS4 General Permit Town of Norwich 2018 Annual Report Existing MS4 Permittee Permit Number GSM [January 1, 2018 December 31, 2018]

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1 2018 MS4 REPORT 1

2 MS4 General Permit Town of Norwich 2018 Annual Report Existing MS4 Permittee Permit Number GSM [January 1, 2018 December 31, 2018] This report documents the City of Norwich efforts to comply with the conditions of the MS4 General Permit to the maximum extent practicable (MEP) from January 1, 2018 to December 31, Part I: Summary of Minimum Control Measure Activities 1. Public Education and Outreach (Section 6 (a)(1) / page 19) 1.1 BMP Summary BMP 1-1 Implement public education and outreach 1-2 Address education/ outreach for pollutants of concern* Education/Outreach for pollutants of concern Status Activities in current reporting period Storm Water best management brochures were mailed in to residents with their utility bills. Since the primary impairments in Norwich are phosphorus, nitrogen and bacteria. We focused on fertilizer reduction and pet waste proper disposal. Posters were installed in many public places. Do-Not- Feed-Ducks signs installed at Brown park near the boat ramp. JP Laguerre went on the Stu Briar Show,a local radio broadcast, to educate the public about illicit dumping and the importance of protecting our waters. Measurable goal Public awareness/ Number of calls received regarding the brochures. A reduction in number of people feeding ducks at Brown Park. The City replenished supplies of plastic bags in an effort to encourage people to curb after their dogs. A reduction of illicit dumping/feedback. At least 4 people called during the broadcast to ask questions. Department / Person Responsible Jean-Paul Laguerre Jean-Paul Laguerre Jean-Paul Laguerre Due Nov Date completed or projected completion date Public Outreach to Continue for the life of the permit even beyond. Public education/ Outreach to Continue for the life of the permit even beyond. Public Education/ outreach to continue for the life of the permit even beyond. Additional details 2

3 1.2 Describe any Public Education and Outreach activities planned for the next year, if applicable. In 2019 we plan to use a billboard to educate residents on stormwater best management practices- Overuse of fertilizers, Pet Waste pollution etc. We will continue our program of mailing stormwater best management practices with the utility bill. 1.3 Details of activities implemented to educate the community on stormwater Program Element/Activity Pet Waste Posters posted in Public Spaces, Otis library Senior Center, Three Rivers College, City Hall. Posters on Fertilizer reduction, Proper disposal of Grass clipping. Audience (and number of people reached) Approximately 2000 Approximately 2000 Topic(s) covered Impact of pet waste on Rivers, lakes and streams Impact of Fertilizer and grass clipping on Rivers, Lakes and Streams. Pollutant of Concern addressed (if applicable) E.Coli-Bacteria Phosphorus, Nitrogen Responsible dept. or partner org. Public Works Engineering Department Public Works Engineering Department 3

4 2. Public Involvement/Participation (Section 6(a)(2) / page 21) 2.1 BMP Summary BMP 2-1 Comply with public notice requirements for the Stormwater Management Plan 2-2 Comply with public notice requirements for Annual Reports Status posted Posted Activities in current reporting period Fertilizer Reduction Poster posted on City Website to educate residents. Notice Posted in 02/15/ Illicit Discharge Ordinance Approved The City council Approved an illicit Discharge Ordinance Measurable goal Department / Person Responsible Public Works Engineering Department Public Works Engineering Department Public Works Engineering Department Due Apr 3, 2017 Feb 15, 2018 Date completed or projected completion date - July 2018 Additional details 2.2 Describe any Public Involvement/Participation activities planned for the next year, if applicable. We have established a storm water committee. We hold quarterly meetings at City Hall to discuss storm water related issues. Meetings were held quarterly in Our main goal was to create the Ordinance that would give the City more power to stop illicit discharges.we also addressed ways of improving the quality of our storm water. 2.3 Public Involvement/Participation reporting metrics Metrics Implemented Date Posted Availability of the Stormwater Management Plan announced to public YES 02/15/2019 Availability of Annual Report announced to public YES 02/15/2019 Norwichct.org/Storm water Norwichct.org/Storm water 4

