Staff Report for action on Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report 1 STAFF REPORT ACTION REQUIRED Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report Date: August 25, 2015 To: Public Works and Infrastructure Committee From: General Manager, Toronto Water Wards: All Reference Number: P:\2015\Cluster B\TW\PWI15021 SUMMARY This report provides highlights of the activities performed in 2014 by Toronto Water's Environmental Monitoring & Protection Unit, which is responsible for Sewers By-law and Water Supply By-law compliance and enforcement (Municipal Code Chapter 681 – Sewers and Municipal Code Chapter 851-Water Supply, respectively). In 2014, the Environmental Monitoring & Protection Unit performed 3,625 inspections and 4,431 sampling events in total that resulted in 33,109 laboratory analyses. There was a total of 680 Notice of Violations issued for non-compliance by the Industrial Wastewater Control and Stormwater Quality groups of the Environmental Monitoring & Protection Unit. Sixty- two companies moved forward to prosecution. Twenty-three companies that were prosecuted in 2014, and in previous years, were convicted with fines totaling $137,000.00. This total does not include the Victim Surcharge Fee (this fee is collected and retained by the Ontario Provincial Government for victims of crime – for fines over $1,000 the surcharge is 25% of the fine). The remaining prosecution files are still before the court. The number of Industrial Waste Surcharge Agreements entered into with companies increased in 2014 and generated approximately $12 million. Similarly, the total Sanitary Discharge Agreements increased as did associated revenues in 2014 totaling $1.95 million. The Outfall Monitoring Program identified 50 cross connections and verified the correction of 16 cross connections. 2014 saw the delisting of 28 Priority Outfalls within Toronto's watersheds thereby improving the environment. PW8.10
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Staff Report for action on Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report 1
STAFF REPORT ACTION REQUIRED
Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report
Date: August 25, 2015
To: Public Works and Infrastructure Committee
From: General Manager, Toronto Water
Wards: All
Reference
Number: P:\2015\Cluster B\TW\PWI15021
SUMMARY
This report provides highlights of the activities performed in 2014 by Toronto Water's
Environmental Monitoring & Protection Unit, which is responsible for Sewers By-law and
Water Supply By-law compliance and enforcement (Municipal Code Chapter 681 – Sewers
and Municipal Code Chapter 851-Water Supply, respectively).
In 2014, the Environmental Monitoring & Protection Unit performed 3,625 inspections and
4,431 sampling events in total that resulted in 33,109 laboratory analyses. There was a total of
680 Notice of Violations issued for non-compliance by the Industrial Wastewater Control and
Stormwater Quality groups of the Environmental Monitoring & Protection Unit.
Sixty- two companies moved forward to prosecution. Twenty-three companies that were
prosecuted in 2014, and in previous years, were convicted with fines totaling $137,000.00.
This total does not include the Victim Surcharge Fee (this fee is collected and retained by the
Ontario Provincial Government for victims of crime – for fines over $1,000 the surcharge is
25% of the fine). The remaining prosecution files are still before the court.
The number of Industrial Waste Surcharge Agreements entered into with companies increased
in 2014 and generated approximately $12 million. Similarly, the total Sanitary Discharge
Agreements increased as did associated revenues in 2014 totaling $1.95 million.
The Outfall Monitoring Program identified 50 cross connections and verified the correction of
16 cross connections. 2014 saw the delisting of 28 Priority Outfalls within Toronto's
watersheds thereby improving the environment.
PW8.10
Staff Report for action on Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report 2
RECOMMENDATIONS
The General Manager, Toronto Water, recommends that:
1. The Public Works and Infrastructure Committee receive this report for information.
Financial Impact
There are no financial implications to the City as a result of this report.
The Deputy City Manager & Chief Financial Officer has reviewed this report and agrees with
the financial impact information.
DECISION HISTORY
At its meeting on September 21 and 22, 2011, during consideration of report PW7.6 from the
Public Works and Infrastructure Committee, City Council requested the General Manager,
Toronto Water, to reinstate the annual report to Council on Toronto Water activities, including
Sewers By-law compliance and the Outfall Monitoring Program.
Staff Report for action on Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report 5
4) Compliance Plan Agreements
5) Grease Issues
6) Spills & Complaint Response
7) Industrial Water Rate – Block 2
8) Liaison with Other Divisions
9) Pollution Prevention (P2) Program
10) Storm Sewer Outfall Monitoring Program
11) Water Supply By-law Backflow Prevention Program
12) Collaborative Surface Water Monitoring Programs
13) 2014 Pollution Prevention (P2)/Sewer Use By-law Stakeholder Consultation
1) Sewers By-law Compliance and Enforcement - Industrial Inspection and Sampling
Program – Industrial Wastewater Control
Toronto Water ensures that contaminants that may be harmful to the sewer system and
wastewater treatment plants, such as heavy metals and solvents, are restricted to the
permissible levels noted within the Sewers By-law. This is performed by using an established
sampling and inspection target for companies discharging to the sewer system based on risk
potential to pollute (i.e. High, Medium or Low Potential) and impact to the sewer system and
wastewater treatment plants.
Toronto Water's Environmental Monitoring & Protection Unit staff includes Provincial
Offences Officers that inspect industries to determine whether there are any concerns about a
facility’s wastewater discharge to the sewer system. These inspections typically include
evaluation of the manufacturing or production process, chemicals and products used or stored
and waste streams that are generated onsite, which can affect the sanitary and storm sewers.
During an inspection, the Officers make notes, may take pictures, interview staff, obtain
copies of documents and/or process inventory logs, and can collect samples. During routine
inspections, the Officers may make observations or issue directives to rectify issues that were
identified. Samples collected by Officers are analyzed by the Toronto Water Laboratory, an
accredited laboratory, and the results are assessed for compliance with the Sewers By-law
parameter limits.
