Willow Glen Town Square Case Study
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1 Willow Glen Town Square Case Study Ambiguous Responsible Parties City of San Jose Environmental Services Department Bahar Ghofraniha
2 Downtown Willow Glen - Lincoln Ave Site Description Combined Commercial / Residential zone Multi-tenant buildings Restaurants, coffee/juice shops, retail stores, supermarkets, law offices, etc. Sidewalks, access roads, parking spaces
3 Area of concern: Parking lots - back of the buildings Site Description Open tallow enclosure spot (chain link fenced zone) Used by 5 food places produce oil/ grease Managed by Property Manager Six parties involved Indoor/ locked dumpster areas for trash only
4 Site Description Enclosure Area/ Nearby Drains: Parking lot a few feet away from the enclosure Enclosure area (plugged drain) Behind enclosure on the planting area
5 History IDDE & FOG Violations Last IDDE case: 08/ /2016 Storm drains: Debris, cigarette butts, other pollutants Enclosure area: Greasy tallow bins/ open buckets of cooking oil/ cardboards/ trash Outside of tallow zone/ Parking lot: Greasy/ traces of fresh oil Health issues: Rodent and insects (cockroach) infestation IND: Industrial/ commercial (inspections) IDDE: Illicit Discharge Detection and Elimination (inspections) FOG: Fat Oil and Grease (inspections)
6 History (IDDE Inspections) Cut out curb leading to SD Liquid waste and oil Accumulated trash and cardboards Open liquid waste containers
7 History (IDDE Inspections) IDDE inspector conducted inspections Unresponsive Property Manager No Remedial actions (about two months) Issued multiple violations/ citations Results: Cleaned parking lot/ storm drains/ enclosure area Fixed the curb (cut out curb leading to a storm drain) IDDE: Illicit Discharge Detection and Elimination
8 IND Initial Inspection Inspection of late Oct 2016: Inspected Restaurants (just a month after the IDDE case) Parking lots/storm drains/dumpster and tallow bin zones/ outdoor mop sinks Violations Found: Enclosure area Enclosure walls Two tallow bins IND: Industrial / Commercial (Inspections) IDDE: Illicit Discharge Detection and Elimination (inspections)
9 IND Inspections - Findings
10 IND Inspections - Findings
11 Involved Parties Five restaurants used the enclosure area Produced oil and grease One/ two might have more contributions Assumed /claimed Property Manager was the responsible party Per contracts Property Manager not available (Have an office) Six Responsible Parties in this case
12 Questions How would you go about enforcing? Multiple tenants pointing fingers (restaurants used tallow zone) Businesses relying on property manager (PM) for cleaning Responsible Party is not responsive (does not clean the enclosure area)
13 IND Enforcements Issued Referral to Administrative Citation (ACR) RP: Property Owner No direct discharge to the storm drain system Responsibilities: Restaurants: Tallow bins Property Manager: Enclosure area/parking lot/ storm drains Dry methods only Effective methods to prevent violations in the future Move tallow bins to the trash area (indoors/ locked) No remedial actions for three weeks Conducted Follow up inspections Issued multiple citations ACR: Escalate enforcement action to evaluate the citation IND: Industrial/ Commercial (inspections) RP: Responsible Party PLUGGED
14 The Third week: IDDE: New Violations Complaint about a power washing tallow bins/ enclosure area/ parking lot IDDE inspectors opened a new case (direct discharge to the SD system/ complaint-based) Signs of power washing/ grease in the drain/ splattered grease on parking lot surface This storm-drain flows downstream through a media-filter Illicit Discharge Detection and Elimination (inspections)
15 IDDE Follow up Enforcements Parallel Inspections/Enforcements (IDDE & IND) IDDE Inspections Issued Administrative Citations to both companies Property Manager & Contractor Suspected that grease had impacted the media filter (C.3) Required inspections and service of media filters/ clean up the storm lines Property Manager (responsible party) was not responsive Issued more citations (during the course of two months) Invited for a compliance meeting (RP didn t show up) Finally addressed all violations by early Jan IDDE: Illicit Discharge Detection and Elimination (inspections) C.3: New Development and Redevelopment IND: Industrial/ commercial (inspections)
16 IND Follow up Enforcements Continued IND Inspections: Yearly basis inspections/ classification based Required clean up of oil and grease from: Tallow bins (lids and sides) Enclosure area Affected parking lot Storm Drain catch basin IND: Industrial/ commercial (inspections)
17 IND Follow up Inspections
18 IND Follow up Inspections Dealing with an unresponsive Responsible Party Discussions over phone calls and s Mailed and ed copies of reports, citations, and recommendations New violations: Trace of oil and grease on parking lot Piles of uncovered soil and construction debris
19 What would you do? Questions
20 GB1 Final Result Dirty Job/ Beautiful Result Restaurants agreed on the indoor tallow bins Individually Responsible Empty enclosure PM removed the bins and cleaned the area Code Enforcement
21 Slide 20 GB1 Ghofraniha, Bahar, 5/2/2017
22 INSPECTORS
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