Document RX9zB1MgDXJYag06bVKEpO0k

INDUSTRIA GOPIA ET ICO 18730 HOLYOKE REGICMONIDINTAE AD DONATA ILLICIT DISCHARGE DETECTION AND ELIMINATION (IDDE) PROGRAM CITY OF HOLYOKE, MASSACHUSETTS MAY 2023 KLEINFELDER Bright People. Right Solutions. ED_019088A_00020378-00001 A Report Prepared for: CITY OF HOLYOKE, MASSACHUSETTS 536 Dwight Street Holyoke, Massachusetts 01040 ILLICIT DISCHARGE DETECTION AND ELIMINATION (IDDE) PROGRAM CITY OF HOLYOKE, MASSACHUSETTS Prepared by: Portia Freeman, Professional Reviewed by: Pamela Westgate, Principal Professional Ajay Sharma, Project Manager KLEINFELDER 1500 Main Street, Suite 1510 Springfield, Massachusetts 01115 May 2023 Kleinfelder Project No: 20233959.001A KLEINFELDER Bright People. Right Solutions. 20233959.001A Page i of iii May 2023 ED_019088A_00020378-00002 TABLE OF CONTENTS KLEINFELDER Bright People. Right Solutions. Section Page 1ILLICIT DISCHARGE DETECTION AND ELIMINATION (IDDE) PROGRAM1 1.1 INTRODUCTION....1 1.1.1 Municipal Separate Storm Sewer System (MS4) Program.....1 1.1.2 Geographical Scope of IDDE Program..2 1.1.3 Allowable Non - Stormwater Discharges........4 1.1.4 Receiving Waters and Impairments......5 1.1.5 IDDE Program Objectives, Requirements, and Timeline .........6 2STORMWATER SYSTEM MAPPING...........9 2.1MAPPING NEXT STEPS......9 3.1 SSO INVENTORY10 3.2REMOVAL AND NOTIFICATION.....10 4OBJECTIVE, AUTHORITY AND IDDE RESPONSIBILITIES.............. 13 4.2IDDE PROGRAM RESPONSIBILITIES.... 13 5 (ASSESSMENT AND PRIORITY RANKING OF CATCHMENTS AND OUTFALLS...........16 5.1OUTFALL / INTERCONNECTION INVENTORY AND RANKING........16 5.2OUTFALL CATCHMENT DELINEATIONS...18 6 DRY WEATHER OUTFALL AND INTERCONNECTION SCREENING AND SAMPLING...................... 19 6.1WEATHER CONDITIONS.....19 6.2SCREENING REQUIREMENTS........19 6.2.1 Access.....20 6.2.2 Identification of Illicit Discharge20 6.2.3 Sample Collection and Testing22 6.3INTERPRETING OUTFALL SAMPLING RESULTS ..27 6.4FOLLOW - UP RANKING OF OUTFALLS AND INTERCONNECTIONS..28 7CATCHMENT INVESTIGATIONS.......29 7.1DRY WEATHER MANHOLE INSPECTIONS.......29 7.2WET WEATHER OUTFALL SAMPLING............31 7.3 ILLICIT DISCHARGE IDENTIFICATION, SOURCE ISOLATION, AND CONFIRMATION. 32 7.3.1 Sandbagging32 7.3.2 Smoke Testing .....32 7.3.3 Dye Testing33 7.3.4 Video Inspections .........33 7.3.5 Optical Brightener Monitoring33 7.4ILLICIT DISCHARGE REMOVAL.............34 7.4.1 Confirmatory Outfall or Interconnection Screening34 7.4.2 Ongoing Screening.....34 8 00 TRAINING 35 20233959.001APage ii of iiiMay 2023 ED_019088A_00020378-00003 TABLE OF CONTENTS (continued) KLEINFELDER Bright People. Right SolutionsS. Section Page 9ANNUAL REPORT.......... 36 FIGURES Figure 1: Holyoke MS4 Urbanized Areas Illicit Discharges...3 Figure 2: IDDE Investigation Procedure..........8 Figure 3: Organizational Structure15 TABLES Table 1: Consent Decree Requirements Included in the IDDE Program2 Table 2: Impaired Waters......6 Table 3: IDDE Program Implementation Timeline.7 Table 4: Investigation and Screening Timeline8 Table 5: MS4 SSO Inventory.......12 Table 6: IDDE Responsibilities....14 Table 7: Visual Condition Assessment......21 Table 8: Conditional and Qualitative Considerations of Foam21 Table 9: Field Equipment.....25 Table 10: Sampling Parameters and Analysis Methods...........26 APPENDICES AOutfall AND Interconnection Prioritization AND Ranking BEPA Sampling Report CMS4 Maps DLegal Authority EField Inspection Forms FInstructions, Manuals, and SOPS GIDDE Employee Training Record 20233959.001APage iii of iiiMay 2023 ED_019088A_00020378-00004 KLEINFELDER Bright People. Right Solutions. 1 ILLICIT DISCHARGE DETECTION AND ELIMINATION (IDDE) PROGRAM 1.1 INTRODUCTION 1.1.1 Municipal Separate Storm Sewer System (MS4) Program This document serves as a written plan for Illicit Discharge Detection and Elimination (IDDE) for the City of Holyoke, hereafter referred to as " the City " or " Holyoke, " and Veolia (the City's current contracted wastewater operator) to address the requirements of the United States Environmental Protection Agency's (U.S. EPA) and the Massachusetts Department of Environmental Protection (MassDEP) General Permits for Stormwater Discharges from Small Municipal Separate Storm Sewer Systems in Massachusetts, effective July 1st, 2018, hereinafter referred to as the " 2016 MS4 Permit " or " MS4 Permit ", and the 2023 MS4 Consent Decree, hereinafter referred to as the " Consent Decree ". The MS4 Permit requires regulated communities to address six Minimum Control Measures (MCM) including: 1. Public Education and Outreach; 2. Public Involvement and Participation; 3. Illicit Discharge Detection and Elimination Program (IDDE); 4. Construction Site Stormwater Runoff Control; 5. Post - construction Stormwater Management in New Development and Redevelopment; and 6. Good Housekeeping and Pollution Prevention for Permittee Owned Operations. Under MCM 3, the City and Veolia are required to implement an IDDE program to systematically find and eliminate sources of non - stormwater discharges to its MS4 and implement procedures to prevent such discharges. The IDDE program must be recorded in a written (hardcopy or electronic) document. This IDDE Program has been prepared to address this requirement. 20233959.001A Page 1 of 36 May 2023 ED_019088A_00020378-00005 KLEINFELDER Bright People. Right Solutions. The City of Holyoke negotiated a Consent Decree, which was finalized in 2023 and defined the terms that the City shall take to reach compliance with the MS4 program. Table 1 links sections of this IDDE Program to requirements outlined in the Consent Decree. Table 1: Consent Decree Requirements Included in the IDDE Program Consent Decree Section Description of RequirementIDDE Section 11-11e Apply new IDDE screening thresholds to all MS4 outfalls and any MS4 discharges toTable 10 Sampling Parameters and Analysis other municipal MS4s or non - City ownedMethods outfalls Current MS4 Catchment area map with 12aboundaries of each catchment area and all Figure 1 Holyoke MS4 Urbanized Areas associated outfalls or interconnections 12b Identification of all combined manholesAppendix A MS4 Outfall and Interconnection within MS4 catchment areasPrioritization 12c Schedule to inspect all identifiedTable 3 IDDE Program Implementation combined manholesTimeline 12d Schedule to repair or eliminate theTable 3 IDDE Program Implementation identified combined manholesTimeline A prioritization of all Catchment areas based EPA monitoring results, Cityon 12emonitoring results, applicable TMDLs for impaired waterbodies, and a schedule for completion of catchment investigations 13Dry - Weather Sampling Appendix A MS4 Outfall and Interconnection Prioritization Section 6.0 Dry Weather Outfall Interconnection Screening and Sampling; Section 7.1 Dry Weather Manhole Inspections 14Wet - Weather SamplingSection 7.2 Wet Weather Outfall Sampling Identification and Elimination of Illicit 15a - 15cDischarges to MS4 area with schedule forTo be provided at a later date as required actions Semi - annual Consent Decree compliance 17report relating to implementation of IDDETo be provided at a later date as required Plan (Due 1/31/2024) 1.1.2 Geographical Scope of IDDE Program The MS4 Permit requires municipalities to implement the IDDE program for those portions of the MS4 that are located either fully or partially within the Urbanized Area (based on 2010 U.S. Census) or located in a geographical area designated by U.S.EPA as requiring a permit. Figure 1 depicts the urbanized areas for Holyoke. 20233959.001APage 2 of 36May 2023 ED_019088A_00020378-00006 NORTHAMPTON KLEINFELDER Bright People. Right Solutions. POH Ad Genvale Southampton SOUTHAMPTON College Swanson Comers Mount Tom State Easthampton Reservation EASTHAMPTON SmithsSouth Hadley SOUTH HADLEY St. Mount Ton Northampton HOLYOKE Holvoke North WESTFIELD Pond CHICOPEE WEST SPRINGEMED Toke Mass Corporation NH NPDES Phase II Stormwater ProgramTown Population: 39880 Automatically Designated MS4 AreasRegulated Population: 39448 Holyoke MA(Populations estimated from 2010 Census) Regulated Area: UA Based onUA Based on 2000 Census2010 Census SEPA Urbanized Areas Town Boundaries:: US Census (2000, 2010) Base map 2013 Microsoft Corporation and its data suppliers 5 MiesUS EPA Region 1 C13 Center Map # 8324,892013 Figure 1: Holyoke Ms4 Urbanized Areas Illicit Discharges (Consent Decree Term # 12a) 20233959.001APage 3 of 36May 2023 ED_019088A_00020378-00007 KLEINFELDER Bright People. Right Solutions. An illicit discharge is any discharge to an MS4 that is not composed entirely of stormwater, except for site - specific NPDES permitted discharges and discharges resulting from firefighting activities and allowable non - stormwater discharges as outlined in Section 1.4. Illicit discharges may enter the drainage system through direct or indirect connections and may be intentional or unintentional. Direct connections include cross - connections of sewer services to the storm drain system. Indirect illicit discharges may be more difficult to detect and may include failing septic systems that discharge untreated sewage to a storm ditch or swale that is part of an MS4, or a sump pump that discharges contaminated water to storm drains intermittently. Some illicit discharges are intentional, such as dumping used oil into catch basins, seasonal dumping of swimming pool water, or illegally connecting a new sewer lateral into a storm drainpipe. Unintentional illicit discharges include breakouts from failing septic systems that enter the MS4, or disposal of floor wash water to a floor drain in an old building where the drain is thought to connect to a sewer line but connects to a storm drain instead. When not addressed, illicit discharges can contribute high levels of pollutants such as metals, toxics, oil, grease, solvents, nutrients, and bacteria to surface waters. 1.1.3 Allowable Non - Stormwater Discharges The following non - stormwater discharges are allowed under the MS4 Permit unless the permittee, U.S.EPA, or MassDEP finds the discharge to be 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 20233959.001A Page 4 of 36 May 2023 ED_019088A_00020378-00008 KLEINFELDER Bright People. Right Solutions. * Irrigation water, springs 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 any of the above discharges are identified as significant contributors of pollution to the MS4, they will be considered " illicit discharges " and addressed in the IDDE program. 1.1.4 Receiving Waters and Impairments 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 2 is a list of the impaired waters that are within the boundaries of Holyoke's regulated area based on the 2018/2020 Massachusetts Integrated List of Waters, produced by the MassDEP. The most recent Draft 2022 List is consistent with the 2018/2020 List. Because Holyoke is in the watershed of Long Island Sound (LIS), which has an approved total maximum daily load (TMDL) for nitrogen, the City is required to meet additional requirements in the MS4 Permit with respect for nitrogen discharges (MAR041000, Appendix B part B1). 20233959.001A Page 5 of 36 May 2023 ED_019088A_00020378-00009 KLEINFELDER Bright People. Right Solutions. Table 2: Impaired Waters Water Body Name Segment ID CategoryImpairmentComments Confluence with Deerfield Escherichia coli, PCB in fish tissue,River, Greenfield / Deerfield Connecticut RiverMA34-045Non - Native aquatic plants (Waterto Holyoke Dam (NATID: Chestnut)MA00973), Holyoke / South Hadley. Holyoke Dam (NATID: MA00973), Holyoke / South Connecticut RiverMA34-055Escherichia coli, PCB in fish tissueHadley to Massachusetts / Connecticut border, Longmeadow. Non - Native aquatic plants (Water Log Pond CoveMA341245Chestnut), PCB in fish tissue Part of Connecticut River Eurasian milfoil, chlorophyll - a, Non - Native aquatic plants, Pequot PondMA320555Enterococcus, dissolved oxygen, Total Phosphorus Located in Southampton Urban Area. Outfalls from Holyoke drain to a tributary of the Pond 1 Category 5: Impaired or threatened for one or more uses and requiring a TMDL. 1.1.5 IDDE Program Objectives, Requirements, and Timeline The objective of the IDDE Program is to systematically find and eliminate sources of non - stormwater discharges to the MS4 and implement procedures to prevent such discharges. The IDDE Program must include the following: Legal authority to prohibit and investigate suspected illicit discharges, eliminate, and remove illicit discharges, and enforce the IDDE Program. MS4 mapping. Sanitary Sewer Overflow (SSO) inventory, reporting, and mitigation. Screening of catchments, manholes, and outfalls during wet and dry weather conditions. Sampling procedures. Priority ranking of outfalls and interconnections - preliminary and follow up (post catchment investigation). 1 Catchment: the area that drains to an individual outfall or interconnection. Catchments are typically delineated based on topographic contours and mapped drainage infrastructure where available. 20233959.001APage 6 of 36May 2023 ED_019088A_00020378-00010 * Follow - up screening. Employee training. * IDDE program evaluation. KLEINFELDER Bright People. Right Solutions. Figure 2 (on the following page) shows the IDDE investigation procedure, Table 3 shows the IDDE implementation timeline, and Table 4 shows the Catchment Investigation and Dry & Wet Weather Screening timeline. Table 3: IDDE Program Implementation Timeline (Consent Decree Term # 12c and # 12d) IDDE Program Requirement Target Completion Date Completed in 2019 5/31/23 6/30/24 6/30/25 6/30/27 Written IDDE Program PlanX SSO InventoryX Preliminary Ranking of Outfalls and interconnections Written Catchment Investigation Procedure IDDE Regulatory Mechanism or By - law (if not already in place) Dry Weather Outfall ScreeningX Follow - up Ranking of Outfalls and Interconnections Catchment Investigations - Problem Outfalls Catchment Investigations - of High and Low Priority Outfalls X Start Finish Start Finish 20233959.001APage 7 of 36May 2023 ED_019088A_00020378-00011 KLEINFELDER Bright People. Right Solutions. Inventory andMap / InvestigateFollow - Up Re - rank Outfalls Rank Outfalls Catchments Screening Dry WeatherConduct Screening Investigations System has Remove Illicitsbeen fully Investigated Figure 2: IDDE Investigation Procedure Table 4: Investigation and Screening Timeline Years to TasksYear 1Year 2Year 3Year 4-Year 5 Complete Catchment Investigation 5 Days per Year 7 22 22 34 Dry Weather Screening1Days per Year13 once every 3 Wet Weather ScreeningDays per Year20202040 years This timeline assumes each task type will be performed on separate field days. However, it is anticipated that multiple tasks can be combined on same field day(s). Based on this, all tasks in a given year will take approximately one (1) month to complete. Wet weather screening must be completely once every three (3) years; however, it may be staggered over the three (3) years to make the total number of screenings required more manageable. Each set of outfalls to be screened per year must be the same outfalls when screened three (3) years later. 2 Illicit Discharge Detection and Elimination (IDDE) Plan template, June 30, 2016 for Central Massachusetts Regional Stormwater Coalition 20233959.001APage 8 of 36May 2023 ED_019088A_00020378-00012 2 STORMWATER SYSTEM MAPPING KLEINFELDER Bright People. Right Solutions. Holyoke's MS4 system maps are used to identify key stormwater infrastructure, factors influencing proper system operation, and the potential for illicit sanitary discharges. The City of Holyoke developed an updated stormwater map to begin addressing mapping requirements of the 2016 MS4 Permit and the Consent Decree Term 21. Copies of the system maps are included in Appendix C. The City is actively updating the current mapping to include West Holyoke. This part of the City will have an estimated 15- 20 additional outfalls. In addition to outfalls, the updated mapping will include interconnections, receiving water bodies, catchment delineations, and other municipally owned stormwater treatment structures. The City used both desktop analysis and field verification to further improve the accuracy of the existing GIS mapping data. This resulted in a total count of 67 identified MS4 outfalls, as well as preliminary catchment area delineations. The inventory and ranking will be updated as additional information from the outfall screening and catchment investigations become available. The screening and catchment investigations are discussed in Section 5.0. Updated maps reflecting newly developed and / or discovered information, corrections, and modifications will be submitted in conjunction with compliance reports semi - annually. In compliance with the MS4 Permit and Consent Decree Term 21, the following information and features will be included on the MS4 map: Base Map containing municipal property information. Water Resources and Topographic Features. Stormwater Infrastructure. Collection System (outside MS4) Investigations, remediation, and capital projects completed for the City's MS4 and collection system. 2.1 MAPPING NEXT STEPS Existing gaps in Holyoke's current GIS data are addressed in this IDDE Plan; updates to the mapping will occur as field information from ongoing investigations, which will get input to the database. Updates will be focused on addressing the listed requirements in the Consent Decree Term 21. 20233959.001A Page 9 of 36 May 2023 ED_019088A_00020378-00013 3 SANITARY SEWER OVERFLOWS (SSOS) KLEINFELDER Bright People. Right Solutions. The MS4 permit requires municipalities to prohibit illicit discharges, including sanitary sewer overflows (SSOs) to the MS4. An SSO is a discharge 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 system bypasses that allow stormwater and groundwater to overload the system, power failures, and human error. 3.1 SSO INVENTORY As part of its Stormwater Management Plan (SWMP), the City maintains an SSO inventory that includes the following information: Location (approximate street crossing / address and receiving water, if any). A clear statement of whether the discharge entered a surface water directly or entered the MS4. Date(s) and time(s) of each known SSO occurrence. Estimated volume(s) of the occurrence. Description of the occurrence including known or suspected cause(s). * Mitigation and corrective actions and completion dates as well as planned corrective measures and their implementation schedule. The SSO inventory is updated annually and is included in the Annual Report. The SSO inventory is summarized in Table 5. 3.2 REMOVAL AND NOTIFICATION Upon detecting or receiving notice of an SSO, the City shall eliminate it as soon as possible and take interim mitigation steps to minimize the discharge of pollutants to the MS4 until the SSO is eliminated. Holyoke must provide oral notification to the U.S.EPA within 24 hours of becoming aware of an SSO, as well as written notification within 5 days of becoming aware of an SSO. 20233959.001A Page 10 of 36 May 2023 ED_019088A_00020378-00014 KLEINFELDER Bright People. Right Solutions. The City is required to issue public advisory notifications within 2 hours of discovery of the SSO, posting public advisory notifications to the City's website and reporting into the MassDEP's online data system. MassDEP ContactU.S. EPA Contact Western Region (413) 784-1100New England (888) 372-7341 436 Dwight Street5 Post Office Square Springfield, MA 01103Boston, MA 02109 24-hour Emergency Line 1-888-304-1133 20233959.001APage 11 of 36May 2023 ED_019088A_00020378-00015 KLEINFELDER Bright People. Right Solutions. Table 5: MS4 SSO Inventory Discharge Volume 5 6 SSO Location2 Date DurationDescription *Mitigation StepsDate Completed Statement (gals) Leary Dr.Day Brook4/3/2018 30 mReimovned sblo.ckage o1f r0ags5. JetDcleeanebdtrhe nieigshbo rho/od. PuRt oan qguarsterly 4/3/2018 cleaning schedule. 72 Old Jarvis Ave.Ground5/11/2018 30 mins.90RagsRemoved blockage. Jet cleaned the main.5/11/2018 Tokeneke & Holy family Rd. Tannery Brook 6/11/2018 45 mins.225Grease & RagsRemoved blockage. Jet cleaned / degreased the City sewer main.6/12/2018 River Terrace (HighlandInterceptor / Manhole Conn. River11/5/201856 hrs.1,344,000Repaired Highland Interceptor. Made emergency repair to the interceptor.11/7/2018 Inter)failure Removed blockage of roots. Jet cleaned & CCTV sewer main.to verify root mass Rt 5 near Smith's Ferry P. S.Ground12/5/20182 hrs.25Roots12/5/2018 was cleared. 50 Holy Family Rd.Tannery Brook 1/24/2019 1.5 hrs.2,250Grease & RagsRemoved blockage. Jet cleaned sewer main.12/08/2019 75 Reservation Rd.Ground4/24/20192 hrs.30Debris & RocksRemoved blockage. Sewer main will be jet cleanedsummer 2019 200 Whiting Farms Rd.Tannery brook 7/23/2019 1.5hrs.> 10,000Grease & RagsRemoved blockage Main was put on Bi - monthly cleaning list.7/23/2019 20 Easthampton Rd.Green Brook1/13/20201hr300GreaseRemoved blockage. De greased sewer main.1/13/2020 63 Canal St.Ct. River4/26/2022 36 mins.225DebrisRemoved blockage. Jet cleaned main. 4/26/2022 Whiting ReservoirCT. River06/07/2022 3.15 hrs.900Grease & debrisRemoved blockage. Jet cleaned main.06/07/2022 Yale St.Ground8/23/2022 Unknown300-500Unbolted man holeReplaced missing bolts on manhole.8/26/2022 50 Holy Family Rd.Tannery Brook 12/08/2022 1.25 hrs.1,500Grease & RagsRemoved blockage. Jet cleaned sewer main.12/08/2022 Highland Park Pump StationCt. River3/17/2023 3.25hrs.600Force main failureSetup bypass and shut station down. Replaced failed section of main.3/27/2023 Notes: 1 Location (approximate street crossing / address and receiving water, if any) 2A clear statement of whether the discharge entered a surface water directly or entered the MS4 3 Estimated volume(s) of the occurrence 4 Description of the occurrence indicating known or suspected cause(s) 5 Mitigation and corrective measures taken or planned 6Date mitigation and corrective measures completed 20233959.001A / BOS23R154074Page 12 of 37May 2023 ED_019088A_00020378-00016 KLEINFELDER Bright People. Right Solutions. 4 OBJECTIVE, AUTHORITY AND IDDE RESPONSIBILITIES The objective of the IDDE program is to systematically find and eliminate illicit discharges to Holyoke's MS4 and prevent them from happening in the future. 4.1 LEGAL AUTHORITY Holyoke's Stormwater Ordinance was adopted by City Council on May 17th, 2010, and revised on September 1st, 2021. Specifically, Holyoke's Stormwater Ordinance grants the City the authority to: Prohibit illicit discharges. The City plans to update regulations or ordinances to grant the City authority to: Investigate suspected illicit discharges; Eliminate illicit discharges, including discharges from properties not owned by or controlled by the City that discharge into the MS4; and Implement appropriate enforcement procedures and actions. Draft ordinance language, proposed by the Pioneer Valley Planning Commission (PVPC), can be found in Appendix D. Copies of bylaws and additional relevant ordinance sections can also be found in Appendix D. 4.2 IDDE PROGRAM RESPONSIBILITIES As owner and operator of the MS4, the City and Veolia hold joint responsibility for implementing the IDDE program. The City Department of Public Works (DPW) is the lead municipal agency that works with Veolia and other departments to administer various aspects of the program. Specific IDDE Program responsibilities and responsible parties are listed in Table 6. The organizational structure of responsible parties is shown in Figure 3. 20233959.001A Page 13 of 36 May 2023 ED_019088A_00020378-00017 KLEINFELDER Bright People. Right Solutions. Table 6: IDDE Responsibilities Responsible PartyIDDE Responsibilities City EngineerEnforcement of ID procedures and actions Catchment Investigations; identifying system vulnerability factors (SVF), manhole inspections and isolation to confirm sources of ID Catchment prioritization Dry weather outfall screens / inspections and outfall sample VEOLIA Project Manager; City Engineercollection Rank / Prioritize and reprioritize outfalls and interconnections Wet and dry weather data review, tracking, collection, and annual reporting IDDE Program Progress Annual Report (SSOS, IDs identified and removed; # and% total outfall catchments evaluated; dry and wet weather screening results; volume of sewage removed VEOLIA Project Manager Illicit Discharge (ID) Investigations; removal, and removal confirmations SSOS Investigations and Maintenance of SSO Inventory Field checks and documentation of new / updated MS4 infrastructure; outfalls and interconnections; update MS4 maps Wet weather outfall screens / inspections and outfall sample collection Track and provide annual report of Illicit discharge removal Confirmatory outfall and interconnection screening after ID has been removed * IDDE training frequency and type in annual report Veolia Project ManagerCity EngineerCity Department of Public Works Michael WilliamsKris BakerDirector Project ManagerHolyoke City Engineer Carl Rossi VeoliaPublic Works (DPW)Director (413) 534-2222(413) 322-5605Public Works (DPW) (413) 322-5645 20233959.001APage 14 of 36May 2023 ED_019088A_00020378-00018 City of Holyoke Department of Public Works (DPW) Director KLEINFELDER Bright People. Right Solutions. City of Holyoke DPW Engineer Veolia Regional Manager Veolia Project Manager Figure 3: Organizational Structure 20233959.001A Page 15 of 36 May 2023 ED_019088A_00020378-00019 KLEINFELDER Bright People. Right Solutions. 