When time permits, Officers conduct street-by-street searches for new or unknown or unlisted
businesses to increase the industry database listing and assess the risk of the facility to the
sewer system. Occasionally, gap analyses are also performed on sector industry listings,
which are obtained from other Divisions or regulatory agencies. Industrial and commercial
inspections are conducted using a streamlined annual inspection form to allow for efficient
and standardized work.
In 2014, the Industrial Wastewater Control group within the Environmental Monitoring &
Protection Unit conducted 821 industrial and commercial inspections and performed 2,396
sampling events. At peak times in 2014, there were 80 High Potential and 421 Medium
Potential industries. During 2014, 75 Medium Potential industries were re-designated as
Medium Potential Plazas as they included multiple unit buildings with more than one business
sector of interest located in them.
Staff Report for action on Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report 6
Table 1 references the High and Medium Potential percentage (%) completion for Sewers
By-law inspection and sampling for the year 2012, 2013 and 2014. Table 1: Sewers By-law Inspection and Sampling Metrics for 2012, 2013 and 2014
Potential High Potential Medium Potential
Year 2014 2013 2012
2014 2013 2012
Sampling Completion Rate (%)
100% 99% 102% 97% 93% 93%
Inspection Completion Rate (%)
88% 86% 78% 73%
If a violation of one or more Sewers By-law provisions is identified, during a sampling event,
Toronto Water staff may contact the facility to advise of the non-compliance and issue a
Notice of Violation letter. The Industrial Wastewater Control group issued 648 Notice of
Violation letters for the work performed in 2014 for Sewers By-law violations.
In the event that multiple and/or re-occurring violations are identified, stricter enforcement
action may be undertaken. A single violation of sufficient severity can result in Provincial
Offences Officers collecting evidence and proceeding with formal charges under either by-
law, without a Notice of Violation being issued.
Appendix A of this report references the individual categories of violations determined in
2014 categorized into various By-law sections: sanitary, storm, Pollution Prevention Plan,
maintenance access hole and interceptor requirements.
For violations requiring more immediate action, an Order can be served. Non-compliance
with the Order can result in an immediate prosecution and/or the City possibly remedying the
situation at full cost to the person or company.
In 2014, 3 Orders were sent to immediately rectify non-compliance of the Sewers By-law,
Municipal Code Chapter 681. One of the Orders issued was addressed to 10 parties, related to
the address of which the Order was applied, and another Order was issued to 7 parties.
Convictions
Under the Sewers By-law, there were 23 convictions in 2014 resulting in $137,000.00 in fines,
excluding victim surcharge fine of 25%. In 2014, out of the 72 companies investigated for
potential prosecution, 62 were moved forward to prosecution. Many of these prosecution cases
are presently before the courts. Additionally, some prosecutions from previous years continue
to remain before the courts. Appendix B, Table 1, provides details of the Sewers and Water
Supply By-law convictions for 2014.
Table 2, below, denotes the number of compliance and enforcement activities undertaken by
Toronto Water during 2014 and the previous 2 years (for comparison purposes) for all aspects
of the Sewers By-law.
Staff Report for action on Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report 7
Table 2: Comparison of All Sewers By-law Compliance and Enforcement Activities: 2012-2014
Activity 2014 2013 2012
Inspections 3,625 3,621 5,459
Sampling Events 4,431 3,595 3,767
Lab Tests Requested 33,109 28,557 26,150
Notice of Violations Issued 680 745 995
Orders 3 4 3
Complaints 572 473 344
Investigationsi 72 43 40
Prosecutionsi, ii 62 41 36
Convictionsiii 23 10 8
Unsuccessful Prosecutions 0 0 0
Withdrawn Prosecutions where charges laid
0 0 2iv
Fines (excluding 25% victim surcharge fee)
$137,000 $66,750 $57,900
Notes:
i. Prosecution and investigation data includes both the Sewers and Water Supply By-laws for 2014. ii. Prosecution refers to the number of companies or people that had charges laid against them in that year and may still
be before the courts for either Sewers By-law or Water Supply By-law as Toronto Water Provincial Offences Officers are responsible for both By-laws;
iii. Convictions may include multiple prosecutions for a company/person and may include prosecution files concluded from prior years in the year reported; they are for the Sewers By-law and do not include the Water Supply By-law convictions.
iv. One charge was withdrawn as the company entered into a IWSA and paid all the back-fees. The second prosecution was withdrawn against the principal contractor as the sub-contractor company was convicted for the offence.
2) Industrial Waste Surcharge Agreements and Permits
In 2014, companies that exceeded the wastewater sanitary concentration limits for 5 specific
and treatable parameters were given the option of entering into an Industrial Waste Surcharge
Agreement ("IWSA"), with Toronto Water, or installing on-site treatment to comply with the
Sewers By-law. Most companies opted to enter into an IWSA as it is generally more cost
effective than installing a separate wastewater treatment system onsite.
The 5 treatable parameters permissible under an IWSA are: Biological Oxygen Demand
(BOD), Total Suspended Solids (TSS), Total Phosphorous (TP), Phenols, and Total Kjeldahl
Nitrogen (TKN – a measure of concentrated nitrogen and ammonia); all of which are treatable
at Toronto's wastewater treatment plants. Under an IWSA, a company's composite sampling
data (samples that are generally collected over a 24 hour period) is used to evaluate the quality
of wastewater generated by that company for the purpose of recovering a portion of the costs
of providing treatment for the excess amount discharged over the by-law limit.
