HomeMy WebLinkAboutIDDE Investigations Training 2021PUBLIC WORKS
CITY OF DURHAM
IDDE Investigations Training
April 15, 2021
Objectives
Map Options
Complaint Triage
Investigation Scenarios
Enforcement Process Overview
PUBLIC WORKS
CITY OF DURHAM
919.560.4326 DurhamNC.gov Follow Us @GtyofDurhamNC O
PW Web Map Upgrade
Web Map Upgrade
Important Message from Public Works GIS
This fiscal year, PWGIS has completely overhauled our web map and it is ready to be put into production. We highly
recommend you start using this new map to get familiar with the functionality. The current Public Works Web Map will
be deactivated at the end of April 2021, so please capitalize on using it beforehand.
Below is a link to the new web map with instructions on how to log in to access the map.
Public Works Web Map
When you open the link, you will be prompted to log in. The username will be the user name you log in to your
computer with " @DURHAM_DOMAIN" added at the end. Your password will be the password you use to sign in to
your computer, Below is an example of what it will look like.
Username: CoryCa@DURHAM_DOMAIN
Password: *************
Please let us know if you encounter any issues while using the new web map or have any questions via email:
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PUBLIC WORKS
CITY OF DURHAM
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CITY OF DURHAM
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Operational layers
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1 ❑ Outfall Screening
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❑ Weekend Enforcement Locations
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1 ❑ Current Ambient Monitoring Sites
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1 ❑ Active Building Permits
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PUBLIC WORKS
CITY OF DURHAM
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CITY OF DURHAM
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FieldDescription Illegal grease dumping - - - ► ❑ Weekend Enforcement Locations
FieldAddress 110Orange St rU1, �6
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In vestigationDate 12/19/2016, 7:00 PM ► Q ISWI Facilities
Zoom to ... ► ❑ Active Building Permits
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Pop Quiz!
How many investigations have we
conducted so far in FY21?
How many investigations identified a
source?
What was the most common source?
What was the most common sub basin?
How many investigations remain open?
What key complaint words were most
commonly associated with "No problem
found?"
PUBLIC WORKS
CITY OF DURHAM
173
126 (73%)
E&SC (Petroleum right behind)
Ellerbe Creek
27 (16%)
Color/Turbidity
Assessing Complaints
ALWAYS ASK YOURSELF: "IS THIS A WATER QUALITY PROBLEM?"
— Does the complaint allege contamination of
• surface waters?
• the MS4?
— Just because we are the only environmental agency in the jurisdiction does not
mean you should force a connection between a pollution problem and the
drainage system. We have specific
• Expertise
• Equipment
• Authority
— Is the complaint an actual problem? Or, is it a possible problem?
• NO PRE -CRIME
• Weigh out the likelihood that a problem may occur with the severity of the
problem if it occurs.
PUBLIC WORKS
CITY OF DURHAM
Complaint Triage
A City Council member email forwards a resident complaint about what seems to be
a failed development. The complaint alleges health issues due to stagnant water,
appearance issues, property damage, sewer damage, and erosion issues.
Is this investigable? How would you assess?
PUBLIC WORKS
CITY OF DURHAM
E&SC Complaints
• City MS4 NPDES permit requires:
— Reduce pollutants in stormwater runoff from construction activities, within the
permittee's regulatory jurisdiction, disturbing one or more acres of land surface and
those activities less than one acre that are part of a larger common plan of
development.
• DEQ recognizes that County has been delegated to handle these via their erosion control
program
We're not completely off the hook for these.
PUBLIC WORKS
CITY OF DURHAM
Complaint Triage
A City Water & Sewer crew chief calls the hotline to report a sanitary sewer overflow
in progress. You are given the facility ID of the overflowing manhole.
Is this investigable? How would you assess?
PUBLIC WORKS
CITY OF DURHAM
Complaint Triage
A hotline caller complains of a bright green color in the stream at Forest Hills Park,
near the tennis courts. The caller also says there is a nasty rotten, maybe sewage
smell near the stream.
Is this investigable? How would you assess?
PUBLIC WORKS
CITY OF DURHAM
Complaint Triage
#1—failed development ?
#2 — City SSO ?
#3 —green stream ?
PUBLIC WORKS
CITY OF DURHAM
City Sanitary Sewer Overflows
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PUBLIC WORKS
Lei 11WAMaBig] 1.4;Y- ul
WQ Unit Role in City SSOs
• Timely response
• Identify origin
• Identify MS4 entry
• Locate outfall to surface waters
• Track flow downstream
• Advise WSM on extent of sewage contamination
• Advise on pump location
• Return to check stream ammonia concentration post -pump install
• Recommend additional pumping or removal
• Document findings and actions
PUBLIC WORKS
CITY OF DURHAM
Typical Complaint Sources
• Directly from Water & Sewer crew
— Usually give an address or cross street
— Sometimes give a facility ID
— Commonly reported after crew is onsite and has restored flow
• Citizen call/email/web report
— Usually give an area where odor or discoloration in stream observed
— Reported usually while overflow still in progress
PUBLIC WORKS
CITY OF DURHAM
The Complaint
• A caller who stopped for lunch at the Hardy's on N Miami and Raynor says that there's a
manhole in the parking lot with sewage coming out of it.
