Illegal Discharge Detection and Elimination

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1 Illegal Discharge Detection and Elimination Ralph Rodriguez, Environmental Inspector II Jamie Avalos, Environmental Inspector I And Patrick Hansen, Environmental Inspector I Watershed Protection May 5, 2011

2 Overview IDDE Program IDDE Investigation Categories and Enforcement Process Investigation Techniques and Tools Case studies

3 City of San Jose IDDE Program Complaint driven calls from citizens, City employees, referrals from other agencies and proactive response. Responded to over 600 in FY IDDE Inspectors investigate complaints, provide education and conduct tiered enforcement as necessary. IDDE Inspectors also perform construction site inspection and C.3 inspections.

4 City of San Jose IDDE Program Priority Discharge/Ongoing Discharge Immediate response Other Incidents- respond within 5 days. Not first responder/off-duty hours.

5 Level 1 City of San Jose Enforcement Tools Verbal Warning/Education Level 2 Official Warning Notice Level 3 Administrative Citation Compliance Meetings

6 Investigation Tools, Resources, and Equipment Safety and personal equipment Tools Resources

7 Gas meter Reflective vest Steel toe shoes Hardhat Safety glasses Disposable gloves Cones Vehicle lights Signs Sanitizer Co-workers for assistance Safety First!

8 Tools and Equipment Vehicle Traffic Control Equipment Storage Light bar Traffic Control

9 Tools and Equipment Manhole pull hooks Sledge hammer Mirror Camera Flash Light Dye Notepad

10 Tools and Equipment Cont.. Storm Sewer Maps GIS Portable tablet/laptop

11 Tools and Equipment Cont..

12 Sampling Equipment Bottles, telescoping poles, bucket, line, waders, ph strips, cooler, labels, stopwatch.

13 Sampling Techniques Code of Federal Regulations Upstream, downstream, and outfall/discharge point Inspector does sampling during initial response Source control during ongoing investigation

14 Additional Resources DOT Sewer Video, Traffic Control, Cleanup, Maps. Fire/Hazmat Police Engineering/Source Control Lab Other Agencies Code Enforcement, Fish & Game, SCVWD, District Attorney.

15 Techniques/Methods Interviews of responsible party, complaining party, and witnesses Visual, smell, and other observations Photos Intra-agency collaboration Surveillance

16 Overview of the IDDE Investigation Storm drain network investigations Drainage area investigations On-site investigations Septic system investigations

17 Storm Drain Network Investigations: Tracking the Source Visual inspections of manholes Presence of Flow Flow direction Odor Color Suspended Materials Deposits or Stains

18 Storm Drain Network Investigations: Dye Testing Check for Cross/Illicit Connections. Additional staff support. Consider: Dye selection Fixtures to test Selecting manhole locations Communication Tracking the Source

19 Storm Drain Network Investigations: Tracking the Source Video Testing Useful when access to property is constrained. Shows flows, leaks, cracks, and blockage, etc.

20 Photo Date Stamp Description Evidence Samples Witness statements/photos Responsible party admission Inspector Observations Site Violation History

21 Common Complaints Leaking vehicles Pool Water Surface cleaning Wash water Chemical Dumping on Public and Private Property Sewage Spill/Sanitary Cleanout Overflow

22 Case Study: Wash Water Complaint: Workers are dumping grease in the back parking lot and using a disinfectant to clean. Wash water is entering the storm drain.

23 Case Study: Wash Water

24 Case Study: Sewage Discharge Complaint: Foamy smelly water coming out of storm drain in the backyard creek.

25

26 Source of sewage discharge was more than 3 miles away

27 Case Study: Hazardous Waste Dumping Complaint: 80 to 100 cans and bottle on sidewalk in front of residence with paint and paint thinner. Some are open containers. Safety hazard for children and if knocked over to storm drains. Has been out there about 2 week and more put out today.

28 Case Study 3: Hazardous Waste Dumping

29 Conclusion Every complaint response is unique. Discharges may involve multiple agencies and multiple responsible parties. Situational awareness is necessary. Goal: educate the public, stop illegal discharges, and achieve environmental compliance.

30 Questions?