Staff Report for action on Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report 8
In November of 2012, Toronto City Council decided to continue with the existing approach of
calculating the surcharge fee based on only the parameter that exceeds the by-law limits the
most. Effective January 1, 2013, City Council adopted the maximum fees per parameter
recommended by the City's consultant. Table 3 shows the current rates for Toronto Water's
treatable parameters. Council also mandated that the Environmental Monitoring & Protection
Unit re-evaluate the fees in the first few years, and subsequently in the next 5 years, to
determine if increases are warranted or not. Table 3: Rates for Toronto Water's Industrial Waste Surcharge Agreement Treatable Parameters (effective January 1, 2013)
BOD/Phenolics
(4AAP)
Total Suspended
Solids
Total Phosphorous
Total Kjeldahl Nitrogen
Rates ($/Kg) 0.62 0.60 1.69 1.18
In 2014, at peak levels, there were 232 companies under an active IWSA; this includes 20
facilities that were newly added. Sixteen companies closed operations, or had their agreement
terminated at some point during 2014. By the end of December 31, 2014 there were 216
IWSAs on file. Refer to Appendix C (a), for a complete list of surcharge companies and their
2014 status. The program generated Toronto Water $11.9 million in revenue in 2014, $11.4
million in revenue in 2013 and $9.4 million in revenue in 2012.
Toronto Municipal Code Chapter 441 - Fees and Charges, authorizes Toronto Water to levy a
minimum charge of $500 for Industrial Waste Surcharge discharge and for the Sanitary
Discharge (explained in next section) by way of permits. These permits offset the City’s time
and/or analysis for those companies where less than $500 in invoices would result. In 2014,
Toronto Water billed 74 companies the $500 minimum Industrial Waste Surcharge fee and
generated $50,800 in revenue, which includes the application fee of $800.00 charged for new
Industrial Waste Surcharge Permits. Appendix C (b) lists the industries under a minimum
Industrial Waste Surcharge Permit. In 2014, there were 11 new Industrial Waste Surcharge
permits issued.
In total for 2014, approximately $12 million in revenue was generated from both the IWSA
and the Industrial Waste Surcharge Permits.
3) Sanitary Discharge Agreements and Permits
The City of Toronto enters into agreements with customers that draw from private water
supplies (e.g. Lake Ontario, ground water) and only require a sanitary collection and treatment
service. In this situation, water is not purchased from the City but still requires treatment.
Therefore, a separate fee is applied to the volume of wastewater discharged to the sanitary
sewer for treatment.
There are two types of agreements: (i) long-term agreements, known as Sanitary Discharge
Agreements, which generally apply to site decontamination and decommissioning work and
(ii) “one-time” Short Term Permits, which apply to construction and excavation sites. The
wastewater quality received from the customers using private water supplies must meet the
Staff Report for action on Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report 9
sanitary Sewers By-law parameter limits. If not, the industry may also need to enter into an
IWSA, where applicable, or install a waste water pre-treatment system.
There were 50 new Sanitary Discharge Agreements and 85 Short Term Permits issued in
2014. There are two types of Short Term Permits depending where the discharge is directed -
storm sewer or sanitary sewer. The Short Term Permits to the sanitary sewer are issued with a
minimum discharge fee of $500, while the Short Term Permits to the storm sewer have
no associated discharge fee. The sanitary discharge fee is assessed to pay for treatment of
non-city supplied water. As of December 31, 2014 there were a total of 89 Sanitary Discharge
Agreements on file.
The Sanitary Discharge Agreements brought in revenues of $1.48 million and the revenue for
Short Term Permits was $468,000 in 2014. The total Sanitary Discharge revenues amounted
to $1.95 million in 2014 for Toronto Water.
4) Compliance Plan Agreements
The Sewers By-law has a provision that allows a company to enter into a formal Compliance
Plan Agreement with the City to provide a company additional time to obtain the necessary
equipment, or implement prevention measures, to remedy a Sewers By-law violation as soon
as possible. This enables the company to discharge to the City sanitary sewer under new
temporary higher parameter limits while taking the required corrective action, based on strict
conditions and timelines as defined in the agreement, to address and resolve the problem as
quickly as possible. Additionally, the company needs to perform weekly sampling and report
these sample results along with progress reports regularly to the City. Failure to comply with
any aspect of the Compliance Plan Agreement may result in termination of the agreement that
is signed by each party.
In 2014, there were 22 Compliance Plan Agreements issued, in comparison to 2012 and 2013
which had 65 and 43, respectively. Appendix D lists companies that entered into Compliance
Plan Agreements with Toronto Water and the parameters and activities they planned to
implement to meet the Sewers By-law limits. Improvements in the quality of the effluent are
accomplished through pollution prevention options or wastewater treatment systems or a
combination of the two. In 2014, 3 compliance plans used pollution prevention options, 17
plans used wastewater treatments systems, and 2 plans utilized both approaches. One
agreement was terminated in 2014 for failing to comply with the sampling and reporting
provisions or the compliance limit(s).
5) Grease Issues
Grease build up in the City sewers is an ongoing issue. Grease blockages can create potential
public health concerns by attracting rodents and may cause sewer back-ups. In an effort to
alleviate the problem a joint Toronto Water – Toronto Public Health pilot project was
established in 2008. Toronto Public Health checks for the presence or absence of grease
interceptors during restaurant inspections under the DineSafe Program. Restaurants without
grease interceptors, or those with a history of sewer backups are referred to Toronto Water for
a further detailed inspection and enforcement under the Sewers By-law.
Staff Report for action on Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report 10
In 2014, Toronto Water issued 63 Notices of Violations for the installation or maintenance of
grease interceptors compared to 172 in 2013 and 338 in 2012. This number has decreased as a
result of less referrals coming from Toronto Public Health as many restaurants have installed a
grease interceptor or addressed the maintenance issues. Restaurants that have not responded
to Notices of Violation are contacted for follow-up and additional enforcement tools, such as
an Order, are considered. There were no Orders for grease interceptor installation issued for
2014.
6) Spills & Complaint Response
Toronto Water Provincial Offences Officers are responsible for responding to spills or
pollution complaint calls requiring by-law enforcement 24 hours per day. This is achieved
through night and on-call weekend shifts via a rotating weekly schedule. Some examples of
complaints are a resident dumping paint into a street catch basin or reporting foam or
discoloured water in a creek. In 2014, staff received and attended to 572 pollution
complaints/spills; a significant increase from the 473 pollution complaints attended in 2013
and 344 attended in 2012.