50 ASSESSMENT AND PRIORITY RANKING OF CATCHMENTS AND OUTFALLS The MS4 permit requires Holyoke to assess and rank outfalls and interconnections based on their illicit discharge potential and the significance of the potential public health issues associated with such discharges. The rankings are used to prioritize the order of screening outfalls and interconnections and the order of conducting catchment investigations for evidence of illicit discharges and SSOs. The rankings are also used to track progress towards meeting permit milestones. Outfalls and Interconnections are defined as follows as per the 2016 Massachusetts Small MS4 General Permit: * Outfall (40 CFR 122.2): the point where the MS4 discharges to waters of the United States. Outfalls do not include open conveyances that connect two MS4s or pipes, tunnels and other conveyances that connect segments of the same stream or waters or are used to convey waters of the United States. Culverts longer than a simple road crossing are considered outfalls unless it is confirmed that they are free of any connections and simply convey waters of the United States. 3 Interconnection: 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. 5.1 OUTFALL / INTERCONNECTION INVENTORY AND RANKING The City maintains an inventory of each outfall and interconnection that discharges from the MS4. Currently, Veolia has identified 67 public outfalls within its MS4 area. The inventory includes the outfall and interconnection locations as well as a means of tracking all inspections, screenings, samplings, and other activities covered by the IDDE program. 3 United States Environmental Protection Agency (EPA). (n.d.). General Permits for stormwater discharges from small municipal -US EPA. Massachusetts Small MS4 General Permit. Retrieved January 16, 2023, from https://www3.epa.gov/region1/npdes/stormwater/ma/2016fpd/final-2016-ma-sms4-gp-mod.pdf 4 United States Environmental Protection Agency (EPA). (n.d.). General Permits for stormwater discharges from small municipal. - US EPA. Massachusetts Small MS4 General Permit. Retrieved January 16, 2023, from https://www3.epa.gov/region1/npdes/stormwater/ma/2016fpd/final-2016-ma-sms4-gp-mod.pdf 20233959.001A Page 16 of 36 May 2023 ED_019088A_00020378-00020 KLEINFELDER Bright People. Right Solutions. There are a number of MS4 catchment systems located in West Holyoke that have not been included in the current inventory. The City estimates approximately 15-20 outfalls that are not included currently, but mapping efforts are ongoing, and these outfalls will be identified and inspected during future field investigations. Both the MS4 map (Appendix C) and the Outfall and Interconnection Prioritization and Ranking Table (Appendix A) will be expanded upon and updated accordingly. The current inventory was given a preliminary ranking prior to future dry weather screening based on whether an outfall drained directly to a water body and whether the EPA completed sampling at select outfalls on May 7-8, 2019 and July 7, 2019. The City uses a point system to determine rank and priority for each outfall; one (1) point is granted to an outfall if it drains directly into a water body, and one (1) point is given to an outfall if it has been previously sampled by the EPA. Any outfall with one or more points is considered high priority. This ranked list is included as Appendix A. Rankings will be updated and presented in future reports once dry weather screening has been completed (as described in Section 6.4). Outfalls and interconnections included in the IDDE Program are classified as follows: 1. Problem Outfalls and Interconnections: have known or suspected contributions of illicit discharges and include outfalls / interconnections where previous screening indicates likely sewer input. 2. High Priority Outfalls: discharge to area of concern to public health due to their proximity to public beaches, recreational areas, or drinking water supplies; or are considered by Holyoke to be high priority based on their environmental attributes. 3. Low Priority Outfalls: are considered by Holyoke to be low priority based on existing land uses and their proximity to high priority environmental areas (e.g. densely developed areas that are not proximate to areas with identified environmental attributes). 4. Excluded outfalls: have no potential for illicit discharges and are 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. 20233959.001A Page 17 of 36 May 2023 ED_019088A_00020378-00021 KLEINFELDER Bright People. Right Solutions. 5.2 OUTFALL CATCHMENT DELINEATIONS A catchment is the area that drains to an outfall or interconnection. Catchment delineations define the contributing areas for investigations of potential sources of illicit discharges. Delineations are based on topographic maps (USGS Springfield North Quadrangle, Massachusetts, 7.5 minute, 2018 and Mount Tom Quadrangle, Massachusetts, 7.5 minute, 2018) and mapped drainage infrastructure. Initial catchment delineations are complete and can be found in Appendix C. Further refined delineations will be completed by June 30, 2024. 20233959.001A Page 18 of 36 May 2023 ED_019088A_00020378-00022 KLEINFELDER Bright People. Right Solutions. 6 DRY WEATHER OUTFALL AND INTERCONNECTION SCREENING AND SAMPLING (Consent Decree Term # 13) Outfalls can be in the form of pipes or ditches and are the final point of discharge into a body of water for an engineered storm drain system. Current and pending regulations require that all outfalls in the storm drain system be inspected and that their water quality be analyzed under dry and wet weather conditions. This section discusses the objectives of dry weather outfall inspections. Section 7.3 Wet Weather Sampling covers the objectives for wet weather outfall inspections. Dry weather flow is a common indicator of potential illicit connections. Veolia inspects and screens outfalls and interconnections in accordance with their priority ranking and the IDDE Program Timeline (Table 3-). The proper identification of any potential source(s) of an illicit discharge is further described in Section 7.4-Illicit Discharge Identification, Source Isolation, and Confirmation. 6.1 WEATHER CONDITIONS To ensure that sampling occurs during dry weather conditions, screening and sampling takes place when no more than 0.1 inches of rainfall has occurred in the previous 24-hour period, or 48-hour period when possible, and during times when there is no significant snow melt. 6.2 SCREENING REQUIREMENTS Screening data is included in the outfall / interconnection inventory and is used to set and update priority rankings for future screenings. For every outfall and interconnection, the following data is collected and entered into the digital inventory: 20233959.001A Page 19 of 36 May 2023 ED_019088A_00020378-00023 KLEINFELDER Bright People. Right Solutions. Unique identifier. Receiving water. Date of most recent inspection. Dimensions and shape. * Material (concrete, PVC). Spatial location (latitude and longitude within +/- 30 feet). Physical condition (vegetation and damage to outfall structures). Visual / olfactory evidence of non - stormwater discharge (evidence of flow, odor, color, turbidity, floatables (suds, toilet paper, or sanitary products), deposits, oil sheen. 6.2.1 Access As per the 2016 Massachusetts Small MS4 General Permit, if an outfall / interconnection is inaccessible or submerged, the permittee shall proceed to the first accessible upstream manhole or structure for the observation and sampling and report the location with the screening results. 6.2.2 Identification of Illicit Discharge Any flow observed during dry weather conditions at a stormwater outfall or manhole is a strong indicator of illicit discharges, though it is important to inspect within and around the outfall or manhole for other indicators of the type of discharge. If no flow is observed, there may be other visual or olfactory indicators that past flow existed, which are shown in Table 7 5. 5 Standard Operating Procedures. Central Massachusetts Regional Stormwater Coalition. (n.d.). Retrieved January 16, 2023, from https://www.centralmastormwater.org/toolbox/pages/standard-operating-procedures 20233959.001A Page 20 of 36 May 2023 ED_019088A_00020378-00024 KLEINFELDER Bright People. Right Solutions. Table 7: Visual Condition Assessment IndicatorPossible Source Foamupstream vehicle washing activities or illicit discharge Oil Sheenleak or spill Cloudiness suspended solids (i.e. dust, ash, powdered chemicals, ground up materials, etc.) Color or Odorraw materials, chemicals, or sewage Excessive Sediment Sanitary Waste / Optical Enhancers * disturbed earth of unpaved areas lacking adequate erosion control measures illicit discharge Orange Staininghigh mineral concentrations * Fluorescent dyes added to laundry detergent and some toilet paper While many of the indicators listed in Table 7 would indicate an illicit discharge, some indicators may occur naturally. For example, orange staining could be the result of naturally occurring iron. Foam can also be naturally occurring or caused by a pollutant; however, it may be difficult to determine the difference between natural foam and foam caused by pollution. Natural foam can typically be found in water with high organic content such as bog lakes, streams that originate from bog lakes, productive lakes, wetlands, or woody areas. As per the Central Massachusetts Regional Stormwater Coalition, it is important to consider the factors listed in Table 8 when determining if the source of foam present at a 56 stormwater outfall is natural or not. Table 8: Conditional and Qualitative Considerations of Foam Factors Explanation Wind Direction or Turbulence Proximity to Potential Pollution Source Natural foam occurrences of the beach coincide with onshore winds. Often, foam can be found along a shoreline and / or on open waters during windy days. Natural occurrences in rivers can be found downstream of a turbulent site. Some entities including the textile industry, paper production facilities, oil industries, and firefighting activities work with materials that cause foaming in water. If these materials are released to a water body in large quantities, they can cause foaming. The presence of silt in water, such as from a construction site can cause foam. Physical FeelingNatural foam is typically persistent, light, not slimy to the touch. Visual ObservationPrescence of decomposing plants or organic material in the water. 6 Standard Operating Procedures. Central Massachusetts Regional Stormwater Coalition. (n.d.). Retrieved January 16, 2023, from https://www.centralmastormwater.org/toolbox/pages/standard-operating-procedures 20233959.001APage 21 of 36May 2023 ED_019088A_00020378-00025 KLEINFELDER Bright People. Right Solutions. In addition to foam, both bacteria and petroleum can create a sheen on the water surface. Differentiating the two can be as simple as disturbing the " sheen " with a pole, stick, or similar object. A sheen caused by oil will remain intact and move in a swirl pattern while a sheen caused by bacteria will separate into several smaller patches and appear " blocky. " In addition, bacteria or naturally occurring sheens are usually silver or dull in color. While bacterial sheen is not a pollutant, it should be noted when describing the discharge57. Optical enhancers, however, can be visible to the naked eye when found in high enough concentrations and will appear as a bluish - purple haze. If a visual observation is unable to confirm the presence of this pollutant, a quantitative test can be used. To perform this test, a clean, white, cotton pad should be placed, either directly in, or within a sample of, the discharge for several days. After soaking, the cotton pad should be dried and then viewed under a fluorometer. If the cotton pad fluoresces, optical enhancers are assumed to be the pollutant. The magnitude of the fluorescence, as measured in fluorescent units, can be used to determine the concentration of optical enhancers within the sample. Often a visual observation is enough. It is not typical that this analysis is required. If evidence of illicit flow exists, a sample should be taken and observations should be recorded. 6.2.3 Sample Collection and Testing At least one (1) sample from each catchment during dry weather flow conditions is collected and analyzed for: ammonia, chlorine, conductivity, salinity, surfactants (such as MBAS), and temperature. E. Coli bacteria samples should be taken only if: a. outfalls identified by EPA in sampling results previously supplied to the City on May 7-8, 2019 and July 7, 2019 based on field test kit screening; b. olfactory or visual evidence of sewage; C. an exceedance of a bacterial threshold concurrent with meeting or exceeding of both the surfactant and ammonia thresholds; d. an exceedance of both the surfactant and ammonia thresholds concurrent with any detectable level of chlorine; and e. an exceedance of a bacterial threshold concurrent with any detectable level of ammonia below its threshold. 7 Standard Operating Procedures. Central Massachusetts Regional Stormwater Coalition. (n.d.). Retrieved January 16, 2023, from https://www.centralmastormwater.org/toolbox/pages/standard-operating-procedures 20233959.001A Page 22 of 36 May 2023 ED_019088A_00020378-00026 KLEINFELDER Bright People. Right Solutions. A discrete manual or grab sample will be collected for dry weather outfall inspections due to the time- sensitive nature of the process. Grab samples classify water at a distinct point in time and are used primarily when the water quality of the discharge is expected to be homogenous, or unchanging, in nature. A flow - weighted composite sample captures water quality over a measured period of time and is 8 used when the water quality of discharge is expected to be heterogenous, or fluctuating, in nature. Protocols for collecting a grab sample, as per the Central Massachusetts Regional Stormwater Coalition, are as follows: 1. Fill out sample information on sample bottles and field sheets (see Attachment 4 for example field sheets). 2. Do not eat, drink, or smoke during sample collection and processing. 3. Do not collect or process samples near a running vehicle. 4. Do not park vehicles in the immediate sample collection area, including both running and non- running vehicles. 5. Always wear clean, powder - free nitrile gloves when handling sample containers and lids. 6. Never touch the inside surface of a sample container or lid, even with gloved hands. 7. Never allow the inner surface of a sample container or lid to be contacted by any material other than the sample water. 8. Collect samples with a dipper or directly into sample containers. If possible, collect water while facing upstream of the flow into the sample bottles to not disturb water or sediments in the outfall pipe or ditch. 9. Do not overfill sample containers, and do not dump any liquid in them. Liquids are often added to sample containers intentionally by the analytical laboratory as a preservative or for pH adjustment. 10. Slowly lower the bottle into the water to avoid bottom disturbance and stirring up sediment. 11. Do not allow any object or material to fall into or contact the collected water sample. 12. Replace and tighten sample container lids immediately after sample collection. 13. Place laboratory samples on ice for analysis of bacteria and pollutants of concern. 8 Standard Operating Procedures. Central Massachusetts Regional Stormwater Coalition. (n.d.). Retrieved January 16, 2023, from https://www.centralmastormwater.org/toolbox/pages/standard-operating-procedures 20233959.001A Page 23 of 36 May 2023 ED_019088A_00020378-00027 KLEINFELDER Bright People. Right Solutions. 14. Accurately label the sample with the time and location. 15. Document on the Dry Weather Outfall Inspection Survey that analytical samples were collected, specify parameters, and note the sample time on an Inspection Survey (see Attachment 2 and 3 for examples). This creates a reference point for samples. 16. Fill out chain - of - custody form for laboratory samples. 17. If using a dipper or other device, triple rinse the device with distilled water and then in water to be sampled, except for bacteria sampling. 18. Store used test strips and test kit waste / ampules properly in a 5-gallon bucket with a cover. Storage and disposal shall be coordinated with the City. 19. Decontaminate all testing personnel and equipment. Samples that are unable to be analyzed for parameters using field instrumentation require laboratory analysis. Coordination with the laboratory, including the pick - up and / or dropping off of samples, is the responsibility of the City. The laboratory requires that a chain - of - custody form be filled out and accompany any samples that require analysis. The laboratory will also provide additional details regarding how samples should be collected based on the sample containers and / or specific analytes. Table 9 includes field equipment commonly used for outfall screening and sampling. Table 10 summarizes tests performed for each analyte and indicates whether they are done in the field or sent to an outside laboratory. 20233959.001A Page 24 of 36 May 2023 ED_019088A_00020378-00028 KLEINFELDER Bright People. Right Solutions. Table 9: Field Equipment Equipment Purpose Covered Metal ClipboardFor organization / protection of field sheets and writing surface Field Sheets or Tablet for Electronic Forms Field sheets for both dry weather inspection and Dry weather sampling should be available with extra copies Chain of Custody FormsTo ensure proper handling of all samples Pens / Pencils / Permanent MarkersFor proper labeling Nitrile GlovesTo protect the sampler and prevent contamination of samples Flashlight / headlamp w / batteriesFor inspecting outfalls or manholes Cooler with Ice For transporting samples to the laboratory (see sample holding requirements) Digital CameraFor documenting field conditions at time of inspection Personal Protective Equipment (PPE)Reflective vest, safety glasses, nitrile gloves and boots, steel toed shoes Insect / Plant Repellant and SunscreenProtection from environmental conditions GPS ReceiverFor recording spatial location data Distilled Water / Calibration Standards Water Quality Meter(s) Test Kits For use with test kits and water quality meters; cleaning equipment and calibration Handheld meters for testing various water quality parameters such as ammonia, surfactants, and chlorine Have extra kits on hand to sample more outfalls than are anticipated to be screened in a single day Label TapeFor labeling sample containers Sample Containers Make sure all sample containers are clean and keep extra sample containers on hand at all times. Confirm sample containers are appropriate for what is being sampled for (i.e., sterile containers for bacteria). Pry Bar. Shovel, or PickFor opening catch basins and manholes SandbagsFor damming low flows to collect water for sampling Small Mallet or HammerTo free stuck manhole and catch basin covers Utility KnifeMultiple uses Measuring TapeMeasuring distances and depth of flow Safety ConesTo clearly mark areas where samplers are present Hand Sanitizer To disinfect hands and nitrile gloves especially prior to collecting samples for bacterial analysis Zip Ties / Duct TapeFor making field repairs Rubber Boots / WadersFor accessing shallow streams / areas Sampling Pole / Dipper / Sampling CageFor accessing hard to reach outfalls and manholes 5-Gallon Bucket w / CoverDisposal of chemical waste Confined Space Entry Equipment (if needed) DBI Sali Tripod and retrieval wench; MSA Tripod, rescue wench and material / personal wench; full body harness; 10'ladder; waders; hard hat; air monitoring equipment (Ventis 4 gas meter) 20233959.001APage 25 of 36May 2023 ED_019088A_00020378-00029 KLEINFELDER Bright People. Right Solutions. Table 10: Sampling Parameters and Analysis Methods Threshold Limits in aMax. Hold Analyte / IndicatorInstrumentationPreservatives Single Field SampleTime E. Coli> 410 cfu / 100 ml Enterococci> 130 cfu / 100 ml Laboratory via approved methodCool >10 C, 8 hours Laboratory via approved0.0008% Na2S2O3 method MBAS Field Test Kit (e.g. > 0.25 mg / l CHEMetrics K-9400) Surfactants48 hoursCool >6 C Laboratory via approved > 0.1 mg / l method > 0.5 mg / l Ammonia Field TestCool >6 C, H2SO4 to Strips (e.g. Hach Brand)pH < 2, No Ammonia (NH3)28Lab oradtoray vyia sapprovp ed reservative > 0.1 mg / lrequired if analyzed method immediately Analyze Field Meter (e.g. Hach Chlorine> 0.02 mg / 1withinNone Required Pocket Colorimeter II) 15 minutes Field Meter (e.g. YSI TemperatureN / AImmediateNone Required Model 30) Field Meter (e.g. YSI ConductivityN / A28 daysCool >6 C Model 30) Field Meter (e.g. YSI SalinityN / A28 Modd el a 30)y sCool >6 C Notes: Where water is being discharged directly into an impaired water body 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. According to the 2016 MS4 Permit and Consent Decree, all analyses, except for indicator bacteria and pollutants of concern, can be performed with field tests or field instrumentation and are not subject to 40 CFR part 136 requirements. Sampling for bacteria and pollutants of concern shall be conducted using the analytical methods found in 40 CFR 136, or alternative methods approved by EPA in accordance with the procedures in 40 CFR 136 . The City, facilitated by Kleinfelder, is responsible for selecting a laboratory or field kits intended for measuring each analyte. When selecting field kits, Kleinfelder will review the detection range for each field kit and ensure it corresponds to the threshold limits for each analyte of interest, as listed in Table 10-. These limits will be communicated to the laboratory so that the laboratory's instrumentation can be properly calibrated to account for the threshold concentrations. In addition, each analyte has a 9 United States Environmental Protection Agency (EPA). (n.d.). General Permits for stormwater discharges from small municipal. - US EPA. Massachusetts Small MS4 General Permit. Retrieved January 16, 2023, from https://www3.epa.gov/region1/npdes/stormwater/ma/2016fpd/final-2016-ma-sms4-gp-mod.pdf 20233959.001APage 26 of 36May 2023 ED_019088A_00020378-00030 KLEINFELDER Bright People. Right Solutions. corresponding analytical method, as per Appendix G of the 2016 MS4 General Permit 10 --, that each field kit and laboratory analysis shall utilize to ensure compliance. Lastly, as per 40 CFR 136 11'maximum holding times and preservation requirements should be communicated to the laboratory. This is not applicable for field kits since samples are analyzed instantaneously after sample collection. Table 10 summarizes this information, which should be shared with the selected laboratory to ensure compliance with the Consent Decree. Testing for indicator bacteria and any pollutants of concern must be conducted using analytical methods and procedures found in 40 CFR 136. Samples for laboratory analysis must be stored and preserved in accordance with procedures found in 40 CFR 136. Table 10 is a list of analytical methods, detection limits, hold times, and preservatives for laboratory analysis of dry weather sampling parameters. 6.3 INTERPRETING OUTFALL SAMPLING RESULTS Outfall analytical data from dry weather sampling can be used to help identify the major type or source of discharge. Screening values that exceed these benchmarks indicate the presence of pollution and / or illicit discharges. Evaluation of sample data can show positive results due to sources other than human wastewater and false negative results due to chemical reactions or interferences. For example, elevated ammonia readings are common in the New England region due to sampling near historically filled tidal wetlands where the breakdown of biological organic material can skew sample results. The same elevated ammonia readings can also be triggered by discharge from a nearby landfill. In addition, elevated surfactant readings caused by salinity levels greater than one (1) part per thousand can be triggered by the presence of oil. Inconclusive surfactant readings, where the indicator ampule turns green instead of a shade of blue, can often be caused by fine suspended particulate matter being present in the sample being tested. Finally, very low bacteria concentrations can often be the result of elevated chlorine from leaking drinking water infrastructure inhibiting bacterial growth. As such, any detection of chlorine above the instrument Reporting Limit should be noted. 