5 3. Illicit Discharge Detection and Elimination (Section 6(a)(3) and Appendix B / page 22) 3.1 BMP Summary BMP 3-1 Develop written IDDE program 3-2 Develop list and maps of all MS4 stormwater outfalls in priority areas Status Completed Completed Activities in current reporting period IDDE Program approved by council 100% of priority outfalls located. Measurable goal Develop written plan of IDDE program Department / Person Responsible Public works Engineering/Jean- Paul Laguerre Public Works Engineering/ Jean-Paul Laguerre Due Date completed or projected completion date Completed December 2018 Completed Additional details Information 3-3 Implement citizen reporting program 3-4 Establish legal authority to prohibit illicit discharges 3-5 Develop record keeping system for IDDE tracking In Place In Place In Place Residents have been calling to report illicit dumping or accidental spills. Ordinance has been approved. Legal Authority is now established Record Keeping System is set-up. Public Works Engineering/ Jean-Paul Laguerre Public Works Engineering/ Jean-Paul Laguerre Public Works Engineering/ Jean-Paul Laguerre Completed Completed Completed 3-6 Address IDDE in areas with pollutants of concern 3-7 Consolidate IDDE tracking spreadsheets In Progress In Place We have been posting No- Dumping Stickers on Catch basins where illicit dumping was discovered or reported. Compile all the IDDE tracking requirements into one spreadsheet Public Works Engineering/ Jean-Paul Laguerre Public Works Engineering/ Jean-Paul Laguerre Not specified Ongoing Reason for addition: Make it easier to track all IDDE activities 5

6 3.2 Describe any IDDE activities planned for the next year, if applicable. Norwich Public Works has been training their staff on Illicit Discharge Identification and Detection. Our staff responded positively from this year s training. More staff training is scheduled in the next year. 3.3 List of citizen reports of suspected illicit discharges received during this reporting period. Date of Report Location / suspected source Response taken 03/02/ Norwich Avenue 5 Gallon Latex Paint left open during a rain storm 04/10/2018 Shortly after City wide mailing of best management brochures, an alert resident called to inform public works that next door residents were discharging laundry waste in their backyard. 04/15/ Alice Court Engineer noticed kitchen grease on a basin grate. 04/30/ Franklin Street During a storm event a resident called to report an oil sheen near a Garage on Franklin Street. 07/17/2018 A resident complained that a lady at 14/16 Mulbery Street has been dumping oil in catch basin adjacent to that address. 10/15/2018 On October 15, A truck carrying a recently excavated tank spilled approximately 15 to 45 gallons of oil at the intersection of Smith Ave, Roosevelt and eight street. Public Works crew removed the can. Engineer confirmed that laundry waste water was being discharged in backyard. A letter was sent to the owner of the property and the pipe was removed. Engineer Dropped illicit discharge brochures in residents mailbox and No-Dumping Sticker was installed on catch basin. Engineer Investigated area. Nothing to report. Catch basins looked clean. Engineer installed No Dumping Stickers in the catch basins in the vicinity. Engineer paid a visit to the resident after a stern warning handed some educational materials. No-Dumping stickers were installed on all 3 catch basin tops in this vicinity. DEEP Dispatched environmental Services Inc. To Clean the Site. 3 Catch basins were vacuumed and sand was spread on these streets. Mr. Richard Scalora with DEEP was in charge of the cleanup process. The oil was vacuumed from catch basins and street was swept before the oil had any chance of going into the River. 6