The requirements for the discharge of residential swimming pool or hot tub water were
amended in the Sewers By-law in 2008 to prescribe procedures for discharge and discharge
limits specific to the residential sector. Provincial Offences Officers respond to swimming
pool complaints on a regular basis from spring to the fall season. In 2014, there were 49
swimming pool complaints in which Toronto Water responded. These are addressed as an
opportunity to educate the public on the Sewers By-law and the requirements for discharging
into the sewer system. If additional complaints for the same property or pool operator occur,
Toronto Water issues a Notice of Violation and/or takes enforcement action.
7) Industrial Water Rate - Block 2
The City offers a lower water rate to eligible industrial water customers, the Block 2 rate,
which is a discount of 30% from the Block 1 water rate. The eligibility criteria to receive the
Block 2 rate is set out in Municipal Code Chapter 849 – Water and Sewage Services and
Utility Bill (“Code Chapter 849”) and is based on the following factors:
an industrial property tax classification;
use of water exclusively for industrial or manufacturing processes;
consumption of water in excess of 6,000 m3 per year;
compliance with the Sewers By-law;
submission, approval and implementation of a Water Conservation Plan and related
progress report(s);
if required, the installation and maintenance of effluent monitoring equipment; and
additional criteria in the event only a portion of the property is assessed in the
industrial property tax class.
Failure by an industrial water customer to maintain eligibility, in accordance with the
Municipal Code requirements as mandated by Council, will result in the loss of the Block 2
rate depending on the circumstances. Toronto Water, however, takes a proactive approach to
encourage industrial water customers to remain in compliance with the eligibility
Staff Report for action on Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report 11
requirements. For example, Toronto Water staff often meet with industrial water customers to
discuss compliance programs and/or other solutions. Where appropriate, the General
Manager, Toronto Water will exercise his delegated authority under Code Chapter 849 to
resolve with a customer any non-compliance matter that affects the customer’s entitlement to
the Block 2 rate in order to rectify the non-compliance within 6 months. During such time, the
customer will be entitled to continue to receive the Block 2 rate.
However, if the non-compliance is not rectified to the General Manager’s satisfaction within
the prescribed time, the customer will lose the benefit of the Block 2 rate. Also, as mandated
by Council, if an industrial water customer has three instances of non-compliance within the
same billing year, that customer will lose the Block 2 rate until such time as the customer
demonstrates to the satisfaction of the General Manager, Toronto Water that the customer has
been in compliance for at least 12 consecutive months. If an industrial water customer loses
the Block 2 rate, Code Chapter 849 allows the customer to reapply for reinstatement of the
lower Block 2 rate.
At the end of 2014, 83 eligible industrial water customers were receiving the lower Block 2
Water Rate. A total of 9 industrial customers were impacted in some way through the loss of
the Block 2 Water Rate in 2014:
One industrial customer lost the Block 2 Water Rate as a result of receiving 3 Notices
of Violation in 2014;
Three industrial customers had received 3 Notices of Violation in a prior year and
continued to remain off the Block 2 Water Rate as they had yet to demonstrate 12
consecutive months of compliance, as per Municipal Code Chapter 849, based on the
City's sampling of the facilities; and
Five industrial customers were non-compliant with the Sewers Bylaw, due to a variety
of issues, and had temporarily lost their Block 2 Water Rate.
8) Liaison with other Divisions
There are over 3,000 licensed automotive garages in Toronto. Many of these are one person
operations with no designated environmental staff. In 2012, Toronto Water initiated a pilot
project with Municipal Licensing and Standards, as part of an Auditor General
Recommendation, to assist in automotive garage inspections.
Toronto Water developed an automotive inspection checklist referral form for Municipal
Licensing and Standards Officers to complete each time they visit an automotive garage for
clearance or investigation purposes. Completed checklists are sent to Toronto Water for
detailed inspection under the Sewers By-law. In November 2012, Municipal Licensing and
Standards Officers were trained by Toronto Water. In 2014, 105 automotive garage referrals
were received from Municipal Licensing and Standards Officers compared to 169 referrals in
2013.
Staff Report for action on Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report 12
9) Pollution Prevention (P2) Plan Program
Toronto Water requires Pollution Prevention Plans to be submitted every six years by any
business that discharges any amount of the 39 subject pollutants, and an update every third
year, per Council Direction, starting in 2014. Certain commercial operations are required to
follow Best Management Practices, which provide a number of “do’s and don’ts” designed to
improve effluent quality of that particular commercial operation. Best Management Practices,
when followed, minimizes the release of pollutants to the sewer system.
The Best Management Practices approach has proven to be more effective for smaller
businesses, rather than submitting Pollution Prevention Plans. Businesses that fall under Best
Management Practices include: photofinishing, automotive repairs, gas stations and vehicle
wash facilities. Each of these facilities must submit a declaration form that outlines their
processes, including confirmation on the use of a waste hauler and commitment to follow Best
Management Practices. Approximately 6,000 facilities fall under the Pollution Prevention
Program.
In 2014, 618 Pollution Prevention Plans and Best Management Practices forms were
reviewed. Failure to submit a Pollution Prevention Plan may result in the issuance of a Notice
of Violation. There were 110 Notices of Violation issued for Pollution Prevention Plan
submission requirements in 2014. A Pollution Prevention Plan submitted that does not meet
the by-law requirements is rejected and the company is requested to re-submit a revised
Pollution Prevention Plan.
In 2014, the Dental Association and Toronto Water worked together to remind its members of
the requirement to submit a Pollution Prevention Plan. This resulted in 374 new dental
Pollution Prevention Plan submissions and an increase in compliance rate for the dental sector.