10 United States Environmental Protection Agency (EPA). (n.d.). Appendix G Massachusetts Small MS4 Permit Monitoring Requirements For Discharges into Impaired Waters - Parameters and Methods. Retrieved January 30, 2023, from https://www3.epa.gov/region1/npdes/stormwater/ma/2016fpd/appendix-g-2016-ma-sms4- gp.pdf. 11 The Federal Register. Federal Register. (n.d.). Retrieved January 30, 2023, from https://www.ecfr.gov/current/title- 40 / chapter-1 / subchapter - D / part-136? toc = 1. 20233959.001A Page 27 of 36 May 2023 ED_019088A_00020378-00031 KLEINFELDER Bright People. Right Solutions. 6.4 FOLLOW - UP RANKING OF OUTFALLS AND INTERCONNECTIONS The City updates its outfall and interconnection priority rankings (see Appendix A) based on information gathered during dry weather screening. Outfalls or interconnections are placed at the top of the priority list when investigations or sampling results indicate there is a high likelihood that illicit discharges from sanitary sources are entering stormwater. 20233959.001A Page 28 of 36 May 2023 ED_019088A_00020378-00032 7 CATCHMENT INVESTIGATIONS KLEINFELDER Bright People. Right Solutions. This section of the IDDE describes the catchment investigation procedure to investigate outfall catchments to trace the source of potential illicit discharges. The MS4 Permit requires catchment investigations for outfalls and / or interconnections to begin no later than June 30, 2020, and that all catchments affiliated with problem outfalls be investigated by June 30, 2025. Catchment investigations affiliated with all the other high and low priority outfalls must be completed by June 30, 2028. Catchment investigation techniques include, but are not limited to, reviewing maps, historic plans, and records. Data collected during catchment investigations will be recorded and reported in each annual report. Infrastructure information gathered during catchment investigations will be incorporated into the MS4 maps. 7.1 DRY WEATHER MANHOLE INSPECTIONS (Consent Decree Term # 13) A key step in catchment investigations is dry weather investigations of the manholes in the storm drain network. Investigations involve systematically and progressively observing, sampling, and evaluating key junction manholes, defined 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 that are only from private storm drains, individual catch basins, or both are not considered junction manholes for these purposes. Key Junction Manholes can represent one or more junction manhole. Adequate implementation of the IDDE 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 determine the possible presence of an upstream illicit discharge. Veolia may exclude a junction manhole located upstream and in the immediate vicinity from another manhole, or one that serves a drainage alignment that has no potential for illicit connections. For all catchments requiring investigation during dry weather, Veolia systematically inspects key junction manholes for evidence of illicit discharges. The program requires progressive inspection and sampling at manholes to find evidence of illicit discharges and to isolate and eliminate them. 20233959.001A Page 29 of 36 May 2023 ED_019088A_00020378-00033 KLEINFELDER Bright People. Right Solutions. Prior to manhole inspections property owners will be notified and the storm drain system will be cleaned, catchment investigations can begin. Veolia's inspections are conducted in one of two ways (or a combination of both): Working progressively up from an outfall and inspecting key junction manholes along the way (" Bottom Up "), and / or Working progressively down from the upper parts of the catchment towards the outfall (" Top Down "). The decision to work bottom up or top down depends on the nature of the drainage system, the land use, and the availability of information on the catchment and drainage system. A bottom - up approach can begin immediately when an illicit discharge is detected at an outfall, and only a map of the storm drain system is required. A top - down approach 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 discharged are believed to be located in the upstream portions of the catchment area. Once an inspection direction has been chosen, the investigation can then begin with key junction manholes and mainline manholes. From there, the inspection can continue towards junction manholes and other manholes, if needed, with the purpose to isolate any illicit discharges. The specific steps are as follows: 1. Manholes are opened and inspected for visual and olfactory evidence of illicit connections during dry weather. Visual evidence may include toilet paper, gray filamentous bacterial growth, sanitary products, sewage, soap, food, or other indications of anything other than stormwater. Olfactory evidence may include sewage, soap, laundry, bleach, or other odors not typical of stormwater. Sample outfall and manhole inspection forms are in Appendix E. 2. When possible, condition information and measured elevation of the manhole rim as well as the invert depth should be recorded. 3. If flows are observed, the inlet and outlet direction of the flow should be recorded. 4. If no flow is observed, record whether the manhole is dry or has standing water and move on to the next manhole upstream or downstream. 5. As the investigation follows the catchment upstream or downstream, only the most upstream manhole with flow should be sampled. For example, if flow is observed at an outfall, as well as 20233959.001A Page 30 of 36 May 2023 ED_019088A_00020378-00034 KLEINFELDER Bright People. Right Solutions. at the next three (3) manholes upstream, then only sample and test at the third manhole upstream. Testing should include chlorine, ammonia, surfactants, conductivity, salinity, and temperature. Refer to Section 6.2.3 Sample Collection and Testing for information on when to take E. Coli bacteria samples. Refer to Table 10 for threshold limits for each analyte. 6. If sampling results or visual or olfactory observations indicate potential illicit discharges or SSOS, Veolia flags the area draining to the junction manhole for further upstream investigation and / or isolation and confirmation of sources. 7. Additional key junction manhole inspections will proceed until the location of the suspected illicit discharge(s) or SSO(s) are located and isolated to a pipe segment between two manholes. 8. If no evidence of an illicit discharge is found, the catchment investigation is complete upon completion of key junction manhole sampling. 7.2 WET WEATHER OUTFALL SAMPLING (Consent Decree Term # 14) Catchments that have a minimum of one (1) system vulnerability factor (SVF) are screened during wet weather conditions. These catchments are sampled and inspected to the extent necessary to determine whether wet weather - induced high flows in sanitary sewers or high groundwater in areas served by septic systems - results in discharges of sanitary flows to the MS4. Catchment investigations are not considered complete until wet weather inspections are done. Wet weather sampling events are scheduled to occur during the spring (March to June) when groundwater levels are high, and timed to avoid sampling during the first flush of a wet weather event. At least one (1) wet weather sample is collected and analyzed for: ammonia, chlorine, conductivity, salinity, E. coli, surfactants (such as MBAS), and pollutants of concern (nitrogen, if discharge directly flows to the Connecticut River). 20233959.001A Page 31 of 36 May 2023 ED_019088A_00020378-00035 KLEINFELDER Bright People. Right Solutions. 7.3 ILLICIT DISCHARGE IDENTIFICATION, SOURCE ISOLATION, AND CONFIRMATION Once the source of an illicit discharge is approximated between two manholes, a range of techniques can be used to isolate and confirm the source of the discharge that may include: Sandbagging Smoke Testing Dye Testing Video Inspections Optical Brightener Monitoring These methods are described in further detail below. 7.3.1 Sandbagging This technique is used to identify and isolate intermittent sources of illicit discharge or sources having little perceptible flow. Sandbagging involves placing sandbags or other temporary barriers (caulking, weirs / plates, etc.) within outlets to manholes to form a temporary dam that collects any intermittent flows that may occur. The bags and barriers are only deployed during dry weather conditions and typically left in place for 48 hours. If water collects behind the barrier 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 intermittent discharge. 7.3.2 Smoke Testing Smoke testing is used on short sections of pipes or pipes with small diameters. It is used to trace illegal connections from buildings to the sewer. Smoke testing involves injecting non - toxic smoke into drain lines and the emergence of smoke from sanitary sewer vents in or from cracks and leaks in the system. Typically, a smoke bomb or smoke generator is used to inject smoke into a catch basin or manhole. Before conducting any smoke testing, area residents, business owners, and local police and fire departments are notified. Smoke can cause minor irritation of respiratory passages. Residents with respiratory conditions may need to be monitored or evacuated from the testing area to ensure safety. 20233959.001A Page 32 of 36 May 2023 ED_019088A_00020378-00036 KLEINFELDER Bright People. Right Solutions. 7.3.3 Dye Testing Dye testing involves flushing non - toxic dye into plumbing fixtures (toilets, showers, sinks) and observers standby at nearby storm drains, sewer manholes, and outfalls. Dye testing is done by a team of two or more with one person stationed inside the building, while others are stationed at the appropriate storm sewer and sanitary sewer manhole and / or outfall. The person inside the building adds dye into a plumbing fixture (sink or toilet) and runs water to move the dye through the system. Employees stationed outside are notified that the dye has been dropped and watch for the dye in the storm sewer and sanitary sewer. Dye testing is best used when the likely source of an illicit discharge has been narrowed down to a few specific houses or businesses. Before dye testing is done, affected residents, business owners, the local police and fire departments, and public health staff are notified. 7.3.4 Video Inspections Video inspections use mobile video cameras that are guided remotely through the stormwater drain lines to observe possible illicit discharges. 7.3.5 Optical Brightener Monitoring Optical brighteners are fluorescent dyes that are used in detergents and paper products. The presence of optical brighteners in surface waters or dry weather discharges indicates a possible illicit discharge or insufficient wastewater treatment at nearby septic systems or wastewater treatment plants. Optical brightener monitoring involves placing a cotton pad in a wire cage and securing the cage in a pipe, manhole, catch basin, or inlet to capture intermittent dry weather flows. The pad is collected and viewed with a UV light or with a fluorometer to determine the presence or absence of brighteners. Additional instructions and Standard Operating Procedures (SOPs) for these methods are in Appendix F. 20233959.001A Page 33 of 36 May 2023 ED_019088A_00020378-00037 KLEINFELDER Bright People. Right Solutions. 7.4 ILLICIT DISCHARGE REMOVAL Once an illicit source is identified, the Veolia Project Manager contacts the City Engineer of Public Works. The City Engineer, in accordance with legal authorities, notifies all responsible parties and requires immediate cessation of improper disposal practices. The City and Veolia take appropriate steps to eliminate the illicit discharge as expeditiously as possible. While the illicit discharge is being eliminated, all reasonable and prudent steps to minimize the discharge of pollutants to the MS4 are taken. When an illicit discharge cannot be removed within 60 days of being identified, the City creates a schedule for elimination and reports dates and schedules for removal in the annual report. For each confirmed source, Holyoke documents the following information in its Annual Report: Location of ID and its source(s); A description of the discharge; The method of discovery; The date of discovery; * The date of elimination, mitigation or enforcement action or planned corrective measure and a schedule for completing the ID removal; and * The estimate of the volume of flow removed. 7.4.1 Confirmatory Outfall or Interconnection Screening Within one (1) year of removal of all identified illicit discharges within a catchment area, confirmatory outfall or interconnection screening shall be conducted. If confirmatory screening indicates evidence of additional illicit discharges, the catchment shall be scheduled for additional investigation. Catchments investigations are considered complete upon confirmation of all illicit sources. 7.4.2 Ongoing Screening Once catchment investigations are completed and illicit discharges eliminated and confirmed, each outfall or interconnection will be reprioritized for screening once every five years. Ongoing screening consists of dry weather screening and sampling, and wet weather screening and sampling for all outfalls. Additional instructions and Standard Operating Procedures (SOPs) for these methods are in Appendix F. 20233959.001A Page 34 of 36 May 2023 ED_019088A_00020378-00038 8 TRAINING KLEINFELDER Bright People. Right Solutions. Veolia provides annual IDDE training to all employees involved in the IDDE program. At a minimum, training includes how to identify illicit discharges and SSOs. Training records, including the frequency and type, are recorded on a form included in Appendix G and included in the annual report. 20233959.001A Page 35 of 36 May 2023 ED_019088A_00020378-00039 9 ANNUAL REPORT KLEINFELDER Bright People. Right Solutions. Holyoke and Veolia evaluate the progress of their IDDE Program annually. This evaluation is documented in the annual report and includes: Number of SSOs and Illicit discharges identified and removed; Number and percent of total outfall catchments served by the MS4 that have been 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; Estimates of the volume of stormwater removed; and Number of employees trained annually. 20233959.001A Page 36 of 36 May 2023 ED_019088A_00020378-00040 KLEINFELDER Bright People. Right Solutions. APPENDIX A OUTFALL AND INTERCONNECTION PRIORITIZATION AND RANKING 20233959.001A / BOS23R154074 May 2023 ED_019088A_00020378-00041 KLEINFELDER Bright People Right Solution MS4 OUTFALL AND INTERCONNECTION PRIORITIZATION TABLE Wet Wet Wet EPA Dry Dry Dry Dry Wet ReceivingWeather Weather Weather Sample Weather Weather Weather Weather Weather Water BodySurfactant Chlorine Enterococci Site Ammonia Surfactant Chlorine Enterococci Ammonia Outfall ID LocationRanking Priority Water Body Yes = 1; = 1; NoneMax: 0.1Max: 0.1Max: 0.1Max: 0.1Max: 0.1Max: 0.1Max: 0.1Max: 0.1 No = 0 O OUTFALL- Connecticut TBD *0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH 00001 River OUTFALL- 00002 TBD *Broad Brook0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH OUTFALL- 00003 TBD *Broad Brook0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH OUTFALL- 00004 TBD *Broad Brook0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH OUTFALL- 00005 TBD *Broad Brook0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH OUTFALL- Pequot TBD *0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH 00006 Pond OUTFALL- Pequot TBD *0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH 00007 Pond OUTFALL- 00008 TBD *Broad Brook0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH OUTFALL- 00009 TBD *Broad Brook0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH OUTFALL- 00010 TBD *Broad Brook0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH OUTFALL- Whiting 00011Reservoir area Broad Brook0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH OUTFALL- WhitingBroad Brook0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH 00012Reservoir area OUTFALL- Connecticut SUMMIT AVE1TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *2HIGH 00013 River OUTFALL- Whiting 00014Reservoir area Broad Brook0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH OUTFALL- 00015 TBD *Broad Brook0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH OUTFALL- 00016 TBD *Broad Brook0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH Page 1 of 5 ED_019088A_00020378-00042 KLEINFELDER Bright People. Right Solutions Wet Wet Wet Recei Ev PAi nDg ry WDe rya tDhre y rD rW y eWaet th er Weather Sample Weather Weather Weather Weather Weather Water BodySurfactant Chlorine Enterococci Site Ammonia Surfactant Chlorine Enterococci Ammonia Outfall ID LocationRanking Priority Water Body Yes = 1; = 1; None =Max: 0.1Max: 0.1Max: 0.1Max: 0.1Max: 0.1Max: 0.1Max: 0.1Max: 0.1 No = 0 0 OUTFALL- Ashley TBD *0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH 00017 Cutoff OUTFALL- 16 HOLLY Pequot 00018 MEADOW RD Pond 0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH OUTFALL- 22 HOLLY Pequot 00019 MEADOW RD Pond 0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH OUTFALL- Schoolhouse BOBALA RD0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH 00020 Brook OUTFALL- HOMESTEAV 00021 AVE Wright Pond1TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *2HIGH OUTFALL- Connecticut MAIN ST0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH 00022 River OUTFALL- Connecticut MAIN ST0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH 00023 River OUTFALL- 00024 North WHITNEY AVERailRoad0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH Pond OUTFALL- 00025 North BOBALA RDRailRoad0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH Pond OUTFALL- WHITNEY 00026 AVENUE North RailRoad0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH Pond OUTFALL- LOWER Connecticut 00027 WESTFIELD RD River 0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH OUTFALL- EASTHAMPTON 00028 RD Broad Brook0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH OUTFALL- 00029 JARVIS AVEBroad Brook0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH OUTFALL- EASTHAMPTON 00030 RD Broad Brook0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH OUTFALL- EASTHAMPTON 00031 RD Broad Brook0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH OUTFALL- 00032 LINDOR STBroad Brook0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH Page 2 of 5 ED_019088A_00020378-00043 KLEINFELDER Bright People. Right Solutions Wet Wet Wet EPA Dry Dry Dry Dry Wet ReceivingWeather Weather Weather Sample Weather Weather Weather Weather Weather Water BodySurfactant Chlorine Enterococci Site Ammonia Surfactant Chlorine Enterococci Ammonia Outfall ID LocationRanking Priority Water Body Yes = 1; = 1; None =Max: 0.1Max: 0.1Max: 0.1Max: 0.1Max: 0.1Max: 0.1Max: 0.1Max: 0.1 No = 0 O 2ND LEVEL OUTFALL- Connecticut CANAL CABOT0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH 00033 River ST OUTFALL-MAIN ST 3RDConnecticut 00034 LEVEL CANAL River 0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH OUTFALL- 2ND LEVEL Connecticut 00035 CANAL RACE ST River 0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH OUTFALL- LONGFELLOW 00036 RD Broad Brook0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH OUTFALL- Schoolhouse BOBALA RD0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH 00037 Brook OUTFALL- LOWER Ashley 00038 WESTFIELD RD Cutoff 0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH OUTFALL- LOWER Ashley 00039 WESTFIELD RD Cutoff 0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH OUTFALL- WHITING Connecticut 00040 FARMS RD River 1TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *2HIGH OUTFALL- WHITING Connecticut 00041 FARMS RD River 0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH OUTFALL- Connecticut MAIN ST0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH 00042 River OUTFALL- Connecticut MAIN ST0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH 00043 River OUTFALL- Connecticut MAIN ST0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH 00044 River OUTFALL- Schoolhouse BOBALA ROAD0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH 00045 Brook OUTFALL- KNOLLWOOD 00046 CIRCLE Wright Pond0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH OUTFALL- EASTHAMPTON 00047 RD Broad Brook0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH OUTFALL- Connecticut MOSHER ST0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH 00048 River OUTFALL- Jones Ferry Connecticut 00049 Pump Station River 0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH Page 3 of 5 ED_019088A_00020378-00044 KLEINFELDER Bright People. Right Solutions Wet Wet Wet Recei EPvAi nDg ry WDe rya tDhre y rD rW y eWaetth er Weather Sample Weather Weather Weather Weather Weather Water BodySurfactant Chlorine Enterococci Site Ammonia Surfactant Chlorine Enterococci Ammonia Outfall ID LocationRanking Priority Water Body Yes = 1; = 1; None =Max: 0.1Max: 0.1Max: 0.1Max: 0.1Max: 0.1Max: 0.1Max: 0.1Max: 0.1 No = 0 O OUTFALL- Connecticut TBD *0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH 00050 River OUTFALL- Connecticut TBD *0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH 00051 River OUTFALL- Connecticut TBD *0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH 00052 River OUTFALL- Connecticut TBD *0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *1HIGH 00053 River OUTFALL- 00054 TBD *TBD *0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *0LOW OUTFALL- 00055 TBD *TBD *0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *0LOW OUTFALL- 00056 TBD *TBD *0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *0LOW OUTFALL- 00057 TBD *TBD *0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *0LOW OUTFALL- 00058 TBD *TBD *0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *0LOW OUTFALL- 00059 TBD *TBD *0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *0LOW OUTFALL- 00060 TBD *TBD *0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *0LOW OUTFALL- 00061 TBD *TBD *0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *0LOW OUTFALL- 00062 TBD *TBD *0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *0LOW OUTFALL- 00063 TBD *TBD *0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *0LOW OUTFALL- 00064 TBD *TBD *0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *0LOW OUTFALL- 00065 TBD *TBD *0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *0LOW OUTFALL- 00066 TBD *TBD *0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *0LOW OUTFALL- 00067 TBD *TBD *0TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *0LOW Page 4 of 5 ED_019088A_00020378-00045 KLEINFELDER Bright People. Right Solutions Wet Wet Wet EPA Dry Dry Dry Dry Wet ReceivingWeather Weather Weather Sample Weather Weather Weather Weather Weather Water BodySurfactant Chlorine Enterococci Site Ammonia Surfactant Chlorine Enterococci Ammonia Outfall ID LocationRanking Priority Water Body Yes = 1; = 1; None =Max: 0.1Max: 0.1Max: 0.1Max: 0.1Max: 0.1Max: 0.1Max: 0.1Max: 0.1 No = 0 O OUTFALL-TBD * 00068- OUTFALL- West HolyokeTBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD *TBD * 000XX Notes: 1.TBD * - Will be updated with information gathered from future outfall investigation and mapping efforts 2.Previous screening results indicate likely sewer input if any of the following are true: *Outfalls identified by the EPA in sampling results previously supplied to the City on May 7-8, 2019 and July 7, 2019 based on field test kit screening, 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, Ammonia > 0.5 mg / L, surfactants > 0.25 mg / L, and detectable levels of chlorine, or Any exceedance of a bacteria threshold and any detectable level of ammonia below its threshold 3. Outfalls and interconnections discharging to or in the vicinity of any of the following: public beaches, recreational areas, or drinking water supplies. 