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Home My WebLink About3c-04 Investigate for Illicit Discharges SOP RevisedCity of Cape Canaveral Proactive Inspection Program Procedure and criteria for identifying priority areas/facilities: For consistency with the Municipal Separate Storm Sewer System (MS4) National Pollutant Discharge Elimination System (NPDES) permit, the following areas are considered a priority in the inspection program: Industrial, commercial or mixed use areas; Areas with history of past illicit discharges and/or illegal dumping; Areas with on-site sewage disposal systems; and Areas upstream of sensitive or impaired water bodies. The attached map depicts the areas zoned as industrial or commercial, that lie within our MS4 contributing area or in an area that discharges from an outfall for which we are responsible. The map is updated as needed by the Community Development Department and saved as a PDF format file for use by all. List of identified priority areas/facilities: Every year, a list of addresses is revised to include facilities that have coverage under the Multi-Sector Generic Permit (MSGP) as listed by Florida Department of Environmental Protection (FDEP). If any facilities that appear to require an MSGP are not on the FDEP list, the names and addresses of those businesses are referred to FDEP. Annual schedule for inspections: All priority areas/facilities are inspected every year. If an area is found to have illicit discharges/ connections/dumping, it is re-inspected for compliance and if warranted, specific facilities within that area are considered for placement on the high risk facility list for more frequent inspection. In addition, inspections for signs of illicit discharges are part of the Standard Operating Procedure for all structural control inspections and maintenance. A “checkbox” for this activity is included on the inspection forms for those activities. If a suspected illicit is identified, it is reported to Code Enforcement for investigation. Finally, all appropriate field personnel receive illicit discharge and illegal dumping identification and notification training. If a suspected illicit discharge is identified during the course of performing their regular activities, it is reported to Code Enforcement for investigation. Procedure for conducting inspections: The inspector(s) patrols the prioritized area searching for indications of illicit discharges/ connections/dumping into the City’s MS4, in accordance with the training received. If any are identified, the inspector makes a cursory attempt at identifying the source of the illicit. If the source is identified, the inspector makes the decision to either approach the facility owner or refer the finding to his supervisor for further action. In speaking with the facility owner or operator, the inspector advises of the findings and cites the ordinance which prohibits such discharges. The inspector may use photo documentation to support the inspection. The inspector indicates his/her intention to return to verify that the problem has been corrected. If no source is identified, the findings are reported to the inspector’s supervisor for further investigation. Pro-active inspections also take place during the inspection of structural controls and other MS4 components by Public Works Services Department personnel that are trained in illicit discharge identification and reporting. Procedure for tracing source of discovered illicit discharge: Visual observation, investigation and testing, if necessary, are used to identify the source of an illicit discharges/connections/dumping. Procedure for eliminating the discharge: If an illicit connection to the MS4 through a pipe is identified, it is immediately terminated (plugged or removed). If the illicit is traced back to a property owner/operator, the owner of the property is contacted by registered mail. The owner is notified of the problem and asked to address the situation immediately. The owner is also notified of the re-inspection date, typically one week. Procedure for documenting the inspections and enforcement activities: The MSGP coverage research and reporting is documented by the copies of the lists generated during each step (list of facilities within MS4 that are commercial/industrial), list of facilities in the City with MSGP coverage and the list of facilities that appear to need MSGP coverage but appear not to have it). These lists will be maintained with other back-up documentation to support the annual inspection activities conducted by the City. The attached inspection form is used for pro-active inspections and the subsequent follow-up. Photo documentation is also provided, as needed. Procedures for enforcement actions (or referrals to appropriate jurisdictional authority): For cases within Cape Canaveral’s MS4 contributing area, an unresolved matter is handled by Code Enforcement. For cases outside Cape Canaveral’s MS4, the appropriate entity is notified (FDOT, Brevard County, etc.) by registered mail. Identification of staff /department/outside entity responsible for inspections and for enforcement: Inspection activities are carried out by the Public Works Services Department. Follow-up and management are provided by the Public Works Services Department. Documentation is handled by the Public Works Services Department. Description of resources allocated to implement this permit element: Approximately $0 (Staff time only) has been allocated for this program for the FY16/17 fiscal period. City of Cape Canaveral Proactive Illicit Discharge/Illegal Connection Inspection Form (Use as many sheets as necessary) Date of Inspection: _____________ Inspector Name: ___________________________ □ New Inspection □ Follow-up Inspection Description of inspection area: ____________________________________________________ ______________________________________________________________________________ Identification of MS4 component that could receive discharge from this site/area: ______________________________________________________________________________ Findings: Evidence of illicit connections to storm sewer? Yes___ No___ Evidence of dumping/spills to storm sewer? Yes___ No___ Evidence of wash water going to storm sewer? Yes___ No___ Storage tanks leaking or improperly contained? Yes___ No___ Stockpiles/debris piles uncontained? Yes___ No___ If “yes,” to any above, describe: ____________________________________________________________________________________________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ Type of Enforcement Action Taken: _______________________________________________ Date to verify correction: __________________