The commercial sectors are usually not notified by Toronto Water when a new plan is required
due to limited resources and there is a corresponding lower percentage compliance rate.
Table 4 highlights the 2014 statistics with respect to the percentage of Pollution Prevention
Plan submissions received by Toronto Water. A new Pollution Prevention Plan submission
cycle for many businesses began in 2013 and 2014: thus, the compliance rate is generally
lower in these two years than the previous years as the sector companies either forget to
submit their Pollution Prevention Plans (for the next six year cycle) or have a late submission
such as the dry cleaners, dental offices and autobody refinishing sector etc.
In December of 2014, Toronto Water began issuing Notices of Violation to industrial
companies who have not met the submission requirement. The remaining non-compliant
companies will be issued a Notice of Violation in 2015.
Staff Report for action on Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report 13
Table 4: Pollution Prevention - Statistics Related to Reporting
Pollution Prevention Plans and Best Management Practices: Submission Reporting Statistics – as of December 31, 2014
Organization Type Total Number of
Facilities
Pollution Prevention & Best Management Practice Compliance Rate
2014 2013 2012
Autobody Refinishing 436 31% 25% 72%
Automotive Services 2616 59% 58% 56%
Dental Offices 1544 65% 23% 82%
Photo Labs 214 69% 69% 69%
Metal Finishing 98 79% 88% 93%
Printing 327 54% 51% 71%
Non-Sector* 46 88% 83% 88%
Manufacturing 192 78% 89% 90%
Dry Cleaners & Commercial Laundry
312 47% 35% 100%
Textile and Industrial Laundry
40 75% 70% 93%
Hospital/Health Care 36 64% 65% 86%
Total 5886
* Refers to any industry that is not listed as a subject sector in Appendix 1, Sewers By-law.
10) Storm Sewer Outfall Monitoring Program
Toronto Water continues to operate the Outfall Monitoring Program with success. Toronto
Water achieved its goal of surveying and sampling all outfalls that have a dry weather flow
within Toronto's watersheds. The program is also responsible for investigating and rectifying
any contaminated flows by enforcing the Sewers By-law. Table 5 compares key performance
indicators for the Outfall Monitoring Program for the last three years.
Staff Report for action on Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report 14
Table 5: Comparison of Cross Connections Found and Corrected, Priority Outfalls, Outfalls of Concern and De-listed Priority Outfalls during 2012, 2013 and 2014.
Year 2014 2013 2012
Precipitation (mm) 734 1019 822
Cross Connections Found 50 11 83
Cross Connections Corrected 16 25 62
Total Priority Outfalls 65 86 100
Outfalls of Concern 50 4 3
Delisted Priority Outfalls 28 15 12
Numerous Priority Outfall investigations were conducted along the storm sewer system
searching for sources of contamination. The Environmental Monitoring & Protection Unit's,
Stormwater Group found 50 cross connections by performing 210 dye tests and also verified
the correction of 16 cross connections. Of the 50 cross connections found, 35 were residential,
7 were commercial and 8 were industrial facilities. Of the 16 cross connections corrected, 8
were residential, 4 were commercial and 4 were industrial facilities (Refer to Appendix E-
Table 1).
Closed Circuit Television (CCTV) continues to be an invaluable tool in detecting cross
connections and infrastructure issues along the sewer system. Of the 50 cross connections
found, 18 were flagged using the help of CCTV. By using CCTV, fewer resources were
needed to narrow down the problem quickly. Normally staff would trace the contaminated
flow to a source by sampling along the storm sewer system at manholes.
As a result of eliminating these sources of contamination, 28 priority outfalls were delisted
from the Priority Outfall List. This was verified by monitoring and sampling the priority
outfalls until they showed improvements in water quality. Refer to Appendix E-Table 2 for a
list of de-listed priority outfalls in 2014 along with their corresponding watersheds and
respective wards. As of December 31, 2014, the Priority Outfall List consists of 65 priority
outfalls. Appendix E-Table 3 provides a summary of priority outfalls, outfalls of concern and
delisted outfalls for 2013 and 2014.
Staff also completed two rounds of Don River outfall sampling for the outfalls with dry
weather flow. Seven Don River outfalls were classified as priority outfalls and were added to
the Priority Outfall List. They showed signs of contamination and were flagged for active
investigation. Outfalls of concern are outfalls that have not been classified due to insufficient
data but have shown signs of contamination.
Additional sources of contamination such as combined sewer overflow spillovers and spills to
the sewer system were also remedied. For enforcement purposes, 32 Notices of Violation were
issued for Sewers By-law infractions related to the Outfall Monitoring Program. Of these
issued Notices of Violation, 17 were residential, 7 were commercial and 8 were industrial
facilities. Table 6, below, provides a summary of storm water related tasks (2012-2014).
Staff Report for action on Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report 15
Table 6: Summary of Storm Water Related Tasks for 2012, 2013 and 2014
Storm Water Related Tasks 2014 2013 2012
Inspections 3,840 2,310 2,447
Sampling Events 2,035 1,032 735
Laboratory Analyses 16,385 10,794 9,624
Notices of Violation Issued 32 9 52
So far, staff working on the Outfall Monitoring Program have found a total of 695 cross
connections and facilitated the correction of 633 cross connections. Fixing these problems has
contributed to the removal of 113 priority outfalls from the Priority Outfall List and from
active investigation. The Outfall Monitoring Program continues to be proactive in improving
storm water quality in the storm sewer system. As a result, less pollution is entering the City
of Toronto's surface waters and the natural environment.
11) Water Supply By-law Backflow Prevention Program
Toronto Water's Environmental Monitoring & Protection Unit administered the Backflow
Prevention Program since its 2008 inception until December 31, 2013. It continues to conduct
inspections of industrial, commercial and institutional properties to ensure compliance with
the Water Supply By-Law. Table 7, below, highlights the number of compliance and
enforcement activities undertaken by Toronto Water staff in 2014 for the Water Supply By-
law compared to 2012 and 2013.