4mj .Receiving water quality based on latest version of MassDEP Integrated List of Waters; Poor = Waters with approved TMDLs (Category 4a Waters) where illicit discharges have the potential to contain the pollutant identified as the cause of the impairment; also, waters exceeding the water quality standards for bacteria; ammonia > 0.5 mg / L; surfactants >0.25 mg / L Fair = Water quality limited waterbodies that receive a discharge from the MS4 (Category 5 Waters) Good No water quality impairments 5. Generating sites are institutional, municipal, commercial, or industrial sites with a potential to generate pollutants that could contribute to illicit discharges (e.g., car dealers, car washes, gas stations, garden centers, and industrial manufacturing areas). 6.Age of development and infrastructure: High = developments with stormwater and sewer infrastructure > 40 years old; medium = developments with infrastructure 20-40 years old; Low = developments with infrastructure < 20 years old. 7. Historic Combined Sewers or Septic: Yes = Areas once served by combined sewers that have been separated, or areas once served by septic that have converted to sanitary sewers. 8. Aging septic systems: Yes = septic systems 30 years or older in residential areas. 9.Local Priority due to Environmental Qualities of the area and land use development. 10. Any river or stream that is culverted for distance greater than a simple roadway crossing. Page 5 of 5 ED_019088A_00020378-00046 APPENDIX B EPA SAMPLING REPORT KLEINFELDER Bright People. Right Solutions. 20233959.001A / BOS23R154074 May 2023 ED_019088A_00020378-00047 UNITED STATES UNITED STATES ENVIRONMENTAL PROTECTION AGENCY * AGENCY Region I-New England Regional Laboratory ENVIROPNRMOETNETCATLIOLNab1o1r aTteocrhyn oSleorgvyi Dcreisv ea,n dN oArptphl iCehde lSmcsifeonrcde, DMiAv i0s1i8o6n3 Drafted Date:September 30, 2019 Finalized Date:October 4, 2019 Subject:Holyoke Stormwater City of Holyoke, MA Compliance Sampling Inspection Report From:Michelle Coombs, Investigator, Laboratory Services and Applied Science Division - Field Services Branch (LSASD - FSB)\ MRC \ Reviewed By:Jerry Keefe, Investigations Team Leader, LSASD - FSB\ JCK \ To:Denny Dart, Water Compliance Section Chief, Enforcement and Compliance Assurance Division (ECAD - EWC) CC:Douglas Koopman, Inspector, ECAD - EWC I. Facility Information A. Facility Name:City of Holyoke B. Facility Location:Holyoke, MA C. Facility Contact:Michael McManus, General Superintendent Phone: (413) 322-5645, Email: mcmanusm@holyoke.org D. NPDES MS4 Permit #: MAR041011 E. NPDES CSO Permit #: MA0101630 II. Background Information A. Date / Start time of inspection:September 24, 2019 @ 0730 HRS B. USEPA Representatives:Michelle Coombs and William Sommer C. Federally Enforceable Requirements Investigated:40 CFR Part 122.26 D. Pollutants Sampled:E. Coli, Enterococci, Pharmaceuticals and Personal Care Products (PPCPs), Surfactants, Ammonia, and Total Chlorine ED_019088A_00020378-00048 III. Disclaimer: City of Holyoke, MA Compliance Sampling Inspection 09/24/2019 Page 2 of 6 Unless otherwise noted, this report describes conditions at the facility / property as observed by EPA inspector(s), and / or through records provided to and / or information reported to EPA inspector(s) by facility representatives and as understood by the inspector(s). This report may not capture all operations or activities ongoing at the time of the inspection. This report does not make final determinations on potential areas of concern. Nothing in this report affects EPA's authorities under federal statutes and regulations to pursue further investigation or action. IV. Type and Purpose of Inspection The purpose of the compliance sampling inspection was to identify illicit connections or illegal discharges within the City of Holyoke, MA Municipal Separate Storm Sewer System (MS4) and / or Combined Sewer System (CSS) that may adversely impact the water quality in the Connecticut River. Samples were collected from eight (8) locations in accordance with the FSB Investigations Team Stormwater Program Plan. V. Inspection Summary On September 24, 2019, EPA employees Michelle Coombs and William Sommer (" the EPA Inspection Team ") conducted a compliance sampling inspection of the stormwater system within the City of Holyoke, MA at the locations described in Section VI. They were not accompanied by any city or state representatives. The inspection started in the northern, residential area of the city, at approximately 0730 HRS. At the time of the inspection, the weather was sunny with an ambient temperature of approximately 60 F. According to The National Weather Service for the Westfield - Barnes Municipal Airport, the last amount of recorded precipitation was 0.20 inches on September 14, 2019. The City of Holyoke, MA was issued NPDES Permit MAR041011 under the National Pollutant Discharge Elimination System (NPDES) MS4 General Permit Program. The City of Holyoke, MA is a regulated small MS4 according to the Stormwater Phase II Rule, which was promulgated and is administered by EPA. The City of Holyoke is authorized to discharge at 11 Combined Sewer Overflow (CSO) locations under the NPDES Permit MA0101630, issued October 1, 2015. The applicable sampling locations described in Section VI below were field screened using test kits for ammonia, surfactants, and chlorine and in - situ measurements for specific conductivity, salinity, and temperature were also collected and recorded using a YSI meter (those not field screened / measured are noted as NA). All samples were analyzed for E. Coli and Enterococcus at Alpha Analytical in Westborough, MA and Pharmaceutical and Personal Care Products (PPCPs) at the EPA New England Regional Laboratory (NERL) in North Chelmsford, MA. The following table(s) summarize the findings: Table 1: Summary of Sampling and Analytical Data. ED_019088A_00020378-00049 City of Holyoke, MA Compliance Sampling Inspection 09/24/2019 Page 3 of 6 VI. Description of Sampling Locations Photographs of each location can be found in the photo log (Attachment A). 29Long: A single concrete, circular outfall approximately 24 inches in diameter with an estimated flow of 5 gallons per minute (gpm). MA-DEP File Number 186-0255. Long, dark brown filamentous bacteria growth downstream. Outfall is located on the eastern side of Longfellow Road. CSO018: A single concrete rectangular culvert approximately 60 inches in diameter with very little flow and standing water from the pool downstream. The color of the water was an opaque gray. Outfall is CSO 18 off of St. Kolbe Drive. CommField: A single concrete, circular outfall approximately 60 inches in diameter with an estimated flow of 7 gpm. The pool at the mouth of the outfall is a milky, gray color and there was dark filamentous bacteria growth downstream of the outfall. Outfall is adjacent to the entrance to the walking trail in Community Field Park. Summit2: A single, circular, green PVC outfall approximately 12 inches in diameter with a trickling flow. A slight musty odor was detected, and dark green filamentous bacteria growth was observed in the pipe and on the rocks below the outfall. An orange precipitate was also observed in the pool and on the pipe. Outfall is located on the eastern side of Community Field Park, discharging toward Concord Avenue. Homestead: A single concrete, circular outfall approximately 24 inches in diameter with an estimated flow of 10 gpm. The outfall was mostly submerged underwater and the pool downstream was a slight milky color. The outfall was inaccessible, so the sample was collected approximately 25 feet downstream. Outfall is located on Homestead Avenue, in between the Holyoke Fire Station # 6 and the Holyoke Mini Mall. JPRest: A set of twin, concrete elliptical outfalls approximately 60 inches in length. The sample was taken at the leftmost outfall (looking downstream). The right facing outfall was dry at the time of collection. Estimated flow was 8 gpm. Bricks and trash were observed downstream. Sewage and chlorine odors were detected. Outfall is located across the street from JP's Restaurant on Whiting Farms Road. Avis: A single concrete, circular outfall approximately 24 inches in diameter with an estimated flow of 20 gpm. Outfall is located on the left side of the Rte. 5 bridge culvert (looking downstream), approximately 20 feet from the end of the concrete flooring. Outfall flows into Tannery Brook near the Avis car rental building. Tannery: In - stream sample of Tannery Brook collected at the overflow point from the 12 ft. by 12 ft. square culvert under the Rte. 5 bridge, downstream of " Avis ". ED_019088A_00020378-00050 Map of Sample Locations City of Holyoke, MA Compliance Sampling Inspection 09/24/2019 Page 4 of 6 Holyoke StormwaterLegend Approximately locations of sample stations visited during EPA sampling inspection on 09/24/2019 Sample Station 29Long CSO018 Summit2 CommField Homestead JPRest Avis Tannery Google EarthN Image Landsat / Copernicus2 mi ED_019088A_00020378-00051 City of Holyoke, MA Compliance Sampling Inspection 09/24/2019 Page 5 of 6 Table 1: Summary of Sampling and Analytical Data Site ID 29Long CSO018 CommField Summit2 Homestead JPRest Avis Tannery Location Sample Time 7:40 8:15 9:20 9:50 10:30 11:09 11:43 11:45 Sample Date09/24/2019 09/24/2019 09/24/2019 09/24/2019 09/24/2019 09/24/2019 09/24/2019 09/24/2019 Coordinates North42.219930 42.212892 42.204429 42.204267 42.186310 42.177575 42.162306 42.162303 West-72.635849 -72.608700 -72.638261 -72.637113 -72.650480 -72.640585 -72.632826 -72.632724 Salinity, ppt. 0.4 0.2 0.5 0.9 0.2 0.0 0.9 0.8 YSI Meter Temperature, C 18.1 19.0 16.6 19.3 14.3 16.5 15.7 15.8 Conductivity, uS / cm 892 406.1 1034 1867 447.4 93.1 1816 1571 Field Test Kits (mg / L) Ammonia 0.0 0.50 0.25 0.0 0.0 0.25 0.30 s, Chlorine 0.02 0.02 0.05 0.03 0.0 0.14 0.05 NA Surfactants 0.35 0.10 0.25 0.50 0.25 0.15 0.60 NA Bacteria (MPN / 100mL) E. coli 95.86 816.41 151 < 1 39.5 < 1 6,178 58.76 Enterococcus 209.82 195.1 172.6 770.1 86.24 < 1 1,732.89 116.02 Cotinine 2.4 9.4 ND 1.21 ND 0.431 7.13 ND Acetaminophen ND 58 ND ND ND ND 844 ND Pharmaceutical Paraxanthine ND 20 ND ND ND ND 101 ND and Personal Atenolol ND 8 ND ND ND ND 22.1 ND Care Products Caffeine 5 130 3.4 ND ND 22.7 363 ND (ng / L) Metoprolol ND 62 ND ND ND ND 8.25 ND Diphenhydramine ND 8.4 ND ND ND ND 4.23 ND Carbamazepine ND 36 ND ND ND ND 9.45 ND Abbreviations and Notes: ND: Not Detected Above Reporting Limit E. Coli: Red > 400col / 100ml, Orange > 200 col / 100ml, Yellow > 50 col / 100ml, Black < 50 col / 100ml Entero: Red 1000 col / 100ml, Orange > 350 col / 100mL, Yellow > 54 col / 100ml, Black < 54 col / 100ml NH3: Red >6 mg / L, Orange > 0.5 mg / L, Yellow > 0.25 mg / L, Black < 0.25 mg / L Cl: Red 1.0 mg / L, Orange > 0.3 mg / L, Yellow > 0.02 mg / L, Black < 0.02 mg / L Surfactants: Red > 1.0 mg / L, Orange > 0.5 mg / L, Yellow > 0.25 mg / L, Black < 0.25 mg / L (may give false positive at salinity greater than 1 ppt) PPCP: Dark Pink 100x the RL; Pink > 10x the RL; Light Pink > 3x the RL; No Pink < 3x the RL * * See Reporting Level (RL) values for each compound in attached Laboratory Report ED_019088A_00020378-00052 VII. Attachments City of Holyoke, MA Compliance Sampling Inspection 09/24/2019 Page 6 of 6 Attachment A: Photo Log Attachment B: Laboratory Report for Pharmaceuticals and Personal Care Products (Source Tracking) Analysis Attachment C: Laboratory Report for E. coli and Enterococcus Analysis End of Report ED_019088A_00020378-00053 APPENDIX C MS4 MAPS KLEINFELDER Bright People. Right Solutions. 20233959.001A / BOS23R154074 May 2023 ED_019088A_00020378-00054 Legend NORTHAMPTONHADLEY Drainage Outfalls MS4 (67) 4 Non - MS4 (88) Drainage Manholes Drainage Pipes Combined GravityMain Sanitary Sewer ManholesLake Bray Sewer GravityMain PTON Stormwater Catchment Impaired Rivers (2018) Category 5 Impaired Lakes & Ponds (2018) Category 3SOUTH HADLEY 4C Whiting 5Street Reservoir Holyoke Town Boundary MS4 Urbanized area SOUTHAMPTON 000 HOLYOKE Connecticut River Log Pond Cove Clear Pond Mclean Reservoir Wright Pond Ashley Cutoff WESTFIELD Ashley Pond North Railroad Connor Pond O Reservoir CHICOPEE WEST SPRINGFIELD The information included on this graphic representation has been compiled from a variety of sources and is subject to change without notice. Kleinfelder makes no representations or INDUSTRIACOPIA ETPROJECT NO. 20233959.001A CREATED:5/22/2023 Storm System Map warranties, express or implied, as to accuracy, completeness, timeliness, or rights to theCREATED BY:STKhan unosr ies it odefsi gnesd uor cinhten deid nas fa oconrstmrucatiton ideosingn .do cumTenht. iThse used oor mcisuusem ent is not intended for use as a land survey product1873KLEINFELDER of the information contained on this graphic representation is at the sole risk of the 04,0008,000 party using or misusing the information.HOLYOKEBright People. Right Solutions.CityofHolyoke CONDITA AD DONATA Feet Holyoke, MA ED_019088A_00020378-00055 APPENDIX D LEGAL AUTHORITY KLEINFELDER Bright People. Right Solutions. 20233959.001A / BOS23R154074 May 2023 ED_019088A_00020378-00056 MODEL ILLICIT CONNECTIONS AND DISCHARGES ORDINANCE Pioneer Valley Planning Commission City of Holyoke Illicit Connections and Discharges To The Municipal Storm Drain System Ordinance SECTION 1. PURPOSE............ 2 SECTION 2. DEFINITIONS SECTION 3. APPLICABILITY............ SECTION 4. AUTHORITY.......... 5 SECTION 5. RESPONSIBILITY FOR ADMINISTRATION............ 5 SECTION 6. REGULATIONS............... 5 SECTION 7. PROHIBITED ACTIVITIES................. 5 SECTION 8. EMERGENCY SUSPENSION OF STORM DRAIN SYSTEM ACCESS......... 7 SECTION 10. ENFORCEMENT.......................... 8 SECTION 12. TRANSITIONAL PROVISIONS..10 Illicit Connections Bylaw / Ordinance ED_019088A_00020378-00057 SECTION 1. PURPOSE The purpose of this ordinance is to regulate illicit connections and discharges to the storm drain system, which is necessary for the protection of the City of Holyoke's water bodies, wetlands, and groundwater, and to safeguard the public health, safety, welfare and the environment. The objectives of this ordinance are: (1) To prevent pollutants from entering the municipal separate storm sewer system; (2) To prohibit illicit connections and unauthorized discharges to the stormwater system; (3) To require the removal of all such illicit connections; (4) To comply with state and federal statutes and regulations relating to stormwater discharges; (5) To establish the legal authority to ensure compliance with the provisions of this ordinance through inspection, monitoring, and enforcement. Increased and contaminated stormwater runoff are major causes of: (1) Impairment of water quality and flow in lakes, ponds, streams, rivers, wetlands and groundwater; (2) Contamination of drinking water supplies; (3) Alteration or destruction of aquatic and wildlife habitat; and (4) Local flooding. SECTION 2. DEFINITIONS For the purposes of this ordinance, the following shall mean: Active Groundwater Dewatering (AGD) Device: Any active device used to transport groundwater, i.e. a sump pump. Authorized Enforcement Agency: The Director of the Department of Public Works or designated representative, its employees or agents designated to enforce this ordinance. Best Management Practice (BMP): An activity, procedure, restraint, or structural improvement that helps to reduce the quantity or improve the quality of stormwater runoff. BMPs also include treatment practices, operating procedures, and practices to control site runoff, spillage or leaks, sludge or water disposal, or drainage from raw materials storage. Clean Water Act: The Federal Water Pollution Control Act (33 U.S.C. 1251 et seq.) as hereafter amended. Discharge of Pollutants: The addition from any source of any pollutant or combination of pollutants into the municipal storm drain system or into the waters of the United States or Commonwealth from any source. Grandfathered: Exempt from new legislation, restrictions, or requirements. Groundwater: All water beneath the surface of the ground. Illicit Connections Bylaw / Ordinance 2 ED_019088A_00020378-00058 Illegal Discharge: Any direct or indirect non - stormwater discharge to the municipal storm drain system, except as specifically exempted in Section 7 of this ordinance. The term does not include a discharge in compliance with an NPDES Storm Water Discharge Permit or resulting from fire fighting activities exempted pursuant to Section 7 of this ordinance. Illicit Connection: Any surface or subsurface drain or conveyance, which allows an illegal discharge into the municipal storm drain system. Illicit connections include conveyances which allow a non - stormwater discharge to the municipal storm drain system, including: sewage, process wastewater or wash water and any connections from indoor drainages sinks, or toilets, regardless of whether said connection was previously allowed, permitted, or approved before the effective date of this ordinance. Impervious Surface: Any material or structure on or above the ground that prevents water from infiltrating the underlying soil. Impervious surface includes, without limitation, roads, paved parking lots, sidewalks, and roof tops. Municipal separate storm sewer system (MS4) or municipal storm drain system: The system of conveyances designed or used for collecting or conveying stormwater, including any road with a drainage system, street, gutter, curb, inlet, piped storm drain, pumping facility, retention or detention basin, natural or man - made or altered drainage channel, reservoir, and other drainage structure that together comprise the storm drain system owned or operated by the City of Holyoke. National Pollutant Discharge Elimination System (NPDES) Storm Water Discharge Permit: A permit issued by United States Environmental Protection Agency or jointly with the State that authorizes the discharge of pollutants to waters of the United States. Non - Stormwater Discharge: Any discharge to the municipal storm drain system not composed entirely of stormwater. Person: Any individual, partnership, association, firm, company, trust, corporation, and, any agency, authority, department or political subdivision of the Commonwealth or the federal government, to the extent permitted by - law, and any officer, employee, or agent of such person. Pollutant: Any element or property of sewage, agricultural, industrial or commercial waste, runoff, leachate, heated effluent, or other matter whether originating at a point or nonpoint source, that is or may be introduced into any sewage treatment works or waters of the Commonwealth. Pollutants shall include: (1) paints, varnishes, and solvents; (2) oil and other automotive fluids; (3) liquid and solid wastes and yard wastes; (4) refuse, rubbish, garbage, litter, or other discarded or abandoned objects, ordnances, accumulations and floatables; (5) pesticides, herbicides, and fertilizers; Illicit Connections Bylaw / Ordinance 3 ED_019088A_00020378-00059 (6) hazardous materials and wastes; sewage, fecal coliform and pathogens; (7) dissolved and particulate metals; (8) animal wastes; (9) rock; sand; salt, soils; (10) construction wastes and residues; (11) and noxious or offensive matter of any kind. Process wastewater means any water which, during manufacturing or processing, comes into direct contact with or results from the production or use of any material, intermediate product, finished product, or waste product. Recharge: The process by which groundwater is replenished by precipitation through the percolation of runoff and surface water through the soil. Storm Drain System: The system of conveyance designed or used for collecting or conveying stormwater, including any road with a drainage system, street, gutter, curb, inlet, piped storm drain, pumping facility, retention, or detention basin, natural or man - made or altered drainage channel, reservoir, and other drainage structure that together comprise the storm drain system on public or private ways within the City of Holyoke. Stormwater: Runoff from precipitation or snow melt. Toxic or Hazardous Material or Waste: Any material, which because of its quantity, concentration, chemical, corrosive, flammable, reactive, toxic, infectious or radioactive characteristics, either separately or in combination with any substance or substances, constitutes a present or potential threat to human health, safety, welfare, or to the environment. Toxic or hazardous materials include any synthetic organic chemical, petroleum product, heavy metal, radioactive or infectious waste, acid and alkali, and any substance defined as Toxic or Hazardous under M.G.L. Ch.21C and Ch.21E, and the regulations at 310 CMR 30.000 and 310 CMR 40.0000. Wastewater: any sanitary waste, sludge, or septic tank or cesspool overflow, and water that during manufacturing, cleaning or processing, comes into direct contact with or results from the production or use of any raw material, intermediate product, finished product, byproduct or waste product. Watercourses: A natural or man - made channel through which water flows or a stream of water, including a river, brook or underground stream. Waters of the Commonwealth: all waters within the jurisdiction of the Commonwealth, including, without limitation, rivers, streams, lakes, ponds, springs, impoundments, estuaries, wetlands, costal waters, and groundwater. Illicit Connections Bylaw / Ordinance ED_019088A_00020378-00060 SECTION 3. APPLICABILITY This ordinance shall apply to all flows entering the storm drain system owned and operated by the City of Holyoke. SECTION-4. AUTHORITY This bylaw / ordinance is adopted under the authority granted by the Home Rule Amendment of the Massachusetts Constitution and the Home Rule Procedures Act, and pursuant to the regulations of the federal Clean Water Act found at 40 CFR 122: 34. SECTION 5. RESPONSIBILITY FOR ADMINISTRATION The Director of the Department of Public Works or designated representative shall administer, implement and enforce this ordinance. Any powers granted to or duties imposed upon the Director of the Department of Public Works may be delegated in writing by the Director of the Department of Public Works to employees or agents of the Department of Public Works. SECTION _6. REGULATIONS The Director of the Department of Public Works may promulgate rules and regulations to effectuate the purposes of this ordinance. Failure by the Director of the Department of Public Works to promulgate such rules and regulations shall not have the effect of suspending or invalidating this ordinance. SECTION 7. PROHIBITED ACTIVITIES 1. Illegal Discharges No person shall dump, discharge, cause or allow to be discharged any pollutant or non- stormwater discharge into any storm drain system, watercourse, or into the waters of the Commonwealth. Emergency pumping performed by the Fire Department must utilize appropriate best management practices (BMPs) and follow hazardous materials disposal guidelines to prevent contamination of the municipal storm drain system with hazardous materials. If hazardous materials are observed within the flooded area from the activities noted above, or are suspected to be contained therein, a qualified hazmat technician and applicable state and local agencies must be consulted. These agencies will be responsible for implementing the BMPs to the contamination of nearby water ways and the municipal storm drain system. 2. Illicit Connections No person shall construct, use, allow, maintain or continue any illicit connection to the municipal storm drain system, regardless of whether the connection was permissible under applicable law, regulation or custom at the time of connection. No grandfathering is permitted. Illicit Connections Bylaw / Ordinance 5 ED_019088A_00020378-00061 3. Obstruction of the Municipal Storm Drain System No person shall obstruct or interfere with the normal flow of stormwater into or out of the storm drain system without prior approval from the Director of the Department of Public Works or designated representative. No person shall dump or dispose of yard waste (leaves, grass clippings, etc.) into the MS4, or into open watercourses (swales, brooks and streams). Could add the following to elaborate if desired: a. Drains - No one shall tie any pump, cellar, yard, roof or area drain directly into the storm drain system without approval from the Applicable Authority. b. Catch Basins - No Person shall directly or indirectly dump, discharge or cause or allow to be discharged into any catch basin, any solid waste, construction debris, paint or paint product, antifreeze, hazardous waste, oil, gasoline, grease and all other automotive and petroleum products, solvents and degreasers, drain cleaners, commercial or household cleaners, soap, detergent, ammonia, food and food waste, grease or yard waste, animal feces, dirt, sand gravel or other pollutant. Any person determined by the applicable authority to be responsible for the discharge of any of the above substances to a catch basin may be held responsible for cleaning the catch basin and any other portions of the storm water system impacted according to City / Town standards and requirements or paying the cost for such cleaning. In addition, the Person shall be responsible for paying any penalties assessed by the City / Town. C. Septage - No person shall discharge or cause or allow to be discharged any septage, or septage tank or cesspool overflow into the City / Town's storm drain system. d. Storage & Disposal of Hazardous Material - No one shall dispose of anything other than clear water into the City / Town's storm drain system. The disposal of waste, gasoline or any other hazardous material into the storm drain system is strictly prohibited and is in violation of state and federal pollution laws. e. Private drainage systems - It is prohibited for anyone with a private drainage system from tying into the public storm drain system without written approval from the Applicable Authority. The maintenance of any and all private drainage systems shall be the responsibility of the owners. 