7 3.4 Provide a record of illicit discharges occurring during the reporting period and SSOs occurring July 2012 through end of reporting period using the following table. Location (Lat long/ street crossing /address and receiving water) 40 feet from the intersection of Boswell and North Main Street A catch basin connected to a sewage manhole backed up and Milky sewage water flooded the street and spilled into North Main Street. Public Utilities was notified and they started working on unclogging the manhole right away. A long term plan is to disconnect the Catch basin from the manhole. Date and duration of occurrence Discharge to MS4 or surface water Estimated volume discharged Known or suspected cause / Responsible party 4 hours No Clogged Pipe Corrective measures planned and completed (include dates) NPU Quickly corrected the problem. Sampling data (if applicable) N/A 3.5 Briefly describe the method used to track illicit discharge reports, responses to those reports, and who was responsible for tracking this information. The City of Norwich strongly encourages citizens to report illicit discharges. When a citizen calls the Engineering Office to report an illicit discharge; The Engineering office dispatches an Engineer immediately to the reported location. The Engineer is responsible to look for any evidence of illicit discharge and to call the Street Department if immediate help is required to remove the pollutant. Once the pollutant is removed, the Engineer is responsible to conduct a full investigation and to assess the damage. The Engineer is responsible to educate the responsible party to ensure that such discharge never repeats. 7

8 3.6 Provide a summary of actions taken to address septic failures using the table below. Location and nature of structure with failing septic systems There has not been any septic tank failures reported in Actions taken to respond to and address the failures N/A Impacted waterbody or watershed, if known N/A 3.7 IDDE reporting metrics Metrics Estimated or actual number of MS4 outfalls 450 Estimated or actual number of interconnections 84 Outfall mapping complete 95% Interconnection mapping complete System-wide mapping complete (detailed MS4 infrastructure) Ongoing Ongoing Outfall assessment and priority ranking 90% Dry weather screening of all High and Low priority outfalls complete 10% Catchment investigations complete Estimated percentage of MS4 catchment area investigated Pending Pending 3.8 Briefly describe the IDDE training for employees involved in carrying out IDDE tasks including what type of training is provided and how often is it given (minimum once per year). 8

9 We have approximately 50 employees in the street Department. On July 24, 2018 Jean-Paul Laguerre, Engineer with Public Works taught a class on Storm Water best management practices and ways and means to identify and report illicit discharges. (See last 2 pages for attendance record) 4. Construction Site Runoff Control (Section 6(a)(4) / page 25) 4.1 BMP Summary BMP 4-1 Implement, upgrade, and enforce land use regulations or other legal authority to meet requirements of MS4 general permit Status The City already has strong regulations in place. Activities in current reporting period Measurable goal Department / Person Responsible Deanna Rhodes and Patrick McLaughlin, P.E. Due 2019 Date completed or projected completion date Additional details 4-2 Develop/Implement plan for interdepartmental coordination in site plan review and approval Active Deanna Rhodes and Patrick McLaughlin, P.E Review site plans for stormwater quality concerns Active Deanna Rhodes and Patrick McLaughlin, P.E Conduct site inspections 4-5 Implement procedure to allow public comment on site development Active Active Deanna Rhodes and Patrick McLaughlin, P.E. Deanna Rhodes and Patrick McLaughlin, P.E Implement procedure to notify developers about DEEP construction stormwater permit Active Deanna Rhodes and Patrick McLaughlin, P.E

10 4.2 Describe any Construction Site Runoff Control activities planned for the next year, if applicable. Silt bags, Silt fences and haybales must be installed wherever they are warranted before the beginning of each project. 5. Post-construction Stormwater Management (Section 6(a)(5) / page 27) 5.1 BMP Summary BMP 5-1 Establish and/or update legal authority and guidelines regarding LID and runoff reduction in site development planning 5-2 Enforce LID/runoff reduction requirements for development and redevelopment projects Status Deanna Rhodes is the Legal Authority Activities in current reporting period Measurable goal Department / Person Responsible Deanna Rhodes and Patrick McLaughlin, P.E. Due 2021 Deanna Rhodes and Patrick McLaughlin, P.E Date completed or projected completion date Additional details 5-3 Identify retention and detention ponds in priority areas 5-4 Implement long-term maintenance plan for stormwater basins and treatment structures Detention pond was cleaned at the end of Fairview Drive. Detention pond cleaned at the end of Sewart Road. The Stormwater basins in the City are cleaned annually as needed. Deanna Rhodes and Patrick McLaughlin, P.E Deanna Rhodes and Patrick McLaughlin, P.E DCIA mapping in progress We were able to come up with 2582 Acres of DCIA. Jean-Paul Laguerre

