SECTION C-10.0, ILLEGAL DISCHARGES/ILLICIT CONNECTIONS

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Piers Sydney French
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1 C-10.0 ILLEGAL DISCHARGES/ILLICIT CONNECTIONS C-10.1 Introduction Illegal discharges/illicit connections (ID/IC) are potential sources of pollutants within municipal storm drain systems. The purpose of DAMP Section 10.0 is to ensure that the Permittees have a programmatic framework for detecting and quickly responding to non-stormwater discharges to their storm drain systems. C-10.2 Accomplishments C Illegal Discharges/Illicit Connections Program The ID/IC Program provides guidance for Permittees when identifying, responding to and mitigating the effects of non-stormwater discharges. DAMP Section 10.0 requires the Permittees to: Detect illegal discharges and illicit connections An innovative Dry Weather Reconnaissance Program, based upon statistically derived benchmarks, was implemented in the Santa Ana Region specifically to identify illegal discharges and illicit connections during the typically dry summer months of May through September using a suite of water quality analyses conducted in the field at designated random and targeted drains. The reporting period marked the seventh season of dry weather monitoring in the Santa Ana Region. The Non-storm Water Action Levels (NALs) Dry Weather monitoring program replaced the Dry Weather Reconnaissance Program in the San Diego Region May Two rounds of NALs monitoring were completed in Facilitate Public Reporting Telephone and web-based reporting systems (both countywide and in individual cities) for the general public have been established and are advertised in the Program's public education materials, Orange County "White Pages" telephone directories, and Permittee websites. A total of 2,744 complaints were received during the reporting period of which 169 were received via water pollution telephone hotlines (Table 10.2; Figure 10.1). During the reporting period, the County developed an iphone application to report water pollution and other public works maintenance issues. A total of 9 complaints were received during the reporting period via the iphone application, (compared to 3 complaints in ). Investigate Each Permittee has designated Authorized Inspectors to investigate compliance with, detect violations of, and take actions pursuant to their Water Quality C-10-1

2 Ordinance. Authorized Inspectors follow specific procedures documented in the Model Investigative Guidance for Orange County Illegal Discharges and Illicit Connections Program (Investigative Guidance Manual). During , the Permittees encountered and sought to mitigate discharges involving hydrocarbons (265 incidents), inorganic materials (84 incidents), metals (52 incidents), nutrients (44 incidents), organic materials (42 incidents), discharge exceptions (46 incidents), pathogens (75 incidents), wastewater (868 incidents), pesticides (39 incidents), sediment (371 incidents), trash and debris (350 incidents), irrigation runoff (256 incidents in the San Diego Region; irrigation runoff discharges are considered discharge exceptions in the Santa Ana Region), and 320 incidents involving miscellaneous types of materials for a total 2,812 incidents (Table C-10.4). Enforce Enforcement actions are undertaken according to the adopted Water Quality Ordinances and accompanying Enforcement Consistency Guide. The Permittees reported a total of 2,767 enforcement actions, associated with ID/IC investigations during the reporting period. Undertake Training To assist responsible municipal staff in understanding the Illegal Discharges/Illicit Connections Program, eight training modules have been developed and were available to the Permittees in the reporting period: 1) Program Management Training - Introductory 2) Program Management Training - Experienced 3) Authorized Inspector Training Introductory 4) Authorized Inspector Field Implementation 5) Sewage Spill Response Training - Introductory 6) Hands-On Sewage Spill Response Training - Experienced 7) Fire Department Activities Training 8) Investigative Guidance Manual Training In addition to the training modules, the NPDES Inspection Sub-Committee also provided training on various subjects relevant to the ID/IC program. This subcommittee meets quarterly to provide training to Authorized Inspectors and others on issues related to spill response, inspection and enforcement. It also serves as a forum for the coordination and discussion of ongoing difficult or new enforcement, investigation, or enforcement issues and to profile cases or incidents. C Model Sewage Spill Response Procedures Starting in 2000, the County and OCSD began development and implementation of a coordinated sewage spill prevention and response demonstration project referred to as, C-10-2