4. Exemptions This section shall not apply to any of the following non - stormwater discharges or flows provided that the source is not a significant contributor of a pollutant to the storm drain system. (a.) Discharges or flows resulting from fire fighting activities; (b) Municipal waterline flushing (c) Discharges from landscape irrigation or lawn watering (d) Diverted stream flows Illicit Connections Bylaw / Ordinance 6 ED_019088A_00020378-00062 (e) Rising groundwater (f) Uncontaminated groundwater infiltration as defined in 40 CFR 35.2005 (20), or uncontaminated pumped groundwater (g) Flows from potable water sources (h) Water from exterior foundation drains, footing drains (not including active groundwater dewatering systems) (i) Irrigation water, springs (j)Water from crawl space pumps (k) Water from individual residential car washing (1)Natural flows from riparian habitats and wetlands (m) Discharges from de - chlorinated swimming pool water provided it is allowed to stand for one week prior to draining, or tested for chlorine levels with a pool test kit prior to draining (less than one parts per million chlorine), and the pool is drained in such a way as not to cause a nuisance; (n) Discharges from street sweepers of minor amounts of water during operation and other storm drain system maintenance; (o) Dye testing, provided notification is given to the Director of the Department of Public Works or designated representative prior to the time of the test; (p) Non - stormwater discharges permitted under an NPDES permit, waiver, or waste discharge order administered under the authority of the United States Environmental Protection Agency, provided that the discharge is in full compliance with the requirements of the permit, waiver, or order and applicable laws and regulations; (q) Discharges for which advanced written approval is received from the Director of the Department of Public Works or designated representative if necessary to protect public health, safety, welfare or the environment. (r) Emergency repairs to either the municipal storm drain system, or any stormwater management structure or practice that poses a threat to public health or safety, or as deemed necessary by the Town. SECTION 8. EMERGENCY SUSPENSION OF STORM DRAIN SYSTEM ACCESS The Director of the Department of Public Works or designated representative may suspend storm drain system access to any person or property without prior written notice when such suspension is necessary to stop an actual or threatened illegal discharge that presents or may present imminent risk of harm to the public health, safety, welfare or the environment. In the event any person fails to comply with an emergency suspension order, the Director of the Illicit Connections Bylaw / Ordinance7 ED_019088A_00020378-00063 Department of Public Works or designated representative may take all reasonable steps to prevent or minimize harm to the public health, safety, welfare or the environment. Not required by MS4 permit, but may be useful addition in some municipalities: SECTION WATERCOURSE PROTECTION Every person owning property through which a watercourse passes, or such person's lessee, shall keep and maintain that part of the watercourse within the property free of trash, debris, and other obstacles that would pollute, contaminate, or significantly retard the flow of water through the watercourse. In addition, the owner or lessee shall maintain existing privately owned structures within or adjacent to a watercourse so that such structures will not become a hazard to the use, function, or physical integrity of the watercourse. Failure by the property owner to maintain the watercourse does not constitute an obligation on the part of the Town to assume this responsibility. SECTION 9. NOTIFICATION OF SPILLS Notwithstanding any other requirements of local, state or federal law, as soon as any person responsible for a facility or operation, or responsible for emergency response for a facility or operation has information of any known or suspected release of materials at that facility operation which is resulting or may result in illegal discharge of pollutants that person shall take all necessary steps to ensure containment, and cleanup of the release. In the event of a release of oil or hazardous materials, the person shall immediately notify the municipal fire and police departments, the Director of the Department of Public Works or designated representative, and the Massachusetts Department of Environmental Protection (if release is reportable as defined by 310 CMR 40.00). In the event of a release of non - hazardous material, said person shall notify the Director of the Department of Public Works or designated representative no later than the next business day. Written confirmation of all telephone, facsimile or in person notifications shall be provided to the Director of the Department of Public Works or designated representative within three business days thereafter. If the discharge of prohibited materials is from a commercial or industrial facility, the facility owner or operator of the facility shall retain on - site a written record of the discharge and the actions taken to prevent its recurrence. Such records shall be retained for at least three years. SECTION 10. ENFORCEMENT 1. The Director of the Department of Public Works or an authorized agent of the Department of Public Works shall enforce this ordinance, and the regulations promulgated thereunder, as well as the terms and conditions of all permits, notices, and orders, and may pursue all civil and criminal remedies for such violations. 2. Orders The Director of the Department of Public Works or designated representative may issue a written order to enforce the provisions of this ordinance or the regulations thereunder, which include, but are not limited to: (a) Elimination of illicit connections or discharges to the storm drain system; (b) Termination of access to the storm drain system; Illicit Connections Bylaw / Ordinance 8 ED_019088A_00020378-00064 (c) Performance of monitoring, analyses, and reporting; (d) Cessation of unlawful discharges, practices, or operations; (e) Remediation of contamination in connection therewith. (f) Implementation of source control or treatment BMPs If the Director of the Department of Public Works or designated representative determines that abatement or remediation of contamination is required, the order shall set forth a deadline for completion of the abatement or remediation. Said order shall further advise that, should the violator or property owner fail to abate or perform remediation within the specified deadline, the City of Holyoke may, at its option, undertake such work and expenses thereof shall be charged to the violator or property owner. Within thirty (30) days after completing all measures necessary to abate the violation or to perform remediation, the violator and the property owner will be notified of the costs incurred by the City of Holyoke, including administrative costs for which payment is due to the City of Holyoke. The violator or property owner may file a written protest or appeal objecting to the amount or basis of costs with the City Council within thirty (30) days of receipt of the notification of the costs incurred. If the amount due is not received by the expiration of the time in which to file a protest or within thirty (30) days following a decision of the City Council or designated representative affirming or reducing the costs, or from a final decision of a court of competent jurisdiction, the costs shall become a special assessment against the property owner and shall constitute a lien on the owner's property for the amount of said costs pursuant to MGL Ch. 40, 58. Interest shall begin to accrue on any unpaid costs at the statutory rate provided in M.G.L. Ch. 59, 57 after the thirty - first day at which the costs first become due. 3. Equitable Remedy If anyone violates the provisions of this ordinance, regulations, permit, notice, or order issued thereunder, the Director of the Department of Public Works or designated representative may seek injunctive relief in a court of competent jurisdiction to restrain the person from activities which would create further violations or compelling the person to abate or remediate the violation. 4. Criminal penalty Any person who violates any provision of this Bylaw / Ordinance, regulation, order or written approval issued thereunder, shall be punished by a fine not to exceed $ 300 per violation. Each day or part thereof that such violation occurs or continues shall constitute a separate offense. 5. Non - Criminal Disposition As an alternative to criminal prosecution or civil action, the City of Holyoke may elect to utilize the non - criminal disposition procedure set forth in M.G.L. Chapter 40, 21D. The Director of the Department of Public Works or designated representative shall be the enforcing person. The penalty for the 1st violation shall be up to $ 100. The penalty for the 2nd violation shall be $ 200. The penalty for the 3rd and subsequent violations shall be $ 300.00. Each day or part thereof that such violation occurs or continues shall constitute a separate offense. Illicit Connections Bylaw / Ordinance ED_019088A_00020378-00065 6. Right - of - Entry To the extent permitted by state law, or if authorized by the owner or other party in control of the property, the Director of the Department of Public Works or designated representative, its agents, officers, and employees may enter upon privately owned property for the purpose of performing their duties under this ordinance and regulations and may make or cause to be made such examinations, surveys or sampling as the Director of the Department of Public Works or designated representative deems reasonably necessary Be advised that any entry without express permission of the owner should be by warrant. Generally, the 4th Amendment to the U.S. Constitution prohibits entry onto private property without the express consent of the owner or person in charge, a warrant or exigent circumstances. Although there are similar provisions in regulations concerning commercial uses, residential property is generally afforded greater protections. Because private property rights are generally afforded rigid protections by Massachusetts courts, use of this provision may expose the Town to liability. Therefore, if you are going to include this provision, I recommend that it be used sparingly. Recommendation to Town of Belchertown by Koppleman & Paige 7. Appeals The decisions or orders of the Director of the Department of Public Works shall be final. Further relief shall be to a court of competent jurisdiction. 8. Remedies Not Exclusive The remedies listed in this ordinance are not exclusive of any other remedies available under any applicable federal, state or local law. SECTION-11. SEVERABILITY If any provision, paragraph, sentence, or clause, of this Bylaw / Ordinance or the application thereof to any person, establishment, or circumstances, shall be held invalid for any reason, such invalidity shall not affect any other provisions or applications of this Bylaw, and shall continue in full force and effect. SECTION 12. TRANSITIONAL PROVISIONS Property owners shall have days from the effective date of the ordinance to comply with its provisions provided good cause is shown for the failure to comply with the ordinance during that period unless local, state, or federal agencies deem that immediate actions are warranted Illicit Connections Bylaw / Ordinance 10 ED_019088A_00020378-00066 APPENDIX E FIELD INSPECTION FORMS KLEINFELDER Bright People. Right Solutions. 20233959.001A / BOS23R154074 May 2023 ED_019088A_00020378-00067 Manhole Inspection ReportStructural Information: MH #ACover Size:24 " 30 " Other: Catchment Area: Inspector: MH Size:4 '5 'Other: MH Sump:Y / NSump Depth: Date / Time:BCMH Channel:Y / N Weather: Street / Location: Weir:Y / N Rim to Top of Weir: General Comments: Internal Drop:Y / N (Hold " D " as outlet) DDepth to Wet Ring from Rim: General Information: Manhole Type: Sanitary Storm Combined Common Location of MH: Roadway Sidewalk Roadside Alley Easement Other Manhole Material:BrickClay BlockPoured ConcreteManhole BlockPrecast ConcreteOther Paved Area Around MH:SatisfactoryCrackedMissing PavementVegetation Growth Unpaved Area Around MH: SatisfactoryEroded Odors: Recommendations:No ActionRebuildLine Manhole WallReset FrameClean / Remove debris from Invert Field Test Kit Results: Pipe (A-F): Ammonia, mg / L (Compliant > 0.5 mg / L) Surfactants, mg / L (Compliant > 0.25 mg / L) Chlorine, mg / L (Compliant < 0.02 mg / L) Pipe Information: PipeFrom / ToInvert DepthFlow DepthDebris Depth MaterialConditionFlowClarity of Flow SizeMH #(from Rim)(from Invert)(from Invert) A. B. C. D. E. F. ED_019088A_00020378-00068 OUTFALL INVENTORY FIELD SHEET Section 1: Background Data City / Town:Street:Tax Map #:Outfall ID: OF- Owner:CityStatePrivateOther:Nearest House / Utility Pole #: Today's date:Time (Military): Investigators:Form completed by: Temperature ( F):Rainfall (in.): Last 24 hours:Last 48 hours: Northing:Easting:GPS Unit:GPS LMK #: Rim Elevation:Invert Elevation: Elevation Datum:Receiving Water: Camera:Photo #s:-- Take 1 Upstream (head on) and 1 Downstream view Land Use in Drainage Area (Check all that apply): IndustrialOpen Space Urban ResidentialInstitutional Suburban ResidentialOther: CommercialKnown Industries: Notes (e.g.., origin of outfall, if known): Section 2: Outfall Description TYPEMATERIALSHAPEDIMENSIONS (IN.)SUBMERGED Closed Pipe RCPCMPCircularSingleDiameter / Dimensions:In Water: No PVC HDPE Elliptical DoublePartially Fully Steel Box Triple With Sediment: No Other: Other: Other: Partially Fully Concrete Pavement / Scupper Trapezoid Depth: Open drainageEarthenParabolicTop Width: rip - rap Other: Bottom Width: Other: Flow Present?YesNoIf No, Skip to Section 3. If Yes, Notify Town and continue field reconnaissance. Flow Description (If present) TrickleModerateSubstantialFlow Direction (If Present): Section 3: Sketch Page 1 of 2 ED_019088A_00020378-00069 Outfall Inventory Field Sheet Section 4: Physical Indicators for Flowing Outfalls Only Are Any Physical Indicators Present in the flow?YesNo(If No, Skip to Section 5) CHECK if INDICATORDESCRIPTIONRELATIVE SEVERITY INDEX (1-3) Present SewageRancid / sourPetroleum / gas3-Noticeable from a Odor1-Faint2-Easily detected Sulfide Other:distance Color ClearBrownGrayYellow1-Faint colors in2-Clearly visible in3-Clearly visible in Green Orange Red Other: outfall flow outfall flow outfall flow TurbiditySee severity1-Slight cloudiness2-Cloudy3-Opaque FloatablesSewage (Toilet Paper, etc.)Suds -Does Not Include 2-Some; indications3-Some; origin clear 1-Few / slight; originof origin (e.g.,(e.g., obvious oil Trash!! Petroleum (oil sheen)Other:not obviouspossible suds or oilsheen, suds, or floating sheen)sanitary materials) Section 5: Physical Indicators for Both Flowing and Non - Flowing Outfalls Are physical indicators that are not related to flow present?YesNo(If No, Skip to Section 6) CHECK if INDICATOR DESCRIPTION COMMENTS Present Outfall Damage Spalling, Cracking or ChippingPeeling Paint Corrosion Deposits / StainsOily Flow Line Paint Other: Abnormal VegetationExcessive Inhibited Poor pool quality Odors Colors Floatables Oil Sheen SudsExcessive AlgaeOther: Pipe benthic growth Brown Orange Green Other: Section 6: Potential for Illicit Discharge UnlikelyPotential (presence of two or more indicators)Suspect (one or more indicators with a severity of 3)Obvious Section 7: Any Non - Illicit Discharge Concerns (e.g., trash or needed infrastructure repairs)? Page 2 of 2 ED_019088A_00020378-00070 Illicit Discharge Incident Tracking Sheet Incident ID: Responder Information (for Citizen - Reported issues) Call Taken By:Call Date: Call Time:Precipitation (inches) in past 24-48 hours: Observer Information Date and Time of Observation:Observed During Regular Maintenance or Inspections? Yes No Caller Contact Information (optional) or Municipal Employee Information: Observation Location: (complete one or more below) Latitude and Longitude: Stream Address or Outfall #: Closest Street Address: Nearby Landmark: Primary Location DescriptionSecondary Location Description: Stream Corridor (In or adjacent to stream)OutfallIn - stream FlowAlong Banks Upland Area (Land not adjacent to stream)Near StormNear other water source Drain(stormwater pond, wetland, ect.): Narrative description of location: Upland Problem Indicator Description Dumping Oil / Solvents / Chemicals Sewage Detergent, suds, etc.Other: Stream Corridor Problem Indicator Description OdorNone Sewage] Rancid / Sour Petroleum (gas) Sulfide (rottenOther: Describe in " Narrative " section eggs); natural gas Appearance " Normal " Oil Sheen Cloudy Foam Optical enhancersDiscolored Other: Describe in " Narrative " section FloatablesNoneSewage (toiletAlgaeTrash or paper, etc)debris Other: Describe in " Narrative " section Narrative description of problem indicators: Suspected Source (name, personal or vehicle description, license plate #, address, etc.): July 2013Page 1 of 1 CMRSWC ED_019088A_00020378-00071 APPENDIX F INSTRUCTIONS, MANUALS, AND SOPS KLEINFELDER Bright People. Right Solutions. 20233959.001A / BOS23R154074 May 2023 ED_019088A_00020378-00072 Standard Operating ProceduresCity of Holyoke KLEINFELDER Bright People. Right Solutions. Illicit Discharge Detection and Elimination Plan SOP 1: Dry Weather Outfall Inspection SOP 1: DRY WEATHER OUTFALL INSPECTION Introduction Outfalls can be in the form of pipes or ditches and is the final point of discharge into a body of water for an engineered storm drain system. Current and pending regulations require that all outfalls, that are part of the storm drain system, be inspected, and that the water quality at these outfalls be analyzed under both dry and wet weather conditions. " SOP 2: Wet Weather Outfall Inspection, " covers the objectives for wet weather outfall 1 inspections. This SOP discusses the objectives of dry weather outfall inspections. During a dry weather period, it is expected that minimal flow will be observed, if at all, at any stormwater outfall. As such, the objective of dry weather outfall inspections is to analyze the presence of any flow at each stormwater outfall and identify any potential source(s) of an illicit discharge further described in " SOP 3: Locating Illicit Discharges. " As per the Consent Decree, by May 31st, 2023, the City of Holyoke (the City) shall submit to the EPA for review an Illicit Discharge Detection and Elimination (IDDE) Plan which includes screening and monitoring all known MS4 outfalls and interconnections under dry weather conditions. As defined in the Consent Decree, the City shall conduct dry - weather inspections only when no more than 0.1 inches of rainfall or significant snowmelt has 2 occurred in the preceding 24 hours, but 48 hours when possible. Unlike wet weather sampling, dry weather inspections are not intended to capture a " first flush " event, but rather identify any discharge that may be present at a stormwater outfall during a period without recorded rain or snowmelt in order to facilitate the detection of an illicit discharge. Catchment Investigations In order to determine the approximate location of suspected illicit discharges, the first step is to complete an investigation of the storm drain system under dry weather conditions. This includes systematically and progressively observing, sampling, and evaluating key junction manholes and sump manholes within the City. The City's DPW is responsible for completing catchment investigations, incorporating updates to the City's infrastructure into their storm system maps, and refining catchment delineations based on field investigations. 1 Standard Operating Procedures. Central Massachusetts Regional Stormwater Coalition. (n.d.). Retrieved January 16, 2023, from https://www.centralmastormwater.org/toolbox/pages/standard-operating-procedures 2 Civil Action No. 19-CV-10332-MGM: Final Consent Decree. " United States District Court for the District of Massachusetts, United States and Massachusetts v. City of Holyoke, September 27, 2022. Project No. 20233959.001Page 1 of 11February 2023 2023 Kleinfelderwww.kleinfelder.com KLEINFELDER One Beacon Street, Suite 8100, Boston, MA 02108 p | 617.497.7800 f | 617.498.4630 ED_019088A_00020378-00073 COPLA Standard Operating ProceduresCity of Holyoke KLEINFELDER Bright People. Right Solutions. Illicit Discharge Detection and Elimination Plan SOP 1: Dry Weather Outfall Inspection As per the 2016 Massachusetts Small MS4 General Permit, the following definitions of important terms related to 3 the dry weather manhole inspection program are as follows: Junction Manhole is a manhole or structure with two or more inlets accepting flow from two or more 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. 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. A pictorial example of junction manholes and how they relate to key junction manholes can be found in Figure 1 below. Junction Manholes Key Junction Manhole Figure 1-Junction vs. Key Junction Manholes * Common Manholes have connections to both the sewer and drain system and therefore provide a potential for cross - contamination. In addition to the manhole types identified above, sump manholes may also be located in the City's system. These structures have a significant difference in elevation between the bottom of the structure and bottom of the outlet pipe. This difference in elevation, also known as a sump, could potentially allow illicit discharges to collect and, as a result, not flow downstream. In preparation for field inspections, the City's DPW should identify all key junction manholes, mainline sump manholes, as well as any potential connections to other catchments such as weirs or overflows. These structures will then systematically be inspected for evidence of illicit discharges, and if found, eventual isolation and elimination. Prior to field investigations, the City shall notify property owners of upcoming investigations via flyers and / or door hangers. Ideally, storm drains and sump manholes should be cleaned prior to investigations, but it is not required. Specifically, any known problem areas or areas with known blockages should be prioritized for cleaning. 