HomeMy WebLinkAbout3c-04 Investigate for Illicit Discharges SOPCity 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 each year, typically in the month of _________, by the ______________ department and saved as a PDF format file for use by all.
List of identified priority areas/facilities:
Each year, a list of addresses is created from an overlay of the map created above and the County's current parcel map and associated database. This list is cross-referenced with the
Florida Department of Environmental Protection (FDEP) list of facilities that have coverage under the Multi-Sector Generic Permit (MSGP). 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. The annual creation of the list of addresses and cross-referencing with the FDEP MSGP
database is typically done in the month of _____ each year.
Annual schedule for inspections:
All priority areas/facilities are inspected at least once within the current five-year permit term. The inspection area has been divided into _____ zones. One zone will be inspected
during each year of the permit term. 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 _________________ for investigation under the Reactive Investigations
program.
Finally, all appropriate field personnel receive illicit discharge and illegal dumping identification and notification training. If a suspected illicit is identified during the course
of performing their regular activities, it is reported to ___________________ for investigation under the Reactive Investigations program.
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 ___department or division or position___ 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 ___________________. 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, 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 permit activities conducted by the City. The list of facilities that appear to need MSGP coverage will be sent to FDEP for follow-up.
The attached inspection form is used for pro-active inspections and the subsequent follow-up. Photo documentation is also provided, as needed. _____________describe how the records
are maintained and used to follow-up with any necessary enforcement action_______.
Procedures for enforcement actions (or referrals to appropriate jurisdictional authority)
For cases within ___permittee name____’s MS4 contributing area, an unresolved matter is handled by the ___department or division or position___. For cases outside ___permittee name____’s
MS4, the appropriate entity is notified (FDOT, Palm Beach County, etc.) by ___department or division or position___.
Identification of staff /department/outside entity responsible for inspections and for enforcement
Inspection activities are carried out by ___department or division or position___. Follow-up and management are provided by ___department or division or position___. Documentation
is handled by the ___department or division or position___.
Description of resources allocated to implement this permit element:
Approximately $_______________ has been allocated for this program for the _______________ 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: __________________