Table 7: Water Supply By-law Compliance and Enforcement Activities 2012 to 2014
Activity 2014 2013 2012
Inspections 754 695 734
Notice of Violations for Backflow Prevention (BF) Device Installation
1,638 585 1,374
Notice of Violations for BF device Installation Correction
138 41 56
Notice of Violations for wrong BF device 0 6 32
Reminder Notices for BF Test Report 3,869 2,311 4,345
BFP Test Reports Received 6,255 5,924 6,224
Notice of Violations for Rejected Test Report 114 112 51
Complaints 9 10 2
Investigations 6 1 3
Prosecutions 5 1 3
Convictions 2 1 3
Unsuccessful Prosecutions 0 0 0
Withdrawn Prosecutions where charges laid 0 0 0
Fines (excluding 25% victim surcharge fee) $2,250 $500 $1,750
Staff Report for action on Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report 16
Fire Hydrant Obstruction:
Fire Hydrants cannot be obstructed according to the Water Supply By-law. Toronto Water's
District Operations staff performs regular scheduled inspections and maintenance of hydrants.
If fire hydrants are found to be obstructed, during a routine inspection, then staff addresses the
issue by immediately notifying the homeowner, by written notice, to have the obstructing
material removed.
District Operations staff re-visit the site shortly thereafter to see if the obstruction has been
cleared as per the notice. If not, a second notice is given and again a second re-visit to the site
occurs. If the obstruction has still not been removed, the issue is escalated with a referral to the
Environmental Monitoring & Protection Unit for enforcement.
In 2014, the Environmental Monitoring & Protection Unit did not issue any orders for hydrant
obstruction.
12) Collaborative Surface Water Monitoring Programs
Toronto Water continues its engagement in coordinating the Beaches Monitoring Program
along with Toronto Public Health and Toronto Police Services through the use of seasonal
beach lifeguards. Certain bacteria, more specifically E. coli, can cause people to become sick.
Water quality along the beaches is monitored by testing for E. coli during the beach season.
Lifeguards collect the beach water samples, while Toronto Water handles the sample delivery
and weekend testing.
The Ministry of Health and Long-Term Care contributes with weekday/holiday testing.
Toronto Public Health determines whether a beach should be open or closed by reviewing the
test results. Staff collected a total of 5,973 beach water samples along all of Toronto's 11
beaches from late May to Labour Day 2014. It should be noted that 8 of Toronto's beaches
have received an internationally recognized Blue Flag designation for meeting strict water
quality criteria.
Toronto Water continued to assist Transportation Services with the Ministry component of the
Federal Government mandated Salt Management Plan. Road Salt concentrations are
monitored year round at various monitoring stations in the Highland Creek watershed. The
purpose is to determine how much chloride is entering the City's waterways from road salting
operators in order to meet Environment Canada's Salt Management Plan requirements.
13) 2014 Pollution Prevention (P2)/Sewers Use By-law Stakeholder Consultations
In December 2013, City Council directed Toronto Water staff to undertake consultations in
2014 regarding five proposed changes to the Pollution Prevention (P2) Program, which is part
Staff Report for action on Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report 18
ATTACHMENTS
Appendix A: Sewers By-law Violations in 2014
Appendix B: 2014 Sewers and Water Supply By-law Convictions
Appendix C (a): Organizations invoiced for Industrial Waste Surcharge Agreements or
Permits, as of December 31, 2014
Appendix C (b): Organizations invoiced for Industrial Waste Surcharge Permits, as of
December 31, 2014 (Billed Minimum Surcharge Fee $500.00/year)
Appendix D: List of Facilities with a Compliance Program in 2014 Appendix E: Outfall Monitoring Program Summary
Staff Report for action on Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report 19
Appendix A: Sewers By-law Violations in 2014 by Category Note: The number in the brackets represent the number of violations. There may be multiple violations within 1 issued Notice of Violation.
Staff Report for action on Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report 20
Appendix B: Table 1: 2014 Sewers and Water Supply By-law Convictions
Conviction Date
Company Ward No. of
Violations charged*
Conviction Fines (excluding
25% Victim Surcharge)
Positive Outcome of Prosecution File
Feb 18, 2014
59 Project Management Inc.
30 1 Sanitary: Total Suspended Solids
$1,500.00
Company applied and received a discharge permit and then requested a Sanitary Discharge Agreement (SDA) for a longer term of over a year.
$8,000.00 Company installed zinc treatment, an ultra filtration system and an air stripper.
Feb 24, 2014
KIK Operating Partnership – 2000
Kipling Avenue 2 2
Sanitary: Benzene Oil & Grease (mineral)
$4,000.00 Company installed zinc treatment, an ultra filtration system and an air stripper.
Feb 26, 2014
Elbee Meat Packers Limited
11 5
Sanitary: Oil & Grease (3) pH (2)
$17,500.00 The company has a history of Sewers By-Law non-compliance and is currently before the courts.
Mar 5, 2014 2259671 Ontario
Inc. (Victory Laundry)
37 2
Sanitary; Oil & Grease (non-mineral) Chloroform
$4,000.00 Company modified wash practise to minimize washing linens soiled with Oil & Grease.
Mar 17, 2014
MTCC 786 2 2
Sanitary; Chloroform Oil & Grease (non-mineral)
$5,000.00 The laundry business moved out of the plaza and the issues have been resolved.
Staff Report for action on Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report 21
Conviction Date
Company Ward No. of
Violations charged*
Conviction Fines (excluding
25% Victim Surcharge)
Positive Outcome of Prosecution File
Apr 14, 2014
Metrolinx (GO Transit - Willowbrook
Facility)
6 1
Sanitary: Biochemical Oxygen Demand (BOD)
$1,500.00 Company entered into an Industrial Waste Surcharge Agreement.