11 5-6 Address post-construction issues in areas with pollutants of concern Deanna Rhodes and Patrick McLaughlin, P.E. Not specified 5.2 Describe any Post-Construction Stormwater Management activities planned for the next year, if applicable. Follow up with at least 2 site visits after the project is completed. 5.3 Post-Construction Stormwater Management reporting metrics Metrics Baseline (2012) Directly Connected Impervious Area (DCIA) 2582 Acres DCIA disconnected (redevelopment plus retrofits) 0.6 acre to be disconnected in 2019 Retrofits completed DCIA disconnected 0.03 this year / 0.25 total since 2012 Estimated cost of retrofits $ 20,000 Detention or retention ponds identified 6 this year /# total 5.4 Briefly describe the method to be used to determine baseline DCIA. The baseline DCIA was determined by using the MS4 maps on the NEMO Website. Turning on the impervious cover layers by basin and tabulating the percentage of each basin that is directly connected we were able to determine a total DCIA of 2582 Acres. Approximately 13 % of the City area. N/A 11

12 6. Pollution Prevention/Good Housekeeping (Section 6(a)(6) / page 31) 6.1 BMP Summary BMP 6-1 Develop/implement formal employee training program 6-2 Implement MS4 property and operations maintenance Status Completed Ongoing Activities in current reporting period Training Held on June 7, Public Works has recently built a wash bay station to maintain City fleet in a green way. Measurable goal more illicit discharges reported. Department / Person Responsible JP Laguerre JP Laguerre Due Date completed or projected completion date More training to follow in 2019 Additional details Ongoing Nothing to Report JP Laguerre 6-3 Implement coordination with interconnected MS4s Not specified 6-4 Develop/implement program to control other sources of pollutants to the MS4 Ongoing -Reduction of -Fertilizers Silt fences before Construction to prevent migration of sedimentation. Reduction of pollutants of concern. JP Laguerre Not specified N/A JP Laguerre 6-5 Evaluate additional measures for discharges to impaired waters* Not specified 6-6 Track projects that disconnect DCIA Established Nothing to report in acre to be disconnected in Engineering Department

13 6-7 Implement infrastructure repair/rehab program. Ongoing Engineering Department 2021 Ongoing 6-8 Develop/implement plan to identify/prioritize retrofit projects Implement retrofit projects to disconnect 2% of DCIA The City is striving to implement retrofit projects to disconnect Impervious areas however budget is an issue Develop/implement street sweeping program Already in Place City streets are swept at least twice in a year Develop/implement catch basin cleaning program Already in Place Catch basins are cleaned at least once a year and more often if required Develop/implement snow management practices Already In Place The City switched to a salt mix eliminating the sand that would end up into our catch basins Describe any Pollution Prevention/Good Housekeeping activities planned for the next year, if applicable. 13