3 The Countywide Area Spill Control (CASC) Program. Initially intended to be implemented Countywide over a period of 10 years, the implementation schedule has been preempted by Section VII.7. of the Santa Ana Fourth Term Permit which required implementation of the CASC Program s essential elements by May The Permittees have defined essential elements to include the following: 1. Participation in CASC coordination efforts attend meetings in order to receive information on CASC Program developments, and provide notifications to the County of any sanitary sewer overflow (SSO) that may impact or threatens to impact a regional water body. 2. CASC Area Characterization Each Permittee to provide GIS map layers (or other maps if GIS map layers are unavailable) of the stormdrain system and sanitary sewer system to the County in order to define and characterize the area. There were two CASC Program responses in Incident Triggering CASC Activation Packaging Products Manufacturer, Buena Park Ammonia Refrigeration Leak, Santa Ana Receiving Waters Date Type Fullerton Creek/ Coyote Creek/San Gabriel River Santa Ana Delhi Channel 7/25/2012 2/4/2013 Other (clarifier discharge) Volume Diverted to Sanitary Sewer (Gallons) 355,000 Other (ammonia 200 discharge) Total: 355,200 C-10.3 Assessment The current and potential Outcome Levels that could be assessed within the current program are summarized in Table C C Illegal Discharges/Illicit Connections Program Detection: Dry Weather Reconnaissance Program monitoring comprised 230 site visits to 63 locations comprising 44 visits to the random sites and 186 visits to the targeted sites (note: the dry weather monitoring season runs from the beginning of May through the end of September each calendar year). Investigations, prompted by findings of elevated contaminant concentrations, may have been triggered on 220 tolerance interval exceedance occasions. The San Diego Region permit mandated implementation of the NALs monitoring program by May Monitoring under the NALs program is conducted on a yearround basis. Site reconnaissance and training began in June 2012, and 25 sites were sampled in August 2012 (dry season) and January March 2013 (wet season), for a total C-10-3

4 of 50 site visits during the reporting period. Investigations prompted by NALs field exceedances were triggered on 3 occasions. A more detailed analysis of the program and data is included in Section C-11. Field data is now entered into the County CBI system on the same day as monitoring occurs, when feasible. Permittees are provided with login information so they have immediate access to all field data once it is entered into the system. A more detailed discussion of the CBI system is included in Section C Program Focus: Continue implementation of the seasonal Dry Weather Reconnaissance Program in the Santa Ana Region, and implementation of the year-round Dry Weather Non-stormwater Discharge Monitoring Program in the San Diego Region. Reporting: The Permittees field inspectors are trained to detect illegal discharges as part of their daily activities and, indeed, the majority of illegal discharges continue to be detected by Permittee staff. In addition, the Permittees promote hotline numbers, principally SPILL, to receive water pollution complaints and incident information from the public and use database software to document the reported incidents which assists with the tracking of water pollution complaints by source. Headline Indicator Number of Complaints: The Permittees reported a total of 2,744 complaints/incidents during the reporting period. This figure compares to a reported 2,884 complaints/incidents during ; 3,598 complaints/incidents during ; a reported 3,470 complaints/incidents during ; a reported 3,843 complaints/incidents during (Table C-10.2; Figure C-10.1). Level 1: Implement Program Level 2: Increase Awareness Level 3: Behavior Change The overall trend for the past five years has been a decrease in the total number of complaints received. This trend may be the result of a wider societal respect of the need for environmental protection which is resulting in a decrease in accidental and deliberate incidents of discharge. Enforcement: Enforcement actions are undertaken according to the adopted Water Quality Ordinance and accompanying Enforcement Consistency Guide. In instances of noncompliance, the Permittee may adopt one of four types of remedies, including educational letters, administrative remedies, criminal remedies, or other civil or criminal remedies, as appropriate. C-10-4