Apr 16, 2014
Atlantic Packaging Products Ltd.
(Color Pak – 80 Progress Avenue)
37 1
Sanitary: Failed to submit spill report in 5 days
$2,000.00 Company submitted a spill report to the City.
Apr 29, 2014
City Linen Inc. 37 1 Sanitary: Chloroform
$500.00 Company closed.
May 14, 2014
Brimac Anodizing (1985) Limited
6 4
Sanitary: Copper Aluminum pH, Discharge to sanitary sewer without permit
$15,000.00
The company installed an oil skimming mechanism and a fully automated pH adjustment to address their effluent. The company entered into a Sanitary Discharge Agreement.
Company was bought out by another company which took immediate action to achieve compliance by purchasing and installing a Dissolve Air Floatation (DAF) system.
Staff Report for action on Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report 22
Conviction Date
Company Ward No. of
Violations charged*
Conviction Fines (excluding
25% Victim Surcharge)
Positive Outcome of Prosecution File
May 20, 2014**
2180137 Ontario Inc. (The Cleaning
Company)
Mark-ham
1
Water Supply : Taking water from a hydrant without a permit
$1,500.00 The company is aware that a permit is required to take water from the City fire hydrant.
May 26, 2014
2209008 Ontario Limited (Asian
Buffet) 2
3
Sanitary: Total Suspended Solids (TSS) Biochemical Oxygen Demand (BOD) Chloroform
$1,500.00
The company entered into Industrial Waste Surcharge Agreement. The company opted for product substitution and eliminated bleach use.
June 2, 2014
59 Project Management
30 1 Discharge to Sanitary sewer without permit
$2,000.00 Company entered into a Sanitary Discharge Agreement.
June 16, 2014
Metro Pool Services Limited
2 4
Sanitary: Chloroform Zinc Total Suspended Solids (TSS) Fail to contain Spill
$7,000.00
Company re-trained staff and now follow the Best Management Practise set out by the City for Residential Swimming Pools and Hot Tubs.
June 17, 2014
DMX Plastics Limited
2 4
Sanitary: Oil & Grease (mineral & non-mineral) Zinc Fail to notify a spill
$6,000.00 Company relocated outside of Toronto.
July 31, 2014
Castleton Homes Ltd.
25 1 Sanitary: Total Suspended Solids
$5,000.00 Company closed.
Staff Report for action on Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report 23
Conviction Date
Company Ward No. of
Violations charged*
Conviction Fines (excluding
25% Victim Surcharge)
Positive Outcome of Prosecution File
Aug 13, 2014
Superior Pool, Spa & Leisure Ltd.
8 6
Sanitary: Copper Zinc Biochemical Oxygen Demand (BOD) Total Suspended Solids (TSS) Lead (Pb) Fail to submit spill report
$17,500.00
Company continues to violate Sewers By Law. Company currently faces charges before the court.
Oct. 27, 2014**
Concord Mobile Wash Ltd.
Concord 1
Water Supply: Obtain water from a fire hydrant without a permit
$750.00
The company is aware that fire hydrant water use is authorized only by Toronto Water General Manager.
Dec. 1, 2014
1044589 Ontario Inc. (Nantucket
Business Centre) 37 1
Sanitary: Failed to maintain access to maintenance access hole.
$1,250.00 Company fulfilled obligation related to a property manhole.
Dec 3, 2014 Kenaidan
Contracting Ltd. 15 1
Sanitary: Discharge non city purchased water into sanitary/combined sewer without a permit.
$12,500.00 Company applied and received a Sanitary (Private Water) Discharge Permit.
Dec 3, 2014 Nino D'Aversa Bakery Limited
8 2
Sanitary: Oil & Grease (non-mineral) (2)
$2,500.00
Company installed additional grease interceptors.
Staff Report for action on Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report 24
Conviction Date
Company Ward No. of
Violations charged*
Conviction Fines (excluding
25% Victim Surcharge)
Positive Outcome of Prosecution File
Dec 9, 2014 Blue Bell
Electroplating Inc. 37 1
Sanitary: Zinc
$2,500.00 Company resolved non-compliance of zinc.
All By-laws
Total $137,000.00
Sewers By-Law Total
Total
$134,750.00
Water Supply By-Law
Total $2,250.00
*The number of violations charged may not reflect the number of convictions as some violations that were charged may have been given a suspended sentence or negotiated to reach a settlement for a conviction. **Shaded row refers to a conviction under the Water Supply By-Law.
Staff Report for action on Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report 25
Appendix C:
a) Organizations invoiced for Industrial Waste Surcharge Agreements, as of December 31, 2014
315 Santa Maria Foods Corporation 353 Humberline Drive 1
Terminated (September 24, 2014) Moved to Limits
316 Shelmac Brand Products Inc. 1289 Caledonia Road 15
Terminated (September 24, 2014) Moved to Limits
317 Via Rail Canada Inc. 50 Drummond Street 6
Terminated (September 24, 2014) Moved to Limits
318 York Condominium Corporation No. 485 30 Titan Road 5
Terminated (September 24, 2014) Moved to Limits
319 Target Canada Co. 3003 Danforth Avenue 32
One Time Discharge – Terminated (December 31, 2014)
320 Target Canada Co. 45 Overlea Boulevard 26
One Time Discharge – Terminated (December 31, 2014)
321 Tervita Corporation 158 Sterling Road 18
One Time Discharge – Terminated (December 30, 2014)
322 Fybon Industries Limited 202 Fairbank Avenue 15 On Hold for 2014
323 Larry Linen Rental Ltd. 91 Penn Drive 7 On Hold for 2014
Staff Report for action on Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report 39
Appendix D: List of Facilities with a Compliance Program in 2014 WWT = Wastewater Treatment installed; P2 = Pollution Prevention ** = Included in 2013 Annual Report. Compliance Agreement carried over into 2014 Terminated/Rejected.