• They text you a photo:
PUBLIC WORKS
CITY OF DURHAM
City of San Diego
Metropolitan Wastewater Department
5 gpm
Reference Sheet for Estimating Sewer Spills
from Overflowing Sewer Manholes
All evimates are catcutated in gaflonsper minute (gpm)
225 gPeR 25a 9PM
All pElotos were taken during a de lemutralion using rnplered water Irorn d hydrant in toaperaSian wills Ih,- C+ty of San 'Kega§ Wale, Deparimem.
Wastewater Collection Division
(619 ) 654-4160 ,
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Pre -Field Tasks
PUBLIC WORKS
CITY OF DURHAM
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CITY OF DURHAM
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PUBLIC WORKS
CITY OF DURHAM
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PUBLIC WORKS
CITY OF DURHAM
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Private Sanitary Sewer Overflows
PUBLIC WORKS
CITY OF DURHAM
Types of Discharges
SourceTeA
. Apartment/Commercial lateral
■ Discharging sand filter system
■ Failing septic system
■ House/Duplex sewer lateral
PUBLIC WORKS
CITY OF DURHAM
Typical Complaint Sources
• Directly from Water & Sewer crew
— Usually give an address
— Commonly refer private issue to us once they've decided it is not a City issue
• Citizen call/email/web report
— Usually report seeing flow in curb or ditch leading from residence
— Can also be a report of odors, constant flow
• Neighborhood Improvement Services
— Will provide address
— Residence under investigation for other housing code issues
— NIS Inspector will have (usually) observed signs of sewage leak
PUBLIC WORKS
CITY OF DURHAM
WQ Unit Role in Private SSOs
• Timely response
• Identify origin, confirm as sewage
• Determine if discharging to MS4/surface waters
• Identify responsible party
— Resident owner
— Landlord/management company
— Property owner/management company
• Instruct on corrective actions
• Issue Notice
• Follow up to check for compliance
• Enforcement as appropriate
• Document findings and actions
PUBLIC WORKS
CITY OF DURHAM
Effective Corrective Actions
• "diagnose and repair"
• Solids removal and disposal
• Contaminated soil removal
• Spread hydrated lime over
contaminated area
PUBLIC WORKS
CITY OF DURHAM
50 LBS. NET 1,11,11
L�/IVIE I
COMPANY
HYDRATED
LIME
KEEP 'OUT NG IL , 1�
See Back Panel For Caution Betore Use
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TEXAS LIME COMPAlly
CLEBURNE, TEXAS
Enforcement
Process
Informal
Requirement
Compliance?
PUBLIC WORKS
CITY OF DURHAM
Evidence of violation
Choice of
First-time
No further action
Notice of Penalty
Assessment
Nonce of Violation
Compliance?
Recalculate civil
penalty
No further action
Recalculate civil
penalty
Nonce of Penalty
Assessment
Pursue
Compliance? Nv alternative
remedy
yees
•
No further action
Proper Service of Notices
• USPS Certified Mail with return receipt
• In -person delivery to
— Named responsible party
— A person of reasonable age and discretion at RP's residence
— An agent of RP at RP's business
• USPS First Class Mail and posted in a conspicuous place at RP's residence or place of
business
EMAIL IS NOT A LEGALLY ACCEPTABLE MEANS OF SERVICE
AND DOES NOT "COUNT" AS PROPER SERVICE
PUBLIC WORKS
CITY OF DURHAM
Due Process Period
1-Z
The 10-day period granted to the RP to exercise their right •
to request a hearing and/or submit evidence. �'•°"'T"''�°•
You cannot issue a Notice of Penalty prior to this time �$ 11b�Z-�11La tq
period elapsing. 25
PUBLIC WORKS
CITY OF DURHAM
r,,A
f Violation Remedies
• Civil Penalties
• Administrative Remedies
— Consent Orders
— Administrative Orders
Hann — Security for Compliance
— Termination of City Utility Service
— Costs Added to City Utility Bill
— Termination of Access
— Withholding of Approvals
• Judicial Actions
— Injunction
— Abatement
— Criminal Prosecution
PUBLIC WORKS
CITY OF DURHAM
UNCOMMON
RARE
EXTRAORDINARY
Enforcement Meetings
Alleged responsible parties have a due process right to meet with
us and have the evidence explained as well as rebut evidence.
• Attendees:
— Water Quality Manager (at their discretion)
— Water Quality IDDE Supervisor (required)
— Water Quality Lead investigator for the enforcement action (required)
— Putative party responsible for the violation(s)
• Meeting Agenda:
— Introductions of meeting attendees and signing of attendance log
— City's review of case and enforcement posture
— City's presentation of relevant evidence of violations and responsibility
— Alleged responsible party's presentation of exculpatory and mitigating evidence
— Group discussion of facts, circumstances, and relevant regulations
— Adjourn
PUBLIC WORKS
CITY OF DURHAM
PUBLIC WORKS
CITY OF DURHAM