14 As part of the staff training in 2018 we have discussed the importance of reducing the amount of fertilizer used by the City. Moving forward in all our construction specifications we will incorporate languages related to silt fences and silt bags for catch Basins. The City of Norwich has built a vehicle wash bay station in 2018, a much environmental friendlier way to maintain our fleet. 6.3 Pollution Prevention/ Good Housekeeping reporting metrics Metrics Employee training provided for key staff 07/24/2018 Street sweeping Curb miles swept 163 miles swept twice a year. Spring and Fall or as required. Volume (or mass) of material collected At least 20 tons a year. Fewer now since the City switched to a salt mix instead of sand. Catch basin cleaning Total catch basins in priority areas 2800 Total catch basins in MS Catch basins inspected 3500 Catch basins cleaned 3000 Volume (or mass) of material removed from all catch basins 18 Tons Volume removed from catch basins to impaired waters (if known) Unknown Snow management Type(s) of deicing material used Salt Total amount of each deicing material applied 2500 Type(s) of deicing equipment used Lane-miles treated 163 miles Snow disposal location Aqueduct Parking Lot/Downtown Staff training provided on application methods & equipment November 2018 Municipal turf management program actions (for permittee properties in basins with N/P impairments) Reduction in application of fertilizers (since start of permit) 400 lbs Reduction in turf area (since start of permit) acres Lands with high potential to contribute bacteria (dog parks, parks with open water, & sites with 1 Acre. Norwich 14

15 failing septic systems) Cost of mitigation actions/retrofits Dog Pound. Not connected to City Storm System. N/A 15

16 6.4 Catch basin cleaning program Briefly describe the method used to optimize your catch basin inspection and cleaning schedule. The City of Norwich has always had a catch basin cleaning schedule. At least every other year the city hires a company to vacuum the city catch basins. The work includes removing the catch basin grates and vacuuming the sumps to remove sedimentations and debris. Any catch basins found in a state of disrepair is usually reported. The City will ensure that language is incorporated in the 2019 contracts to report any illicit dumping. 6.5 Retrofit program Briefly describe the Retrofit Program identification and prioritization process, the projects selected for implementation, the rationale for the selection of those projects and the total DCIA to be disconnected upon completion of each project. The City of Norwich has not started any retrofit program as of yet however we have worked with the Eastern Conservation District to create a rain garden at the Moriarty School in We will maintain this partnership and create more rain gardens in Describe plans for continuing the Retrofit program and how to achieve a goal of 1% DCIA disconnection in future years. The city plans to disconnect 1% a year by educating the residents when they come for a driveway apron permit. We will also work with zoning to ensure that more green areas are created during new construction. Describe plans for continuing the Retrofit program beyond this permit term with the goal to disconnect 1% DCIA annually over the next 5 years The City will work with council to create an incentive program for creating more green space within the City. 16

17 Part II: Impaired waters investigation and monitoring. 1. Impaired waters investigation and monitoring program 1.1 Indicate which stormwater pollutant(s) of concern occur(s) in your municipality or institution. This data is available on the MS4 map viewer: Nitrogen/ Phosphorus Bacteria Mercury Other Pollutant of Concern E-coli 1.2 Describe program status. Discuss 1) the status of monitoring work completed, 2) a summary of the results and any notable findings, and 3) any changes to the Stormwater Management Plan based on monitoring results. Monitoring work was completed by Fuss and Oneil on behalf of the city. The pollutants of concern are phosphorus and Nitrogen due to overfertilization, Bacteria and E-Coli due mainly to Combine Sewage discharging in the Thames. The Public Work Department is reducing the amount of fertilizer used each year, we have switched to organic fertilizer while reducing the amount used. 2. Screening data for outfalls to impaired waterbodies (Section 6(i)(1) / page 41) 2.1 Screening data collected under 2017 permit Complete the table below for any outfalls screened during the reporting period. Each Annual Report will add on to the previous year s screening data showing a cumulative list of outfall screening data. Outfall ID Sample date Parameter (Nitrogen, Phosphorus, Bacteria, or Other pollutant of concern) Results Name of Laboratory (if used) R /21/2018 Coliform Bacteria Phoenix Yes Follow-up required? 17