3 United States Environmental Protection Agency (EPA). (n.d.). General Permits for stormwater discharges from small municipal... -US EPA. Massachusetts Small MS4 General Permit. Retrieved January 16, 2023, from https://www3.epa.gov/region1/npdes/stormwater/ma/2016fpd/final-2016-ma-sms4-gp-mod.pdf Project No. 20233959.001Page 2 of 11February 2023 2023 Kleinfelderwww.kleinfelder.com KLEINFELDER One Beacon Street, Suite 8100, Boston, MA 02108 p | 617.497.7800 f | 617.498.4630 ED_019088A_00020378-00074 Standard Operating ProceduresCity of Holyoke KLEINFELDER Bright People. Right Solutions. Illicit Discharge Detection and Elimination Plan SOP 1: Dry Weather Outfall Inspection Once property owners have been notified and cleaning of the storm drain system has occurred, catchment investigations can begin. This can occur in one of two ways, or via a combination of both: (1) By working progressively down from the upper parts of the catchment toward the outfall (" Top Down ") or (2) By working progressively up from the outfall and inspecting key junction manholes along the way (" Bottom - Up "). Both methods have their advantages. Starting upstream can be more efficient, whereas starting downstream works well for small catchments that aren't influenced by receiving water bodies. As such, inspection direction can depend on the nature of the drainage system (e.g. size, receiving water influence) and also the completeness and accuracy of the City's GIS mapping. This can also depend on whether or not most outfalls are partially or totally submerged. In the event that manholes are partially or completely submerged, samples should not be collected. Rather these structures should be investigated furthered via building inspections, dye testing, or even bypass pumping so as to remove flow from the structure so it can be further visually inspected. Once an inspection direction has been chosen, the investigation can then begin with key junction manholes and mainline sump manholes. From here, the inspection can continue towards junction manholes and other manholes, as needed, with the purpose to isolate any illicit discharges. The specific steps shall be as follows: 1. Manholes will be opened and inspected for visual and olfactory evidence of illicit connections during dry weather. A sample manhole inspection report is provided in Attachment 1. Visual evidence may include toilet paper, sanitary products, sewage, soap, food, or other indications of anything other than stormwater. Olfactory evidence may include sewage, soap, laundry, bleach, or other odors not typical of stormwater. 2. Where possible, condition information and measured elevation of the manhole rim as well as the invert depth should be recorded. 3. If flow is observed, a sample shall be collected and analyzed in accordance with the procedures outlined in the following sections. 4. If no flow is observed, the inlet or outlets to the manholes may be partially blocked using sandbags or similar barriers. More details associated with this method can be found in " SOP 3: Locating Illicit Discharges. " 5. Where sampling results or visual or olfactory evidence indicate potential illicit discharges, the area draining to the manhole should be flagged for further upstream manhole investigation and / or isolation and confirmation of sources. 6. Subsequent manhole inspections shall proceed until the location of the suspected illicit discharges can be isolated to a pipe segment between two manholes. 7. If no evidence of an illicit discharge is found, catchment investigations will be considered complete upon completed of key junction manhole sampling. Condition Assessment If any flow is observed during dry weather conditions at a stormwater outfall, a sample shall be taken after a visual observation of the discharge is complete. If any pollution or signs of potential illicit connections are observed, they should be noted and investigated further. As per the Central Massachusetts Regional Stormwater Coalition, the 4 following visual indicators shown in Table 1 may be the result of the following sources listed in Table 1. 4 Standard Operating Procedures. Central Massachusetts Regional Stormwater Coalition. (n.d.). Retrieved January 16, 2023, from https://www.centralmastormwater.org/toolbox/pages/standard-operating-procedures Project No. 20233959.001Page 3 of 11February 2023 2023 Kleinfelderwww.kleinfelder.com KLEINFELDER One Beacon Street, Suite 8100, Boston, MA 02108 p | 617.497.7800 f | 617.498.4630 ED_019088A_00020378-00075 Standard Operating ProceduresCity of Holyoke KLEINFELDER Bright People. Right Solutions. Illicit Discharge Detection and Elimination Plan SOP 1: Dry Weather Outfall Inspection Table 1-Visual Condition Assessment IndicatorPossible Source Foamupstream vehicle washing activities or illicit discharge Oil Sheenleak or spill Cloudinesssuspended solids (i.e. dust, ash, powdered chemicals, ground up materials, etc.) Color or Odorraw materials, chemicals, or sewage Excessive Sedimentdisturbed earth of unpaved areas lacking adequate erosion control measures Sanitary Waste / Optical Enhancers * illicit discharge Orange Staininghigh mineral concentrations Fluorescent dyes added to laundry detergent and some toilet paper While many of the indicators listed in Table 1 would indicate an illicit discharge, some indicators may occur naturally. For example, orange staining could be the result of naturally occurring iron. However, it may be difficult to determine the difference between natural foam and foam caused by pollution. Natural foam can typically be found in water with high organic content such as bog lakes, streams that originate from bog lakes, productive lakes, wetlands, or woody areas. As per the Central Massachusetts Regional Stormwater Coalition, it's important to consider the following factors listed in Table 2 when determining if the source of foam present at a stormwater 5 outfall is natural or not. Table 2-Conditional and Qualitative Considerations of Foam Factors Explanation Wind Direction or Turbulence Natural foam occurrences of the beach coincide with onshore winds. Often, foam can be found along a shoreline and / or on open waters during windy days. Natural occurrences in rivers can be found downstream of a turbulent site. Proximity to Potential Pollution Source Some entities including the textile industry, paper production facilities, oil industries, and fire fighting activities work with materials that cause foaming in water. If these materials are released to a water body in large quantities, they can cause foaming. The presence of silt in water, such as from a construction site can cause foam. Physical FeelingNatural foam is typically persistent, light, not slimy to the touch. Visual ObservationPrescence of decomposing plants or organic material in the water. In addition to foam, both bacteria and petroleum can create a sheen on the water surface. Differentiating the two can be as simple as disturbing the " sheen " with a pole, stick, or similar object. A sheen caused by oil will remain intact and move in a swirl pattern while a sheen caused by bacteria will separate into a number of smaller patches and appear " blocky. " In addition, bacteria or naturally occurring sheens are usually silver or dull in color. While 6 bacterial sheen is not a pollutant, it should be noted when describing the discharge. 5 Standard Operating Procedures. Central Massachusetts Regional Stormwater Coalition. (n.d.). Retrieved January 16, 2023, from https://www.centralmastormwater.org/toolbox/pages/standard-operating-procedures 6 Standard Operating Procedures. Central Massachusetts Regional Stormwater Coalition. (n.d.). Retrieved January 16, 2023, from https://www.centralmastormwater.org/toolbox/pages/standard-operating-procedures Project No. 20233959.001Page 4 of 11February 2023 2023 Kleinfelderwww.kleinfelder.com KLEINFELDER One Beacon Street, Suite 8100, Boston, MA 02108 p | 617.497.7800 f | 617.498.4630 ED_019088A_00020378-00076 COPLA Standard Operating ProceduresCity of Holyoke KLEINFELDER Bright People. Right Solutions. Illicit Discharge Detection and Elimination Plan SOP 1: Dry Weather Outfall Inspection Optical enhancers on the other hand can be visible to the naked eye when found in high enough concentrations and will appear as a bluish - purple haze. If a visual observation is unable to confirm the presence of this pollutant, a quantitative test can be used. In order to perform this test, a clean, white, cotton pad should be placed, either directly in, or within a sample of, the discharge for several days. After soaking, the cotton pad should be dried and then viewed under a fluorometer. If the cotton pad fluoresces, optical enhancers are assumed to be the pollutant and present. The magnitude of the fluorescence, as measured in fluorescent units, can be used to determine the concentration of optical enhancers within the sample. Often a visual observation is enough as it is not typical that this analysis is required. Sample Collection Table 3 lists the field equipment commonly used for dry weather outfall screening and sampling. Table 3-Field Equipment for Dry Weather Outfall Screening and Sampling Equipment Use / Notes ClipboardFor organization of field sheets and writing surface Field Forms or Tablet for Electronic Forms Field sheets for both dry weather inspection and dry weather sampling should be available, with extra sheets included Chain of Custody FormsTo ensure proper handling of all samples Pens / Pencils / Permanent MarkersFor proper labeling Nitrile GlovesTo protect the sampler as well as the sample from contamination Flashlight / Headlamp w / BatteriesFor looking in outfalls or manholes, helpful in early mornings as well Cooler with IceFor transporting samples to the laboratory Digital CameraFor documenting field conditions at time of inspection Personal Protective Equipment (PPE) Reflective vest, safety glasses, hard hats, and boots at a minimum. Work gloves, long pants, and sleeves for protection from environmental conditions such as brush, insects, and poisonous plants. Insect / Plant Repellant and SunscreenFor protection from environmental conditions. GPS ReceiverFor taking spatial location data Distilled waterFor use with test kits and water quality meters Water Quality MetersHand - held meters for testing various water quality parameters. Field Test Kits Have extra kits on hand to sample more outfalls than are anticipated to be screened in a single day Rinse Water / Calibration standardsCleaning equipment and calibration Label TapeFor labeling sample containers Make sure all sample containers are clean. Keep extra sample containers on hand at all times. Sample ContainersMake sure there are proper sample containers for what is being sampled for (i.e., bacteria and total phosphorus analysis require sterile containers and preservatives). Telescopic Sampling Pole / Dipper for hard to reach locations. Cooler with IceLaboratory sample submittals Project No. 20233959.001Page 5 of 11February 2023 2023 Kleinfelderwww.kleinfelder.com KLEINFELDER One Beacon Street, Suite 8100, Boston, MA 02108 p | 617.497.7800 f | 617.498.4630 ED_019088A_00020378-00077 COPLA Standard Operating ProceduresCity of Holyoke KLEINFELDER Bright People. Right Solutions. Illicit Discharge Detection and Elimination Plan SOP 1: Dry Weather Outfall Inspection EquipmentUse / Notes Pry Bar, Pick, and / or ShovelFor opening catch basins and manholes when necessary SandbagsFor damming low flows in order to take samples Small Mallet or HammerHelping to free stuck manhole and catch basin covers Utility KnifeMultiple uses Measuring TapeMeasuring distances and depth of flow Traffic ConesSafety Hand SanitizerDisinfectant / decontaminant Machete / ClippersAccessing overgrown infrastructure Flashlight with batteriesFor looking in outfalls, manholes, and catch basins Zip Ties / Duct TapeFor making field repairs Rubber Boots / WadersFor accessing shallow streams / areas Sampling Pole / Dipper / Sampling CageFor accessing hard - to - reach outfalls and manholes 5-gallon Bucket w / CoverDisposal of chemical waste DBI Sali Tripod and retrieval wench; MSA Tripod, rescue wench and Confined Space Entry Equipment (if needed)material / personal wench; full body harness; 10'ladder; waders; hard hat; air monitoring equipment (Ventis 4 gas meter) As per the 2016 Massachusetts Small MS4 General Permit, where dry weather flow is found at an 7 outfall / interconnection, at least one (1) sample shall be collected. A discrete manual or grab sample shall be collected for dry weather outfall inspections due to the time - sensitive nature of the process. Grab samples classify water at a distinct point in time and are used primarily when the water quality of the discharge is expected to be homogenous, or unchanging, in nature. A flow - weighted composite sample classifies water quality over a measured period of time and are used when the water quality of discharge is expected to be heterogenous, or 8 fluctuating, in nature. " Protocols for collecting a grab sample as per the Central Massachusetts Regional Stormwater Coalition are as follows: 1. Fill out sample information on sample bottles and field sheets (see Attachment 4 for example field sheets). 2. Do not eat, drink, or smoke during sample collection and processing. 3. Do not collect or process samples near a running vehicle. 4. Do not park vehicles in the immediate sample collection area, including both running and non - running vehicles. 5. Always wear clean, powder - free nitrile gloves when handling sample containers and lids. 6. Never touch the inside surface of a sample container or lid, even with gloved hands. 7. Never allow the inner surface of a sample container or lid to be contacted by any material other than the sample water. 7 United States Environmental Protection Agency (EPA). (n.d.). General Permits for stormwater discharges from small municipal... - US EPA. Massachusetts Small MS4 General Permit. Retrieved January 16, 2023, from https://www3.epa.gov/region1/npdes/stormwater/ma/2016fpd/final-2016-ma-sms4-gp-mod.pdf 8 Standard Operating Procedures. Central Massachusetts Regional Stormwater Coalition. (n.d.). Retrieved January 16, 2023, from https://www.centralmastormwater.org/toolbox/pages/standard-operating-procedures Project No. 20233959.001Page 6 of 11February 2023 2023 Kleinfelderwww.kleinfelder.com KLEINFELDER One Beacon Street, Suite 8100, Boston, MA 02108 p | 617.497.7800 f | 617.498.4630 ED_019088A_00020378-00078 Standard Operating ProceduresCity of Holyoke KLEINFELDER Bright People. Right Solutions. Illicit Discharge Detection and Elimination Plan SOP 1: Dry Weather Outfall Inspection 8. Collect sample with dipper or directly into sample containers. If possible, collect water while facing upstream of the flow into the sample bottles so as to not to disturb water or sediments in the outfall pipe or ditch. 9. Do not overfill sample containers, and do not dump out any liquid in them. Liquids are often added to sample containers intentionally by the analytical laboratory as a preservative or for pH adjustment. 10. Slowly lower the bottle into the water to avoid bottom disturbance and stirring up sediment. 11. Do not allow any object or material to fall into or contact the collected water sample. 12. Do not allow rainwater to drip from rain gear or other surfaces into sample containers. 13. Replace and tighten sample container lids immediately after sample collection. 14. Place laboratory samples on ice for analysis of bacteria and pollutants of concern. 15. Accurately label the sample with the time and location. 16. Document on the Dry Weather Outfall Inspection Survey that analytical samples were collected, specify parameters, and note the sample time on an Inspection Survey (see Attachment 2 and 3 for examples). This creates a reference point for samples. 17. Fill out chain - of - custody form for laboratory samples. 18. If using a dipper or other device, triple rinse the device with distilled water and then in water to be sampled, except for bacteria sampling. 19. Store used test strips and test kit waste / ampules properly in a 5-gallon bucket with a cover. Storage and disposal shall be coordinated with the City. 20. Decontaminate all testing personnel and equipment. Samples that are unable to be analyzed for parameters using field instrumentation require laboratory analysis. Coordination with the laboratory, including the pick - up and / or dropping off, of samples, is the responsibility of the City. The laboratory requires that a chain - of - custody form be filled out and accompany any samples that require analysis. The laboratory will also provide additional details regarding how samples should be collected based on the sample containers and / or specific analytes. Project No. 20233959.001Page 7 of 11February 2023 2023 Kleinfelderwww.kleinfelder.com KLEINFELDER One Beacon Street, Suite 8100, Boston, MA 02108 p | 617.497.7800 f | 617.498.4630 ED_019088A_00020378-00079 Standard Operating ProceduresCity of Holyoke KLEINFELDER Bright People. Right Solutions. Illicit Discharge Detection and Elimination Plan SOP 1: Dry Weather Outfall Inspection Parameter Analysis As per the Consent Decree, the City shall utilize the following IDDE screening thresholds shown in Table 4 as 9 guidelines for its analysis of the data generated for each outfall and interconnection discharge sample. In addition, each outfall and interconnection discharge sample shall be concurrently analyzed for all the parameters shown using laboratory analysis or field instrumentation defined in Table 4 as per EPA's Region 1's " EPA New England 10 Bacteria Source Tracking Protocol, " January 2012 Draft. Table 4-Freshwater Water Quality Criteria, Threshold Limits, and Example Instrumentation Threshold Analyte / Indicator Limits / Instrumentation Single Sample E. coli 2> 410 cfu / 100mlLaboratory via approved method Enterococci 2130 cfu / 100mlLaboratory via approved method Surfactants (as> 0.25 mg / 1 MBAS Field Test Kit (e.g. CHEMetrics K- 9400) MBAS) > 0.1 mg / 1Laboratory via approved method Ammonia (NH3) > 0.5 mg / 1Ammonia Field Test Strips (e.g. Hach Brand) > 0.1 mg / 1Laboratory via approved method Chlorine> 0.02 mg / 1Field Meter (e.g. Hach Pocket Colorimeter II) TemperatureN / AField Meter (e.g. YSI Model 30) ConductivityN / AField Meter (e.g. YSI Model 30) SalinityN / AField Meter (e.g. YSI Model 30) A The mention of trade names or commercial products does not constitute endorsement or recommendation for use by the U.S. EPA B Class A or B Waters C Levels that may be indicative of potential wastewater or washwater contamination As per the 2016 Massachusetts Small MS4 General Permit and Consent Decree, all analyses, with the exception of indicator bacteria and pollutants of concern, can be performed with field tests or field instrumentation and are not subject to 40 CFR part 136 requirements. Sampling for bacteria and pollutants of concern shall be conducted using the analytical methods found in 40 CFR 136, or alternative methods approved by EPA in accordance with the 11 procedures in 40 CFR 136. The City is responsible for selecting a laboratory or field kits intended for measuring each analyte. When selecting field kits, review the detection range for each field kit and ensure it corresponds to the threshold limits for each analyte of interest, as listed in Table 4. These limits should be communicated to the laboratory so that the laboratory's instrumentation can be properly calibrated to account for the threshold concentrations. In addition, each analyte has a corresponding analytical method as per Appendix G of the 2016 Massachusetts Small MS4 9 Civil Action No. 19-CV-10332-MGM: Final Consent Decree. " United States District Court for the District of Massachusetts, United States and Massachusetts v. City of Holyoke, September 27, 2022. 9 United States Environmental Protection Agency (EPA). (n.d.). EPA New England Bacterial Source Tracking Protocol Purpose. EPA New England Bacterial Source Tracking Protocol. Retrieved January 16, 2023, from https://www3.epa.gov/region1/npdes/stormwater/ma/2014Appendixl.pdf 10 United States Environmental Protection Agency (EPA). (n.d.). General Permits for stormwater discharges from small municipal ...- US EPA. Massachusetts Small MS4 General Permit. Retrieved January 16, 2023, from https://www3.epa.gov/region1/npdes/stormwater/ma/2016fpd/final-2016-ma-sms4-gp-mod.pdf Project No. 20233959.001Page 8 of 11February 2023 2023 Kleinfelderwww.kleinfelder.com KLEINFELDER One Beacon Street, Suite 8100, Boston, MA 02108 p | 617.497.7800 f | 617.498.4630 ED_019088A_00020378-00080 COPIA Standard Operating ProceduresCity of Holyoke KLEINFELDER Bright People. Right Solutions. Illicit Discharge Detection and Elimination Plan SOP 1: Dry Weather Outfall Inspection 12 General Permit, that each field kit and laboratory analysis shall utilize to ensure compliance. Lastly, as per 40 CFR 13 136, maximum holding times and preservation requirements should be communicated to the laboratory. This is not applicable for field kits since samples are analyzed instantaneously after sample collection. Table 5 summarizes this information and it should be shared with the selected laboratory to ensure compliance with the Consent Decree. Table 5-Analytical Methods, Hold Times, and Preservatives for Laboratory Analysis EPA or Analyte orMax. Hold Approved Preservation ParametMe ethr od No.T 'i me EPA: 1103.1; 1603 Other: E. coliColilert , Colilert-18, mColiBlue- 8 hours Cool >10 C, 0.0008% Na2S2O3 EPA: 1106.1; 1600 EnterococcusOther: Enterolert 8 hours Cool >10 C, 0.0008% Na2S2O3 12 22. SurfactantsSM: 5540-C48 hoursCool >6 C AmmoniaEPA: 350.128 daysCool >6 C, H2SO4 to pH < 2 SM Standard Methods EPA or Approved Method No. obtained from Appendix G of the MA Small MS4 Permit, except for Surfactants obtained from 40 CFR Part 136 2Max Holding Time and Preservation obtained from 40 CFR Part 136 3 Ammonia and Surfactants can be analyzed in the field. Samples are sent to the lab to confirm field results if desired (not required to meet 40 CFR Part 136). Evaluation of sample data can show positive results due to sources other than human wastewater and false negative results due to chemical reactions or interferences. For example, elevated ammonia readings are common in the New England region due to sampling near historically filled tidal wetlands where the breakdown of biological organic material can skew sample results. The same elevated ammonia readings can also be triggered by discharge from a nearby landfill. In addition, elevated surfactant readings caused by salinity levels greater than one (1) part per thousand can be triggered by the presence of oil. Inconclusive surfactant readings, where the indicator ampule turns green instead of a shade of blue, can often be caused by fine suspended particulate matter being present in the sample being tested. Finally, very low bacteria concentrations can often be the result of elevated chlorine from 12 United States Environmental Protection Agency (EPA). (n.d.). Appendix G Massachusetts Small MS4 Permit Monitoring Requirements For Discharges into Impaired Waters Parameters and Methods. Retrieved January 30, 2023, from https://www3.epa.gov/region1/npdes/stormwater/ma/2016fpd/appendix-g-2016-ma-sms4-gp.pdf 13 The Federal Register. Federal Register. (n.d.). Retrieved January 30, 2023, from https://www.ecfr.gov/current/title-40/chapter- I / subchapter - D / part-136? toc = 1 Project No. 20233959.001Page 9 of 11February 2023 2023 Kleinfelderwww.kleinfelder.com KLEINFELDER One Beacon Street, Suite 8100, Boston, MA 02108 p | 617.497.7800 f | 617.498.4630 ED_019088A_00020378-00081 Standard Operating ProceduresCity of Holyoke KLEINFELDER Bright People. Right Solutions. Illicit Discharge Detection and Elimination Plan SOP 1: Dry Weather Outfall Inspection leaking drinking water infrastructure inhibiting bacterial growth. As such, any detection of chlorine above the 14 instrument Reporting Limit should be noted. Inspection Reporting The City shall maintain detailed and accurate records of outfall and interconnection discharge samples that includes the following information: Date and time that sampling was conducted Weather conditions both during, and in the 48 hours prior to, each sampling event Unique identifier Receiving water *Date of most recent inspection Dimensions Shape Material (concrete, PVC, etc.) Spatial location (latitude and longitude with a minimum accuracy of +/- 30 feet Physical condition Indicators of potential non - stormwater discharges (including presence or evidence of suspect flow and sensory observations such as odor, color, turbidity, floatable, or oil sheen) The Dry Weather Outfall Inspection Survey (Attachment 2) developed by the Central Massachusetts Regional Stormwater Coalition and Outfall Inventory Field Sheet (Attachment 4) are templates that can be used for documenting the listed observations related to both quantitative and qualitative characteristics of any / all flows 15 conveyed by the structure. As per the 2016 Massachusetts Small MS4 General Permit, if an outfall / interconnection is inaccessible or submerged, the permittee shall proceed to the first accessible upstream manhole or structure for the observation and sampling and report the location with the screening results. In addition, if no flow is observed, but evidence of illicit flow exists (see SOP 3 Locating Illicit Discharges), the City shall 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 16 observed flow. Attachments 1. Manhole Inspection Report 2. Dry Weather Outfall Inspection Survey developed by the Central Massachusetts Regional Stormwater Coalition 3. Field Data Collection Sheet 4. Outfall Inventory Field Sheet 14 Standard Operating Procedures. Central Massachusetts Regional Stormwater Coalition. (n.d.). Retrieved January 16, 2023, from https://www.centralmastormwater.org/toolbox/pages/standard-operating-procedures 15 Standard Operating Procedures. Central Massachusetts Regional Stormwater Coalition. (n.d.). Retrieved January 16, 2023, from https://www.centralmastormwater.org/toolbox/pages/standard-operating-procedures 13 United States Environmental Protection Agency (EPA). (n.d.). General Permits for stormwater discharges from small municipal ...