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Home My WebLink AboutIDDE Investigations Training 2022PUBLIC WORKS CITY OF DURHAM IDDE Investigations Training April 28, 2022 Topics ESRI Explorer Mobile App The Pandemic in Review Newly Revised Procedures Complaint Triage Private Sewage Investigation Best Practices Enforcement Process Overview PUBLIC WORKS CITY OF DURHAM 919.560.4326 DurhamNC.gov Follow Us @GtyofDurhamNC O Google App Store Link F Sign in Specify the URL to your portal e.g. https://<serven/portal https://webgis.durhamnc.gov/portal CONTINUE Recent hitps://webgis.durhamnc.gov/portal ESRI ArcGIS Explorer 10:28 n 10:28 ii O$ 0 i€ 0 7t ,nl 53%. Maps R = S Explorer for Android wants to access your Durham Groups City -County ArcGIS Enterprise Portal account information Public Works Sign in to Durham City- Oesn 6 Map:: County ArcGIS Enterprise Portal Featured by Durham City -County ArcGIS Enterprise Portal Username jamesaz@durham_domain Demolition Permits Password Forgot password? CANCEL Apple App Store Link 10:28 11 O d IiW -ft * N1 0 1 53 I F Public Works 20 Pavement Conditions 2018 Map SW80 Trail Pavement Condition Webmap Explorer Utility Map Pending Assessment Review Map No Background ReferenceLayer_M ap_T EST III 0 < III 0 0 < A few years, at a glance How many investigations did we conduct? 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 CITY OF DURHAM DESCRIPTION, GUIDELINES, AND PROCEDURES FOR ILLICIT DISCHARGE DETECTION AND ELIMINATION (IDDE) INVESTIGATIONS Reviewed bW Oty of Durham -Department of Pul Works Stormwater & GIS Services Division Water Quality Unit Date. Michelle Wooltolk, Water Quality Manager or, ela¢rm s.¢�.�.x¢a Qa s.n�¢,—fPtPl sso-asas wrrrw. a�r1��mNCaor/no arNgr✓Pbn a<vs w—anbege/rbeFng Cm¢ms rFbedpbin lnfenrra Seorm.Pttr vuesr Ea�cm�on—Smfore Water Q�mlay—Srwm.rorn ailing-615 Mappng PUBLIC WORKS CITY OF DURHAM • Reorganized, streamlined • Removed broken references and links • Included complaint assessment guidance • Rewrote general procedure • New guidance on common investigation tools/techniques • Full guidance on reporting to state agencies F:\SW\Division Files\Water Qua lity\Investigations\Documents\Procedures Guidelines for Enforcement of the Stormwater Management and Pollution Control Ordinance CITY OF DURHAM City of Durham — Department of Public Works Stormwater & GIS Services Division Water Quality Unit Reviewed by: Date: Michelle Woolfolk, Water Quality Manager City of Durham Stormwater & 615 5emcet (919)560-¢376 wwwd�rhomnr aav/.rarmworer D`igrt/Plan Review I Drainage/floading Can— J fbodpfarn lnformaron sw—watervablic Ed—tion J surface water Qaanty I starmwarereirling J GIs Wrapping PUBLIC WORKS CITY OF DURHAM • Full rewrite • Defines general enforcement process/procedures • Defines content of Notices • Proper Notice issuance • Enforcement Meetings • Defines all types of remedies 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 Durham County has an erosion control program and that there is a formal agreement between City and County The City is 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 sewage discharge from a private residence. No lateral cleanout was found by that crew. Is this investigable? How would you assess? PUBLIC WORKS CITY OF DURHAM Complaint Triage On an Saturday, a hotline caller leaves a message complaining that their neighbor is doing some landscaping and has a big pile of mulch in the street. Is this investigable? How would you assess? PUBLIC WORKS CITY OF DURHAM Complaint Triage #1—failed development ? #2 — private sewage leak ? #3 — mulch ? PUBLIC WORKS CITY OF DURHAM Private Sanitary Sewer Overflows 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 Discharging sand filter system M 36 Failing septic system Apartment/Commercial lateral House/Duplex sewer lateral PUBLIC WORKS CITY OF DURHAM Types of Private Sewage Discharges (n=522) 83 173 230 50 100 150 200 250 Number of Investigations Pre -Field Tasks PUBLIC WORKS CITY OF DURHAM Research 0 Equipment Field Tasks 1 3 q 5 6 7 S 1� Ammonia as Nitr en , PPM JL� Y CAT. NO-: C-1510 CNEMfZ 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 i 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