18 R R R R R R R R R /21/2018 Coliform Bacteria Phoenix Yes 12/21/2018 Coliform Bacteria 14,100 Phoenix Yes 12/21/2018 Coliform Bacteria 17,300 Phoenix Yes 01/24/2019 Coliform Bacteria >24,200 Phoenix Yes 01/24/2019 Coliform Bacteria >24,200 Phoenix Yes 01/24/2019 Coliform Bacteria >24,200 Phoenix Yes 01/24/2019 Coliform Bacteria >24,200 Phoenix Yes 01/24/2019 Coliform Bacteria >24,200 Phoenix Yes 01/24/2019 Coliform Bacteria >24,200 Phoenix Yes 01/24/2019 Coliform Bacteria >24,200 Phoenix Yes 01/24/2019 Coliform Bacteria 11,200 Phoenix Yes 01/24/2019 Coliform Bacteria >24,200 Phoenix Yes 2.2 Credit for screening data collected under 2004 permit If any outfalls to impaired waters were sampled under the 2004 MS4 permit, that data can count towards the monitoring requirements under the modified 2017 MS4 permit. Complete the table below to record sampling data for any outfalls to impaired waters under the 2004 MS4 permit. Outfall R R R Sample date 07/07/17 E-Coli Nitrogen 07/07/17 E-Coli Nitrogen 07/07/17 E-coli Nitrogen Parameter (Nitrogen, Phosphorus, Bacteria, or Other pollutant of concern) Results Name of Laboratory (if used) Phoenix Phoenix Phoenix Follow-up required? Follow up required for E-coli, not required for nitrogen Follow up required for E-coli, not required for nitrogen. Follow up required for E-coli, not required for nitrogen 18

19 R /07/2017 E-coli Nitrogen Phoenix Follow up required for E-coli, not required for nitrogen R R /07/17 E-coli Nitrogen 07/07/17 E-coli Nitrogen bacteria Phoenix Phoenix Follow up required for E-coli, not required for nitrogen Follow up required for E-coli, not required for nitrogen 3. Follow-up investigations (Section 6(i)(1)(D) / page 43) Provide the following information for outfalls exceeding the pollutant threshold. Outfall Status of drainage area investigation Control measure implementation to address impairment R R R R Limit for Bacteria exceeded. Drainage Area to be investigated under this permit. Limit for bacteria exceeded. Drainage Area to be investigated under this permit. Limit for bacteria exceeded. Drainage Area to be investigated under this permit. Limit for bacteria exceeded. Drainage Area to be investigated under this permit. Through ads and Web Postings we are educating our residents about curbing after their pets. Through ads and Web Postings we are educating our residents about curbing after their pets. Through ads and Web Postings we are educating our residents about curbing after their pets. Through ads and Web Postings we are educating our residents about curbing after their pets R Limit for bacteria exceeded. Drainage Area to be investigated under this permit. Through ads and Web Postings we are educating our residents about curbing after their pets. 19

20 R Limit for bacteria exceeded. Drainage Area to be investigated under this permit. Through ads and Web Postings we are educating our residents about curbing after their pets. 4. Prioritized outfall monitoring (Section 6(i)(1)(D) / page 43) Once outfall screening has been completed for at least 50% of outfalls to impaired waters, identify 6 of the highest contributors of any pollutants of concern. Begin monitoring these outfalls on an annual basis by July 1, Outfall Sample Date Parameter(s) Results Name of Laboratory (if used) Part III: Additional IDDE Program Data 1. Assessment and Priority Ranking of Catchments data (Appendix B (A)(7)(c) / page 5) Provide a list of all catchments with ranking results (DEEP basins may be used instead of manual catchment delineations). Part III: Additional IDDE Program Data 20

21 1. Assessment and Priority Ranking of Catchments data (Appendix B (A)(7)(c) / page 5) Provide a list of all catchments with ranking results (DEEP basins may be used instead of manual catchment delineations) 2. Category 3. Rank Total Basin Area (Acres) IC Area (ACRES) R4 Reginal name: R1 Regional Name: Thames R8 Regional name: Yantic High Priority High Priority High Priority

22 L3 Regional name: R6 Regional Name: Yantic Regional name: R3 Thames Main Stem L1 Thames Main Stem Thames Main Stem Thames Main Stem R1 Thames Main Stem High Priority High Priority High Priority High Priority High Priority High Priority High Priority High Priority