- US EPA. Massachusetts Small MS4 General Permit. Retrieved January 16, 2023, from https://www3.epa.gov/region1/npdes/stormwater/ma/2016fpd/final-2016-ma-sms4-gp-mod.pdf Project No. 20233959.001Page 10 of 11February 2023 2023 Kleinfelderwww.kleinfelder.com KLEINFELDER One Beacon Street, Suite 8100, Boston, MA 02108 p | 617.497.7800 f | 617.498.4630 ED_019088A_00020378-00082 Standard Operating ProceduresCity of Holyoke KLEINFELDER Bright People. Right Solutions. Illicit Discharge Detection and Elimination Plan SOP 1: Dry Weather Outfall Inspection Related Standard Operating Procedures 1. SOP 2: Wet Weather Outfall Inspection 2. SOP 3: Locating Illicit Discharges Project No. 20233959.001Page 11 of 11February 2023 2023 Kleinfelderwww.kleinfelder.com KLEINFELDER One Beacon Street, Suite 8100, Boston, MA 02108 p | 617.497.7800 f | 617.498.4630 ED_019088A_00020378-00083 Standard Operating ProceduresCity of Holyoke KLEINFELDER Bright People. Right Solutions. Illicit Discharge Detection and Elimination Plan SOP 2: Wet Weather Outfall Inspection SOP 2: WET WEATHER OUTFALL INSPECTION Introduction Outfalls can be in the form of pipes or ditches and is the final point of discharge into a body of water for an engineered storm drain system. Current and pending regulations require that all outfalls, that are part of the storm drain system, be inspected, and that the water quality at these outfalls be analyzed under both dry and wet weather conditions. " SOP 1: Dry Weather Outfall Inspection, " covers the objectives for dry weather outfall inspections. This SOP discusses the objectives of wet weather outfall inspections. The objective of wet weather inspections is to determine whether wet weather - induced high flows in sanitary sewers, or high groundwater in areas served by septic systems, results in discharges of sanitary flow to the MS4. As per the Consent Decree, by May 31st, 2023, the City of Holyoke (the City) shall submit to the EPA for review an Illicit Discharge Detection and Elimination (IDDE) Plan which includes screening and monitoring all known MS4 outfalls and interconnections in wet weather conditions. As defined in the Consent Decree, the City shall conduct wet - weather inspections once every three years when at least 0.25-inches of rain has occurred over a 24-hour period prior to sampling. However, precipitation events that produce enough flow from outfalls or interconnections to be sampled, will also be acceptable. Condition Assessment Typical practice is to prepare for a wet weather inspection event when weather forecasts show a 40% chance of rain or greater. Early preparation is key to sampling first flush which is within the first 30 minutes of discharge to and reflects the maximum pollutant load. In some watersheds, increased discharge from an outfall may not occur with the required 0.25-inches of rain due to the amount of impervious surface present. Therefore, as more inspections occur, and the City understands how their outfalls respond to rain events, this precipitation amount 2 can be modified. Dry weather sampling is required at any outfall or interconnection where any flow is observed under dry weather conditions, but sampling during wet weather conditions is required at all outfalls. Particularly, any outfalls that did not have any observed flow during dry weather conditions or those with dry weather flow that passed screening thresholds. Unlike dry weather conditions, wet weather conditions can help to identify a number of situations that would otherwise go unnoticed during dry weather. For example, wet weather can help identify locations where elevated groundwater exists and is causing an exchange of wastewater between cracked or broken sanitary sewers, failed septic systems, underdrains, or storm drains. Wet weather can also help to identify instances when there's an increase in sewer volume and sewage may be entering the storm drain system at common manholes or directly - piped connections to storm drains. Finally, wet weather can also help to identify locations subject to capacity - related SSO discharges or illicit connections that are not carried through the storm drain system during 3 dry weather conditions.` 1 Civil Action No. 19-CV-10332-MGM: Final Consent Decree. " United States District Court for the District of Massachusetts, United States and Massachusetts v. City of Holyoke, September 27, 2022. 2 Standard Operating Procedures. Central Massachusetts Regional Stormwater Coalition. (n.d.). Retrieved January 16, 2023, from https://www.centralmastormwater.org/toolbox/pages/standard-operating-procedures 3 United States Environmental Protection Agency (EPA). (n.d.). EPA New England Bacterial Source Tracking Protocol Purpose. EPA New England Bacterial Source Tracking Protocol. Retrieved January 16, 2023, from https://www3.epa.gov/region1/npdes/stormwater/ma/2014Appendixl.pdf Project No. 20233959.001Page 1 of 8February 2023 2023 Kleinfelderwww.kleinfelder.com KLEINFELDER One Beacon Street, Suite 8100, Boston, MA 02108 p | 617.497.7800 f | 617.498.4630 ED_019088A_00020378-00084 Standard Operating ProceduresCity of Holyoke KLEINFELDER Bright People. Right Solutions. Illicit Discharge Detection and Elimination Plan SOP 2: Wet Weather Outfall Inspection Prior to samples being taken, a visual observation of the discharge should occur. During this observation, the presence of any pollution should be noted and further investigated. As per the Central Massachusetts Regional 4 Stormwater Coalition, the following visual indicators shown in Table 1 may be the result of the following. " Table 1 - - Visual Condition Assessment IndicatorPossible Source Foamupstream vehicle washing activities or illicit discharge Oil Sheenleak or spill Cloudinesssuspended solids (i.e. dust, ash, powdered chemicals, ground up materials, etc.) Color or Odorraw materials, chemicals, or sewage Excessive Sedimentdisturbed earth of unpaved areas lacking adequate erosion control measures Sanitary Waste / Optical Enhancers * illicit discharge Orange Staininghigh mineral concentrations Fluorescent dyes added to laundry detergent and some toilet paper While many of the indicators listed in Table 1 would indicate an illicit discharge, some indicators may occur naturally. For example, orange staining could be the result of naturally occurring iron. However, it may be more difficult to determine the difference between natural foam and foam caused by pollution. Natural foam can typically be found in water with high organic content such as bog lakes, streams that originate from bog lakes, productive lakes, wetlands, or woody areas. As per the Central Massachusetts Regional Stormwater Coalition, it's important to consider the following factors listed in Table 2 when determining if the source of foam present at a 5 stormwater outfall is natural or not. Table 2-Conditional and Qualitative Considerations of Foam Factors Explanation Wind Direction or Turbulence Natural foam occurrences of the beach coincide with onshore winds. Often, foam can be found along a shoreline and / or on open waters during windy days. Natural occurrences in rivers can be found downstream of a turbulent site. Proximity to Potential Pollution Source Some entities including the textile industry, paper production facilities, oil industries, and fire fighting activities work with materials that cause foaming in water. If these materials are released to a water body in large quantities, they can cause foaming. The presence of silt in water, such as from a construction site can cause foam. Physical FeelingNatural foam is typically persistent, light, not slimy to the touch. Visual ObservationPrescence of decomposing plants or organic material in the water. 4 Standard Operating Procedures. Central Massachusetts Regional Stormwater Coalition. (n.d.). Retrieved January 16, 2023, from https://www.centralmastormwater.org/toolbox/pages/standard-operating-procedures 5 Standard Operating Procedures. Central Massachusetts Regional Stormwater Coalition. (n.d.). Retrieved January 16, 2023, from https://www.centralmastormwater.org/toolbox/pages/standard-operating-procedures Project No. 20233959.001Page 2 of 8February 2023 2023 Kleinfelderwww.kleinfelder.com KLEINFELDER One Beacon Street, Suite 8100, Boston, MA 02108 p | 617.497.7800 f | 617.498.4630 ED_019088A_00020378-00085 Standard Operating ProceduresCity of Holyoke KLEINFELDER Bright People. Right Solutions. Illicit Discharge Detection and Elimination Plan SOP 2: Wet Weather Outfall Inspection In addition to foam, both bacteria and petroleum can create a sheen on the water surface. Differentiating the two can be as simple as disturbing the " sheen " with a pole, stick, or similar object. A sheen caused by oil will remain intact and move in a swirl pattern while a sheen caused by bacteria will separate into a number of smaller patches and appear " blocky. " In addition, bacteria or naturally occurring sheens are usually silver or dull in color. While 6 bacterial sheen is not a pollutant, it should be noted when describing the discharge. Optical enhancers on the other hand can be visible to the naked eye when found in high enough concentrations and will appear as a bluish - purple haze. If a visual observation is unable to confirm the presence of this pollutant, a quantitative test can be used. In order to perform this test, a clean, white, cotton pad should be placed, either directly in, or within a sample of, the discharge for several days. After soaking, the cotton pad should be dried and then viewed under a fluorometer. If the cotton pad fluoresces, optical enhancers are assumed to be the pollutant and present. The magnitude of the fluorescence, as measured in fluorescent units, can be used to determine the concentration of optical enhancers within the sample. Often a visual observation is enough. It's not typical that this analysis is required. Sample Collection Table 3 lists the field equipment commonly used for wet weather outfall screening and sampling. Table 3-Field Equipment for Wet Weather Outfall Screening and Sampling Equipment Use / Notes ClipboardFor organization of field sheets and writing surface Field Forms or Tablet for Electronic Forms Field sheets for both dry weather inspection and dry weather sampling should be available, with extra sheets included Chain of Custody FormsTo ensure proper handling of all samples Pens / Pencils / Permanent MarkersFor proper labeling Nitrile GlovesTo protect the sampler as well as the sample from contamination Flashlight / Headlamp w / Batteries For looking in outfalls or manholes, helpful in early mornings as well Cooler with IceFor transporting samples to the laboratory Digital CameraFor documenting field conditions at time of inspection Reflective vest, safety glasses, hard hats, and boots at a minimum. Personal ProtectiveEquipment (PPE)Work gloves, long pants, and sleeves for protection from environmental conditions such as brush, insects, and poisonous plants. Insect / Plant Repellant and SunscreenFor protection from environmental conditions. GPS ReceiverFor taking spatial location data Distilled waterFor use with test kits and water quality meters Water Quality MetersHand - held meters for testing various water quality parameters. Field Test Kits Have extra kits on hand to sample more outfalls than are anticipated to be screened in a single day 6 Standard Operating Procedures. Central Massachusetts Regional Stormwater Coalition. (n.d.). Retrieved January 16, 2023, from https://www.centralmastormwater.org/toolbox/pages/standard-operating-procedures Project No. 20233959.001Page 3 of 8February 2023 2023 Kleinfelderwww.kleinfelder.com KLEINFELDER One Beacon Street, Suite 8100, Boston, MA 02108 p | 617.497.7800 f | 617.498.4630 ED_019088A_00020378-00086 Standard Operating ProceduresCity of Holyoke KLEINFELDER Bright People. Right Solutions. Illicit Discharge Detection and Elimination Plan SOP 2: Wet Weather Outfall Inspection EquipmentUse / Notes Rinse Water / Calibration standardsCleaning equipment and calibration Label TapeFor labeling sample containers Make sure all sample containers are clean. Keep extra sample containers on hand at all times. Sample ContainersMake sure there are proper sample containers for what is being sampled for (i.e., bacteria and total phosphorus analysis require sterile containers and preservatives). Telescopic Sampling Pole / Dipper for hard to reach locations. Cooler with IceLaboratory sample submittals Pry Bar,, Pick, and / or ShovelFor opening catch basins and manholes when necessary Small Mallet or HammerHelping to free stuck manhole and catch basin covers Utility KnifeMultiple uses Measuring TapeMeasuring distances and depth of flow Traffic ConesSafety Hand SanitizerDisinfectant / decontaminant Machete / ClippersAccessing overgrown infrastructure Flashlight with batteriesFor looking in outfalls, manholes, and catch basins Zip Ties / Duct TapeFor making field repairs Rubber Boots / WadersFor accessing shallow streams / areas Sampling Pole / Dipper / Sampling CageFor accessing hard - to - reach outfalls and manholes 5-gallon Bucket w / CoverDisposal of chemical waste DBI Sali Tripod and retrieval wench; MSA Tripod, rescue wench Confined Space Entry Equipment (if needed)and material / personal wench; full body harness; 10'ladder; waders; hard hat; air monitoring equipment (Ventis 4 gas meter) A discrete manual or grab sample shall be collected for wet weather outfall inspections due to the time - sensitive nature of the process. Grab samples classify water at a distinct point in time and are used primarily when the water quality of the discharge is expected to be homogenous, or unchanging, in nature. A flow - weighted composite sample classifies water quality over a measured period of time and are used when the water quality of 7 discharge is expected to be heterogenous, or fluctuating, in nature. Protocols for collecting a grab sample as per the Central Massachusetts Regional Stormwater Coalition are as follows: 1. Fill out sample information on sample bottles and field sheets (see Attachment 3 for example field sheets). 2. Do not eat, drink, or smoke during sample collection and processing. 3. Do not collect or process samples near a running vehicle. 4. Do not park vehicles in the immediate sample collection area, including both running and non - running vehicles. 5. Always wear clean, powder - free nitrile gloves when handling sample containers and lids. 6. Never touch the inside surface of a sample container or lid, even with gloved hands. 7 Standard Operating Procedures. Central Massachusetts Regional Stormwater Coalition. (n.d.). Retrieved January 16, 2023, from https://www.centralmastormwater.org/toolbox/pages/standard-operating-procedures Project No. 20233959.001Page 4 of 8February 2023 2023 Kleinfelderwww.kleinfelder.com KLEINFELDER One Beacon Street, Suite 8100, Boston, MA 02108 p | 617.497.7800 f | 617.498.4630 ED_019088A_00020378-00087 Standard Operating ProceduresCity of Holyoke KLEINFELDER Bright People. Right Solutions. Illicit Discharge Detection and Elimination Plan SOP 2: Wet Weather Outfall Inspection 7. Never allow the inner surface of a sample container or lid to be contacted by any material other than the sample water. 8. Collect sample with dipper or directly into sample containers. If possible, collect water while facing upstream of the flow into the sample bottles so as to not to disturb water or sediments in the outfall pipe or ditch. 9. Do not overfill sample containers, and do not dump out any liquid in them. Liquids are often added to sample containers intentionally by the analytical laboratory as a preservative or for pH adjustment. 10. Slowly lower the bottle into the water to avoid bottom disturbance and stirring up sediment. 11. Do not allow any object or material to fall into or contact the collected water sample. 12. Do not allow rainwater to drip from rain gear or other surfaces into sample containers. 13. Replace and tighten sample container lids immediately after sample collection. 14. Place laboratory samples on ice for analysis of bacteria and pollutants of concern. 15. Accurately label the sample with the time and location. 16. Document on the Dry Weather Outfall Inspection Survey that analytical samples were collected, specify parameters, and note the sample time on an Inspection Survey (see Attachment 1 and 2 for examples). This creates a reference point for samples. 17. Fill out chain - of - custody form for laboratory samples. 18. If using a dipper or other device, triple rinse the device with distilled water and then in water to be sampled, except for bacteria sampling. 19. Store used test strips and test kit waste / ampules properly in a 5-gallon bucket with a cover. Storage and disposal shall be coordinated with the City. 20. Decontaminate all testing personnel and equipment. Samples that are unable to be analyzed for parameters using field instrumentation require laboratory analysis. Coordination with the laboratory, including the pick - up and / or dropping off, of samples, is the responsibility of the City. The laboratory requires that a chain - of - custody form be filled out and accompany any samples that require analysis. The laboratory will also provide additional details regarding how samples should be collected based on the sample containers and / or specific analytes. Parameter Analysis As per the Consent Decree, the City shall utilize the following IDDE screening thresholds shown in Table 4 as 8 guidelines for its analysis of the data generated for each outfall and interconnection discharge sample. In addition, each outfall and interconnection discharge sample shall be concurrently analyzed for all the parameters shown using laboratory analysis or field instrumentation defined in Table 4 as per EPA's Region 1's " EPA New England 9 Bacteria Source Tracking Protocol, " January 2012 Draft.fl Table 4-Freshwater Water Quality Criteria, Threshold Limits, and Example Instrumentation Threshold Analyte / Indicator Limits / Instrumentation Single Sample E. coli 2> 410 cfu / 100mlLaboratory via approved method Enterococci 2> 130 cfu / 100mlLaboratory via approved method 8 Civil Action No. 19-CV-10332-MGM: Final Consent Decree. " United States District Court for the District of Massachusetts, United States and Massachusetts v. City of Holyoke, September 27, 2022. 9 United States Environmental Protection Agency (EPA). (n.d.). EPA New England Bacterial Source Tracking Protocol Purpose. EPA New England Bacterial Source Tracking Protocol. Retrieved January 16, 2023, from https://www3.epa.gov/region1/npdes/stormwater/ma/2014Appendixl.pdf Project No. 20233959.001Page 5 of 8February 2023 2023 Kleinfelderwww.kleinfelder.com KLEINFELDER One Beacon Street, Suite 8100, Boston, MA 02108 p | 617.497.7800 f | 617.498.4630 ED_019088A_00020378-00088 Standard Operating ProceduresCity of Holyoke KLEINFELDER Bright People. Right Solutions. Illicit Discharge Detection and Elimination Plan SOP 2: Wet Weather Outfall Inspection Threshold Analyte / Indicator Limits / Instrumentation Single Sample Surfactants (as> 0.25 mg / 1 MBAS Field Test Kit (e.g. CHEMetrics K- 9400) MBAS) > 0.1 mg / 1Laboratory via approved method > 0.5 mg / 1 Ammonida Field Test Strips (e.g. Hach Ammonia (NH3)Brand) > 0.1 mg / 1Laboratory via approved method Chlorine> 0.02 mg / 1Field Meter (e.g. Hach Pocket Colorimeter II) TemperatureN / AField Meter (e.g. YSI Model 30) ConductivityN / AField Meter (e.g. YSI Model 30) SalinityN / AField Meter (e.g. YSI Model 30) A The mention of trade names or commercial products does not constitute endorsement or recommendation for use by the U.S. EPA B Class A or B Waters C Levels that may be indicative of potential wastewater or washwater contamination As per the 2016 Massachusetts Small MS4 General Permit and Consent Decree, all analyses, with the exception of indicator bacteria and pollutants of concern, can be performed with field tests or field instrumentation and are not subject to 40 CFR part 136 requirements. Sampling for bacteria and pollutants of concern shall be conducted using the analytical methods found in 40 CFR 136, or alternative methods approved by EPA in accordance with the 10 procedures in 40 CFR 136. The City is responsible for selecting a laboratory, or field kits for measuring each analyte. When selecting field kits, review the detection range for each field kit and ensure that it corresponds to the threshold limits for each analyte of interest, as listed in Table 4. These limits should be communicated to the laboratory so that the laboratory's instrumentation can be properly calibrated to account for the threshold concentrations. In addition, each analyte 11 has a corresponding analytical method as per Appendix G of the 2016 Massachusetts Small MS4 General Permit that each field kit and laboratory analysis shall utilize to ensure compliance. Lastly, as per 40 CFR 136 12, maximum holding times and preservation requirements should be communicated to the laboratory. This is not applicable for field kits since samples are analyzed instantaneously after sample collection. Table 5 summarizes this information and it should be shared with the selected laboratory to ensure compliance with the Consent Decree. 10 United States Environmental Protection Agency (EPA). (n.d.). General Permits for stormwater discharges from small municipal ...- US EPA. Massachusetts Small MS4 General Permit. Retrieved January 16, 2023, from https://www3.epa.gov/region1/npdes/stormwater/ma/2016fpd/final-2016-ma-sms4-gp-mod.pdf 11 United States Environmental Protection Agency (EPA). (n.d.). Appendix G Massachusetts Small MS4 Permit Monitoring Requirements For Discharges into Impaired Waters Parameters and Methods. Retrieved January 30, 2023, from https://www3.epa.gov/region1/npdes/stormwater/ma/2016fpd/appendix-g-2016-ma-sms4-gp.pdf 12 The Federal Register. Federal Register. (n.d.). Retrieved January 30, 2023, from https://www.ecfr.gov/current/title-40/chapter- I / subchapter - D / part-136? toc = 1 Project No. 20233959.001Page 6 of 8February 2023 2023 Kleinfelderwww.kleinfelder.com KLEINFELDER One Beacon Street, Suite 8100, Boston, MA 02108 p | 617.497.7800 f | 617.498.4630 ED_019088A_00020378-00089 Standard Operating ProceduresCity of Holyoke KLEINFELDER Bright People. Right Solutions. Illicit Discharge Detection and Elimination Plan SOP 2: Wet Weather Outfall Inspection Table 5-Analytical Methods, Hold Times, and Preservatives for Laboratory Analysis EPA or Analyte orMax. Hold Approved Preservation Parameter Time Method No. EPA: 1103.1; 1603 Other: E. coliColilert , Colilert -, mColiBlue- 8 hours Cool >10 C, 0.0008% Na2S2O3 EPA: 1106.1; 1600 EnterococcusOther: Enterolert 8 hours Cool >10 C, 0.0008% Na2S2O3 12 22. SurfactantsSM: 5540-C48 hoursCool < 6 C AmmoniaEPA: 350.128 daysCool >6 C, HSO4 to pH < 2 SM Standard Methods EPA or Approved Method No. obtained from Appendix G of the MA Small MS4 Permit, except for Surfactants obtained from 40 CFR Part 136 2 Max Holding Time and Preservation obtained from 40 CFR Part 136 3 Ammonia and Surfactants can be analyzed in the field. Samples are sent to the lab to confirm field results if desired (not required to meet 40 CFR Part 136). Evaluation of sample data can show positive results due to sources other than human wastewater and false negative results due to chemical reactions or interferences. For example, elevated ammonia readings are common in the New England region due to sampling near historically filled tidal wetlands where the breakdown of biological organic material can skew sample results. The same elevated ammonia readings can also be triggered by discharge from a nearby landfill. In addition, elevated surfactant readings caused by salinity levels greater than one (1) part per thousand can be triggered by the presence of oil. Inconclusive surfactant readings, where the indicator ampule turns green instead of a shade of blue, can often be caused by fine suspended particulate matter being present in the sample being tested. Finally, very low bacteria concentrations can often be the result of elevated chlorine from leaking drinking water infrastructure inhibiting bacterial growth. As such, any detection of chlorine above the 13 instrument Reporting Limit should be noted. 