5 Headline Indicator Number and Level of Enforcement Actions: The Permittees reported a total of 2,767 enforcement actions during This figure compares to a reported 2,877 enforcement actions during ; a reported 3,183 enforcement actions during ; a reported 3,581 enforcement actions during ; and a reported 3,500 enforcement actions during (Table 10.3; Figure 10.2). Level 1: Implement Program Level 2: Increase Awareness Level 3: Behavior Change The five year trend largely represents a decrease in the total number of enforcement actions, indicating a decrease in the total number of ID/IC incidents occurring, particularly given the correlating decrease in the total number of complaints received over the same time period. Training: The Permits require that staff is adequately trained. In response, the Permittees will develop new training modules during the upcoming reporting period supportive of the specified expertise and technical competencies established for individuals in the authorized inspector position, as well as to provide training on NALs investigative procedures. These modules include: o o o o o Existing Development Program Management Commercial/Industrial/Municipal Inspector Field Implementation Food Facility Inspector Municipal Facility Model Maintenance Procedures NALs Investigative Guidance Program Focus: Deliver new training modules supportive of the specified expertise and technical competencies established for individuals in the Authorized Inspector position. C Model Sewage Spill Response Procedures During the reporting period, CASC was activated on two occasions Program Focus: Further implementation of the CASC on a countywide basis. C-10-5

6 C-10.4 Summary C Illegal Discharges/Illicit Connections Program The Permittees program for responding to complaints regarding ID/IC is a long established element of the Program. The major elements of the program, including the Dry Weather Reconnaissance and NALs Monitoring Programs, the facilitation of public reporting of complaints, and the designation and training of Authorized Inspectors, continue to be vital and successful pieces of the countywide Program Model Sewage Spill Response Procedures During the reporting period, the Permittees successfully implemented essential elements of the CASC Program countywide, and implementation will continue in the next reporting period. C-10.5 ID/IC Dry Weather Monitoring During the reporting period, notifications of illegal discharges and NALs exceedances (in the San Diego Region) were made from the field by monitoring staff to city Authorized Inspectors (see Tables C-10.5 and C-10.6). The individual jurisdictional PEAs should be consulted for information on city responses to these notifications. C-10-6

7 Table C-10.1: Current Outcome and Potential Outcome Levels (ID/IC) Effectiveness Assessment Outcome Levels ID/IC Program Component Level 1 Level 2 Level 3 Level 4 Level 5 Level 6 Document Stormwater Program Activities Raise Awareness Change Behavior Load Reduction Runoff Quality Receiving Water Quality Detection of ID/IC Identify ID/IC, facilitate public reporting of complaints Track number of complaints by source, facility type, or pollutant Reduced occurrences of ID/IC Enforcement Issue Enforcement Actions Track number of Enforcement Actions Track number and type of Enforcement Actions P Discharge is eliminated P Change in runoff quality Training Track # and type of training P Surveys Key: = Currently Achieved Outcome Level P = Potentially Achievable Outcome Level C-10-7

8 Table C-10.2: Sources of Complaints/Incidents: Comparison of , , , and C-10-8

9 Table C-10.3: Permittee Enforcement Actions: Comparison of , , , and C-10-9

10 Table C-10.4: Types of Materials C-10-10

11 Table C-10.5: Santa Ana Region Dry Weather Monitoring Notifications, Reporting Period C-10-11

12 Table C-10.5: Santa Ana Region Dry Weather Monitoring Notifications, Reporting Period (continued) C-10-12

13 Table C-10.5: Santa Ana Region Dry Weather Monitoring Notifications, Reporting Period (continued) C-10-13

14 Table C-10.5: Santa Ana Region Dry Weather Monitoring Notifications, Reporting Period (continued) C-10-14

15 Table C-10.6: San Diego Region NALs Field Exceedance Notifications, Reporting Period C-10-15

16 Figure C-10.1: Source of Complaints, Comparison of , , , and C-10-16

17 Figure C-10.2: Enforcement Actions, Comparison of , , , and C-10-17

Model Illicit Discharge and Connection Stormwater Ordinance ORDINANCE NO.

Model Illicit Discharge and Connection Stormwater Ordinance ORDINANCE NO. SECTION 1. PURPOSE/INTENT. The purpose of this ordinance is to provide for the health, safety, and general welfare of the citizens