23 1. Catchment ID (DEEP Basin ID) 2. Category 3. Rank Total Basin Area (Acres) IC Area (Acres) R6 Yantic R R R R L1 Thames Main Stem R1 Thames Main Stem Thames Main Stem R7 Yantic R1 Yantic Yantic High priority High Priority High Priority High Priority High Priority High Priority High Priority High Priority High Priority High Priority High Priority High Priority High Priority

24 1. Catchment ID (DEEP Basin ID) 2. Category 3. Rank Total Basin Area (Acres) IC Area (Acres) R1 Yantic Yantic Yantic Yantic Thames Main Stem R1 Thames Main Stem L1 Yantic L Yantic Beaver Brook Pond L1 Yantic L R L L2 River High Priority High Priority High Priority High Priority Low Priority Low Priority Low Priority Low Priority Low Priority Low priority Low priority Low priority Low Priority Low Priority Low Priority Low Priority Low Priority Low Priority Low Priority

25 1. Catchment ID (DEEP Basin ID) 2. Category 3. Rank Total Basin Area (Acres) IC Area (Acres) R R R Thames Main Stem Low Priority Low Priority Low Priority Low Priority Low Priority Total 2,582 Acres Approximate Total Area of the City 18,221 Acres. Total Impervious Cover percentage is approximately 13%. 25

26 2. Outfall and Interconnection Screening and Sampling data (Appendix B (A)(7)(d) / page 7) 2.1 Dry weather screening and sampling data from outfalls and interconnections Provide sample data for outfalls where flow is observed. Only include Pollutant of concern data for outfalls that discharge into stormwater impaired waterbodies. Outfall / Interconnection ID Screening / sample date Ammonia Chlorine Conductivity Salinity E. coli or enterococcus Surfactants Water Temp Pollutant of concern If required, follow-up actions taken 2.2 Wet weather sample and inspection data Provide sample data for outfalls and key junction manholes of any catchment area with at least one System Vulnerability Factor. Outfall / Interconnection ID Sample date Ammonia Chlorine Conductivity Salinity E. coli or Enterococcus Surfactants Water Temp Pollutant of concern 26

27 3. Catchment Investigation data (Appendix B (A)(7)(e) / page 9) 3.1 System Vulnerability Factor Summary For those catchments being investigated for illicit discharges (i.e. categorized as high priority, low priority, or problem) document the presence or absence of System Vulnerability Factors (SVF). If present, report which SVF s were identified. An example is provided below. Outfall ID Receiving Water System Vulnerability Factors Where SVFs are: 1. History of SSOs, including, but not limited to, those resulting from wet weather, high water table, or fat/oil/grease blockages. 2. Sewer pump/lift stations, siphons, or known sanitary sewer restrictions where power/equipment failures or blockages could readily result in SSOs. 3. Inadequate sanitary sewer level of service (LOS) resulting in regular surcharging, customer back-ups, or frequent customer complaints. 4. Common or twin-invert manholes serving storm and sanitary sewer alignments. 5. Common trench construction serving both storm and sanitary sewer alignments. 6. Crossings of storm and sanitary sewer alignments. 7. Sanitary sewer alignments known or suspected to have been constructed with an underdrain system; 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. Areas formerly served by combined sewer systems. 10. Any sanitary sewer and storm drain infrastructure greater than 40 years old in medium and densely developed areas. 11. 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). 27

28 12. History of multiple local health department or sanitarian 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). 3.2 Key junction manhole dry weather screening and sampling data Key Junction Manhole ID Screening / Sample date Visual/ olfactory evidence of illicit discharge Ammonia Chlorine Surfactants 3.3 Wet weather investigation outfall sampling data Outfall ID Sample date Ammonia Chlorine Surfactants 3.4 Data for each illicit discharge source confirmed through the catchment investigation procedure Discharge location Source location Discharge description Method of discovery Date of discovery Date of elimination Mitigation or enforcement action Estimated volume of flow removed 28

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