13 Standard Operating Procedures. Central Massachusetts Regional Stormwater Coalition. (n.d.). Retrieved January 16, 2023, from https://www.centralmastormwater.org/toolbox/pages/standard-operating-procedures Project No. 20233959.001Page 7 of 8February 2023 2023 Kleinfelderwww.kleinfelder.com KLEINFELDER One Beacon Street, Suite 8100, Boston, MA 02108 p | 617.497.7800 f | 617.498.4630 ED_019088A_00020378-00090 Standard Operating ProceduresCity of Holyoke KLEINFELDER Bright People. Right Solutions. Illicit Discharge Detection and Elimination Plan SOP 2: Wet Weather Outfall Inspection Inspection Reporting The City shall maintain detailed and accurate records of outfall and interconnection discharge samples that includes the following information: Date and time that sampling was conducted Weather conditions both during, and in the 24 hours prior to, each sampling event Unique identifier Receiving water Date of most recent inspection Dimensions Shape Material (concrete, PVC, etc.) Spatial location (latitude and longitude with a minimum accuracy of +/- 30 feet Physical condition Indicators of potential non - stormwater discharges (including presence or evidence of suspect flow and sensory observations such as odor, color, turbidity, floatable, or oil sheen) The Wet Weather Outfall Inspection Survey (Attachment 1) developed by the Central Massachusetts Regional Stormwater Coalition and the Outfall Inventory Field Sheet (Attachment 3) are templates that can be used for documenting the listed observations related to both quantitative and qualitative characteristics of any flows 14 conveyed by the structure.. Attachments 1. Wet Weather Outfall Inspection Survey developed by the Central Massachusetts Regional Stormwater Coalition 2. Field Data Collection Sheet 3. Outfall Inventory Field Sheet Related Standard Operating Procedures 1. SOP 2: Wet Weather Outfall Inspection 2. SOP 3: Locating Illicit Discharges 14 Standard Operating Procedures. Central Massachusetts Regional Stormwater Coalition. (n.d.). Retrieved January 16, 2023, from https://www.centralmastormwater.org/toolbox/pages/standard-operating-procedures Project No. 20233959.001Page 8 of 8February 2023 2023 Kleinfelderwww.kleinfelder.com KLEINFELDER One Beacon Street, Suite 8100, Boston, MA 02108 p | 617.497.7800 f | 617.498.4630 ED_019088A_00020378-00091 Standard Operating ProceduresCity of Holyoke KLEINFELDER Bright People. Right Solutions. Illicit Discharge Detection and Elimination Plan SOP 3: Locating Illicit Discharges SOP 3: LOCATING ILLICIT DISCHARGES Introduction An " illicit discharge " is any discharge to an engineered storm drain system that is not composed entirely of stormwater. Exceptions for allowable non - stormwater discharge are detailed in the Massachusetts MS4 Permit and are as follows ': a. Water line flushing b. Landscape irrigation C. Diverted stream flows d. Rising ground water e. Uncontaminated ground water infiltration (as defined at 40 CFR 35.2005 (20)) f. Uncontaminated pumped ground water g. Discharge from potable water sources h. Foundation drains . Air conditioning condensation j. Irrigation water, springs k. Water from crawl space pumps I. Footing drains m. Lawn watering n. Individual resident car washing 0. Flows from riparian habitats and wetlands p. De - chlorinated swimming pool discharges q. Street wash waters r. Residential building wash waters without detergents Illicit discharges can enter an engineered storm drain system via direct and indirect connections. These connections can include: cross - connections of sewer services to storm drain systems; leaking septic systems; intentional discharge of pollutants to catch basins; combined sewer overflows; connected floor drains; and sump pumps connected to storm drain systems. As such, the discharges from these illicit connections can contribute high levels of pollutants, including heavy metals, toxics, oil, grease, solvents, nutrients, and pathogens to the receiving 2 body of water. The City of Holyoke's (City) Stormwater Ordinance, adopted by the City Council on May 17th, 2017, grants the City the 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), and implement appropriate enforcement procedures and actions. 1 United States Environmental Protection Agency (EPA). (n.d.). General Permits for stormwater discharges from small municipal ...- US EPA. Massachusetts Small MS4 General Permit. Retrieved January 16, 2023, from https://www3.epa.gov/region1/npdes/stormwater/ma/2016fpd/final-2016-ma-sms4-gp-mod.pdf 2 Standard Operating Procedures. Central Massachusetts Regional Stormwater Coalition. (n.d.). Retrieved January 16, 2023, from https://www.centralmastormwater.org/toolbox/pages/standard-operating-procedures Project No. 20233959.001Page 1 of 8February 2023 2023 Kleinfelderwww.kleinfelder.com KLEINFELDER One Beacon Street, Suite 8100, Boston, MA 02108 p | 617.497.7800 f | 617.498.4630 ED_019088A_00020378-00092 Standard Operating ProceduresCity of Holyoke KLEINFELDER Bright People. Right Solutions. Illicit Discharge Detection and Elimination Plan SOP 3: Locating Illicit Discharges Identifying Illicit Discharges Illicit discharges can be located be several methods, including routine dry weather outfall inspections (as described in detail in " SOP 1: Dry Weather Outfall Inspection ") and citizen reports. As per the Central Massachusetts Regional 3 Stormwater Coalition, the following indicators shown in Table 1 may be the result of an illicit discharge.` Table 1-Visual Condition Assessment IndicatorPossible Source Foamupstream vehicle washing activities or illicit discharge Oil Sheenleak or spill Cloudinesssuspended solids (i.e. dust, ash, powdered chemicals, ground up materials, etc.) Color or Odorraw materials, chemicals, or sewage Excessive Sedimentdisturbed earth of unpaved areas lacking adequate erosion control measures Sanitary Waste / Optical Enhancers * illicit discharge Orange Staininghigh mineral concentrations Fluorescent dyes added to laundry detergent and some toilet paper While many of the indicators listed in Table 1 would indicate an illicit discharge, some indicators may occur naturally. For example, orange staining could be the result of naturally occurring iron. However, it may be difficult to determine the difference between natural foam and foam caused by pollution. Natural foam can typically be found in water with high organic content such as bog lakes, streams that originate from bog lakes, productive lakes, wetlands, or woody areas. As per the Central Massachusetts Regional Stormwater Coalition, it's important to consider the following factors listed in Table 2 when determining if the source of foam present at a stormwater 4 outfall is natural or not. Table 2-Conditional and Qualitative Considerations of Foam Factors Explanation Wind Direction or Turbulence Natural foam occurrences of the beach coincide with onshore winds. Often, foam can be found along a shoreline and / or on open waters during windy days. Natural occurrences in rivers can be found downstream of a turbulent site. Proximity to Potential Pollution Source Some entities including the textile industry, paper production facilities, oil industries, and fire fighting activities work with materials that cause foaming in water. If these materials are released to a water body in large quantities, they can cause foaming. The presence of silt in water, such as from a construction site can cause foam. Physical FeelingNatural foam is typically persistent, light, not slimy to the touch. Visual ObservationPrescence of decomposing plants or organic material in the water. 3 Standard Operating Procedures. Central Massachusetts Regional Stormwater Coalition. (n.d.). Retrieved January 16, 2023, from https://www.centralmastormwater.org/toolbox/pages/standard-operating-procedures 4 Standard Operating Procedures. Central Massachusetts Regional Stormwater Coalition. (n.d.). Retrieved January 16, 2023, from https://www.centralmastormwater.org/toolbox/pages/standard-operating-procedures Project No. 20233959.001Page 2 of 8February 2023 2023 Kleinfelderwww.kleinfelder.com KLEINFELDER One Beacon Street, Suite 8100, Boston, MA 02108 p | 617.497.7800 f | 617.498.4630 ED_019088A_00020378-00093 COPLA Standard Operating ProceduresCity of Holyoke KLEINFELDER Bright People. Right Solutions. Illicit Discharge Detection and Elimination Plan SOP 3: Locating Illicit Discharges In addition to foam, both bacteria and petroleum can create a sheen on the water surface. Differentiating the two can be as simple as disturbing the " sheen " with a pole, stick, or similar object. A sheen caused by oil will remain intact and move in a swirl pattern while a sheen caused by bacteria will separate into a number of smaller patches and appear " blocky. " In addition, bacteria or naturally occurring sheens are usually silver or dull in color. While 5 bacterial sheen is not a pollutant, it should be noted when describing the discharge. Optical enhancers on the other hand can be visible to the naked eye when found in high enough concentrations and will appear as a bluish - purple haze. If a visual observation is unable to confirm the presence of this pollutant, a quantitative test can be used. In order to perform this test, a clean, white, cotton pad should be placed, either directly in, or within a sample of, the discharge for several days. After soaking, the cotton pad should be dried and then viewed under a fluorometer. If the cotton pad fluoresces, optical enhancers are assumed to be the pollutant and present. The magnitude of the fluorescence, as measured in fluorescent units, can be used to determine the concentration of optical enhancers within the sample. Often a visual observation is enough. It's not typical that this analysis is required. Citizen Reports Reports by residents and other users can be effective tools in helping the City to identify illicit discharges. The City's Department of Public Works (DPW) set up a phone hotline for this purpose, the phone number is (413) 534- 2222. In addition, DPW should also provide guidance to the local City police department(s) and dispatch centers on how to manage data reported if residents should decide to report an illicit discharge with the police. An example Incident Tracking Sheet, provided by the Central Massachusetts Regional Stormwater Coalition, is included as Attachment 1 and can be used as an example that guides the responder to ensure that all pertinent details about the reported discharge are accurately documented. Reported illicit discharges should be communicated with the DPW. Tracing Illicit Discharges Once identified, suspected illicit connections must then be confirmed by the City. If confirmed, but the source is unidentified, the following additional procedures, as per the Central Massachusetts Regional Stormwater Coalition, should be: 1. Review and consider information collected when an illicit discharge was initially identified, including, but not limited to, the time of day and the weather conditions for the previous 72 hours. Also review past reports or investigations of similar illicit discharges in the area. 2. Obtain storm drain mapping for the area of the reported illicit discharge. If possible, use a tracking system that can be linked to the City's GIS. 3. Document current conditions at the location of the observed illicit discharge point, including odors, water appearance, estimated flow, presence of floatables, and other pertinent information. Photograph relevant evidence. 4. If there continues to be evidence of the illicit discharge, collect water quality data using the methods described in " SOP 1: Dry Weather Outfall Inspection " and " SOP 2: Wet Weather Outfall Inspection ". This may include using field test kits or instrumentation or collecting analytical samples for full laboratory analysis. 5 Standard Operating Procedures. Central Massachusetts Regional Stormwater Coalition. (n.d.). Retrieved January 16, 2023, from https://www.centralmastormwater.org/toolbox/pages/standard-operating-procedures 6 Standard Operating Procedures. Central Massachusetts Regional Stormwater Coalition. (n.d.). Retrieved January 16, 2023, from https://www.centralmastormwater.org/toolbox/pages/standard-operating-procedures Project No. 20233959.001Page 3 of 8February 2023 2023 Kleinfelderwww.kleinfelder.com KLEINFELDER One Beacon Street, Suite 8100, Boston, MA 02108 p | 617.497.7800 f | 617.498.4630 ED_019088A_00020378-00094 Standard Operating ProceduresCity of Holyoke KLEINFELDER Bright People. Right Solutions. Illicit Discharge Detection and Elimination Plan SOP 3: Locating Illicit Discharges 5. Move upstream from the point of observation to identify the source of the discharge, using the system mapping to determine infrastructure, tributary pipes, and drainage areas that contribute. At each point, survey the general area and surrounding properties to identify potential sources of the illicit discharge. Document observations at each point on an Incident Tracking Sheet (Attachment 1) as well as with photographs. 6. Continue this process until the illicit discharge is no longer observed, which will define the boundaries of the likely source. For example, if the illicit discharge is present in catch basin 137 but not the next upstream catch basin, 138, the source of the illicit discharge is between these two structures. If the source of an illicit discharge cannot be determined via the procedures listed above, additional methods, such as sandbagging, dye testing, smoke testing, and / or closed - circuit television inspection (CCTV) may need to be utilized. Descriptions for these four (4) methods are listed below. Sandbagging Sandbagging can be particularly useful when attempting to isolate intermittent or illicit discharges with very little perceptible flow. This technique involves placing sandbags, caulking, weirs / plates, or other temporary barriers within the outlets of a manhole to form a temporary dam. Sandbags and other barriers should only be installed when dry weather is forecasted and are typically left in place for 48 hours. If flow is present after 48 hours behind the sandbags / barriers, this would allow the inspector to properly observe and sample the flow, however, if no flow collects behind the sandbags / barriers, the upstream pipe network can be ruled out as a source of the intermittent discharge. Unlike the other three (3) methods described subsequently, this method can be quite time - consuming. Dye Testing Dye testing consists of discharging or flushing non - toxic dye into a suspended plumbing fixture and observing a nearby storm drain structure and / or sanitary sewer manhole for the presence of the same dye downstream. Fixtures, such as sinks, toilets, and sump pumps can all be tested with dye, but should be tested separately. This test should ideally be conducted with a team of two or more people, with one person adding the dye to the fixture of interest, while the other person watches for the presence or absence of dye near the source. Unlike the other methods mentioned, dye testing is relatively quick, effective, and inexpensive. This method is best used when the source of the illicit discharge has been relatively narrowed down. Dye testing can be done by the City or a third - party contractor and requires the City to receive permission prior to accessing any sites that may contain the suspected fixtures. Residents, business owners, police, fire, and local public health staff shall be notified prior to testing in preparation for responding to citizen phone calls concerning the dye and their presence in local surface waters. Smoke Testing Unlike dye testing, smoke testing is a useful method to utilize if the source of an illicit discharge is not as obvious. Smoke testing often works best when trying to locate an illicit discharge along short sections of pipe and, more specifically, along small diameters pipes. This method involves injecting a non - toxic smoke with the use of a smoke bomb or smoke generator. When added to the storm drain system, smoke will emerge in connected locations, allowing for an inspector to locate a less obvious source of an illicit discharge. Similar to dye testing, this testing activity can be performed by a third - party contractor. Proper notifications to residents, business owners, local police, and fire departments that may be in the area of interest is critical. Smoke may cause minor irritation for residents with respiratory conditions. These individuals should be monitored or evacuated from the area of testing. 7 Standard Operating Procedures. Central Massachusetts Regional Stormwater Coalition. (n.d.). Retrieved January 16, 2023, from https://www.centralmastormwater.org/toolbox/pages/standard-operating-procedures Project No. 20233959.001Page 4 of 8February 2023 2023 Kleinfelderwww.kleinfelder.com KLEINFELDER One Beacon Street, Suite 8100, Boston, MA 02108 p | 617.497.7800 f | 617.498.4630 ED_019088A_00020378-00095 Standard Operating ProceduresCity of Holyoke KLEINFELDER Bright People. Right Solutions. Illicit Discharge Detection and Elimination Plan SOP 3: Locating Illicit Discharges Closed Circuit Television Inspection (CCTV) In CCTV inspections, cameras are used to record the interior of storm drain pipes. These cameras can be manually pushed with a stiff cable or guided remotely on treads or wheels. Video can be watched live, or reviewed as a recording, to locate illicit connections and infiltration from sanitary sewers into the storm drain. Again, this testing activity can be performed by a third - party contractor. If the source of an illicit discharge still cannot be located, further investigation in a future program is necessary. Figure 1 below, from the Central Massachusetts Regional Stormwater Coalition shows a pictorial summary of this section. Illicit Discharge Detected (Baseline Information Collected from Incident Tracking Sheet) ' Return Visit No Flow (Transitory orReturn Visit (Continuous Flow) Intermittent Discharge)Collect a sample before (and after) source is removed. Source SiteNo Source SiteNo Source SiteSource Site Suspected Suspected Suspected Suspected Inspect PotentialVisually InspectVisually InspectInspect Potential Source SiteStorm Drain AccessStorm Drain AccessSource Site Points; Install Weirs,Points to trace flow Sandbags, Dams orback to Source Blocks. Source SiteNo Source SiteSource Site Suspected Identified Suspected Smoke Test or Televise Storm Drain System; Sample if necessary Add to Further Inspection List Dye Test, Smoke Test, Televise, or Electronically Locate Floor Drains, Sumps, or other Suspect Connection Figure 1-Steps for Tracing Illicit Discharges Project No. 20233959.001Page 5 of 8February 2023 2023 Kleinfelderwww.kleinfelder.com KLEINFELDER One Beacon Street, Suite 8100, Boston, MA 02108 p | 617.497.7800 f | 617.498.4630 ED_019088A_00020378-00096 Standard Operating ProceduresCity of Holyoke KLEINFELDER Bright People. Right Solutions. Illicit Discharge Detection and Elimination Plan SOP 3: Locating Illicit Discharges Removal and Abatement of Illicit Discharges As per the Consent Decree, the " date of verification " of an illicit discharge shall be the date on which the City has identified a point of entry of an illicit discharge from a specific location, or address, that contributes wastewater 8 flow to the MS4. Figure 2 summarizes the steps the City shall take upon identification of an illicit source. 8 CivilAction No. 19-CV-10332-MGM: Final Consent Decree. " United States District Court for the District of Massachusetts, United States and Massachusetts v. City of Holyoke, September 27, 2022. Project No. 20233959.001Page 6 of 8February 2023 2023 Kleinfelderwww.kleinfelder.com KLEINFELDER One Beacon Street, Suite 8100, Boston, MA 02108 p | 617.497.7800 f | 617.498.4630 ED_019088A_00020378-00097 COPLA Standard Operating ProceduresCity of Holyoke KLEINFELDER Bright People. Right Solutions. Illicit Discharge Detection and Elimination Plan SOP 3: Locating Illicit Discharges Identification verification of illicit discharge by City. Notify all responsible parties for zny such discharge. Require immediate cessation of improper disposal practices. Can the source of the illicit discharge be identified? Yes No Is the source a direct-Is the source an indirect plumbed source?source? Yes No Yes No Can the source be eliminatedCan the source be eliminated within 60 days ofwithin 60 days of identification verification ofidentification verification of the original illicit discharge?the original illicit discharge? Yes No Yes No City shall establish anCity shall establish an expeditious schedule, not toexpeditious schedule, not to exceed one (1) year, for itsexceed one (3) year, for its elimination elimination Further investigation (i.e. dye testing, smoke testing, CCTV, etc.) Figure 2-Steps to Eliminate Illicit Discharge as per Consent Decree If the source of an illicit discharge is located, proper removal ensures that it does not recur. This includes documenting any repairs, installation of new sanitary sewer connections, or any other corrective actions on an Incident Tracking Sheet (Attachment 1). This should include, but is not limited to, the following information: 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 Project No. 20233959.001Page 7 of 8February 2023 2023 Kleinfelderwww.kleinfelder.com KLEINFELDER One Beacon Street, Suite 8100, Boston, MA 02108 p | 617.497.7800 f | 617.498.4630 ED_019088A_00020378-00098 COPLA Standard Operating ProceduresCity of Holyoke KLEINBriFghEt PLeopDle.E RiRght SIolultiolns.i cit Discharge Detection and Elimination Plan SOP 3: Locating Illicit Discharges A final inspection is required to confirm the illicit connection has been removed. As per the Consent Decree, within one year following the removal of a verified illicit discharge, the City shall conduct additional dry and wet weather (see SOP's 1 and 2) monitoring to confirm that the illicit discharge has been eliminated. If confirmatory screening indicates evidence of a continued potential illicit discharge, additional investigation of the catchment shall be scheduled and removal of the illicit discharge is required. Table 3-Illicit Discharge Enforcement Summary Enforcement Source IdentifiedAuthorityProcedure to Follow One - time illicitOrdinance enforcement discharge (e.g. spill,authority (e.g. Code dumping, etc.)Enforcement Officer) Contact Owner * Issue Notice of Violation * Issue fine * Contact Owner Intermittent orIssue Notice of Ordinance enforcement continuous illicitViolation authority (e.g. Code discharge from legalDetermine schedule for Enforcement Officer) connection removal * Confirm removal Intermittent or continuous illicit discharge from illegal connection or indirect (e.g. infiltration or failed septic) Plumbing Inspector orNotify Plumbing ordinance enforcementInspector or ordinance authorityenforcement authority Intermittent or continuous illicitOrdinance enforcement discharge from illegalauthority (e.g. Code connection or indirectEnforcement Officer) (e.g. failed sewer line) * Issue work order * Schedule removal * Remove connection Confirm removal Notify exempt third AnyUSEPAparty and USEPA of illicit discharge Attachments 1. Incident Tracking Sheet Related Standard Operating Procedures 1. SOP 1: Dry Weather Outfall Inspection 2. SOP 2: Wet Weather Outfall Inspection Project No. 20233959.001Page 8 of 8February 2023 2023 Kleinfelderwww.kleinfelder.com KLEINFELDER One Beacon Street, Suite 8100, Boston, MA 02108 p | 617.497.7800 f | 617.498.4630 ED_019088A_00020378-00099 APPENDIX G IDDE EMPLOYEE TRAINING RECORD KLEINFELDER Bright People. Right Solutions. 20233959.001A / BOS23R154074 May 2023 ED_019088A_00020378-00100 HR-001 Training Documentation Form Please complete the form in its entirety. All participant names on the Training Documentation Form must be entered into the Talent Up system for accurate employee attendance tracking. All hard copies of the completed Training Documentation Forms must be kept on site for a minimum of five years. Title of Training SessionTraining Course # (ifTraining BU / Project Location (please applicable):include address if applicable): Name of BU / Project Training Coordinator:Date of Training:Time (e.g. 2 pm-4pm):Duration (hours): Training Instructor:InternalExternalVendor / Consultant Name and Company (if applicable): Instructor Name: CEU (if applicable):Reason for Training (check all that apply): New InformationRecertification Skill Development Regulatory Refresher Tailgate Requirement Training Training Materials and Outline Used (i.e. Powerpoint, Hands On, Youtube Video, etc.): Participants Veolia Employee ID City Employee IDEmployee NameEmployee SignatureDate 1 2 3 4 5 6 7 8 00 9 10 11 12 13 ED_019088A_00020378-00101 Veolia Employee ID City Employee ID Employee Name Employee Signature Date 14 15 16 17 18 19 20 22--2OE2 21 23 24 25 222622 27 28 29 232023 31 32 333433 35 36 37 38 39 40 ED_019088A_00020378-00102