Installed wastewater management system and conducted operator training.
October to November 2013 lab results indicated one Oil & Grease higher than compliance limit. November to December 2013 lab results indicated one zinc higher than compliance limit. Delays for installation of treatment system, re-applied for compliance program. (WWT)
In the process of expanding pond to direct run-off towards newly expanded pond, as well as installing new storm catch basins and filtration system on the property.
Ongoing (WWT)
Staff Report for action on Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report 40
Industry Name
Address
Ward
Compliance Plan Agreement
Comments Program Date Parameters
Limit Activities
Start End mg/L
Campbell Company of Canada
60 Birmingham Street
6 Dec 1, 2014
Mar 31, 2015
Oil & Grease – animal/veg pH
500 5 – 12.5 SU
In the process of doing a wastewater characterization to determine treatment options for their waste effluent.
Installed a Dissolved Air Floatation (DAF) system to treat their wastewater effluent.
Compliance agreement terminated on October 3, 2014 for failing to submit required reports to the City. DAF has been installed. (WWT)
Crown Metal Packaging Canada LP
21 Fenmar Drive
7 Oct 31, 2014
Mar 15, 2015
Oil & Grease – mineral 35 In the process of installing 3 oil skimmers on the production line as well as installing an oil coalescer and electrocoagulation polishing system on to the existing wastewater system.
Oil skimmers have been installed, currently waiting to install rest of treatment system. Ongoing (WWT)
G & K Services Canada Inc.
940 Warden Avenue
37 Nov 18, 2013
Jul 11, 2014
Toluene
1 Evaluated Bio-Reactor system and re-evaluated the use of ozone to treat effluent D4-1.
Bio-reactor not viable and currently testing use of ozone to treat effluent. Will be moving forward with installation of an air stripper. (WWT)
Staff Report for action on Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report 41
Industry Name
Address
Ward
Compliance Plan Agreement
Comments Program Date Parameters
Limit Activities
Start End mg/L
G & K Services Canada Inc.
940 Warden Avenue
37 Dec 29, 2014
May 1, 2015
Toluene 0.5 In the process of installing an air stripper at the end of the waste water treatment system.
Installed a Dissolved Air Floatation (DAF) system to treat their effluent.
DAF installed. (WWT)
Imperial Oil Ltd.
1150 Finch Avenue West
8 Oct 1, 2013
Dec 31, 2014
Manganese Zinc
2 0.2
Detailed cleaning and repair plan of the storm sewer and performed sewer integrity repairs and subsequent sewer system/catch basin cleaning.
Samples have high Manganese and Zinc due to high total suspended solids and sampling location. Will sample at same location as Toronto Water in future. Ongoing (P2)
Installed and commissioned new fiber processing equipment.
New disc filter equipment installed. Successful in reducing TSS with equipment. (WWT)
Knoll North America Corporation
1000 Arrow Road
7 May 1, 2014
Aug 30, 2014
Toluene 0.05 Installed air stripper to remove volatile organic compounds (VOC's) from waste effluent.
Air stripper installed and functioning. Sample results are below the Sewers By-Law limit. (WWT)
Staff Report for action on Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report 42
Industry Name
Address
Ward
Compliance Plan Agreement
Comments Program Date Parameters
Limit Activities
Start End mg/L
Newalta Corporation
55 Vulcan Street
2 Jan 1, 2014
Mar 31, 2014
Oil & Grease - mineral Nonylphenols (NP) Nonylphenol Ethoxylates (NPE)
100 1 10
Completed an acid split to remove mineral oil from the effluent and identified generators of NP/NPE and worked with companies to transition to alternative soaps and degreasers that contain no or reduced NP/NPE.
Company identified sources of NP/NPE's in their waste stream and are no longer accepting those companies waste. Still working on method to extract all mineral oil from their effluent. (P2 & WWT)
Toronto Abattoirs Limited
2 Tecumseth Street
19 Dec 23, 2013
Apr 30, 2014
Oil & Grease – animal/veg
500 Company inspected the sewer from the DAF (dissolved air floatation) unit to the manhole and power washed and vacuumed the sewer. Tested and evaluated two treatment systems.
Company filed for creditor protection April 3, 2014 and on May 6, 2014 the company filed for bankruptcy. (WWT)
Installed screening system and trained operators. Assessed and implemented Oil and Grease treatment system.
Sample results were below compliance limit except for one Oil and Grease, which they acted upon quickly. Compliance plan terminated on March 21, 2014 for exceeding limit for Oil & Grease (animal/veg). (WWT)
Staff Report for action on Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report 43
Industry Name
Address
Ward
Compliance Plan Agreement
Comments Program Date Parameters
Limit Activities
Start End mg/L
Nitta Gelatin Canada Inc. **
90 Paton Road
18 Dec 9, 2013
Feb 15, 2014
Oil & Grease – animal/veg
250 Replaced flocculant pump, verified performance of chemical treatment program for fats, oils and grease (FOG) removal and installed Webmaster control, chemical feed algorithms and new pH probes to improve performance.
Report and sample data submitted late and showed samples above compliance limit. FOG removal evaluation to be performed by end of March 2014. Block 2 rate removed from company until Mar 4/14 due to late reports. Fulfilled compliance activities. (WWT)
Conducted wastewater characterization, evaluated cleaning chemical usage, tested alternative cleaning chemicals, improved housekeeping procedures and trained staff on procedures. Inspected floor/sink drains, replaced missing strainers and included procedure in preventive maintenance protocol.
Terminated Nov. 2013. The October Oil and grease (mineral) samples over the compliance limits. (P2)
Added equipment to enhance current treatment system (two 5000 gallons retention tanks, drum screening device for solids removal and coalescing type separator for oil removal) and improved Programmable Logic Controller (PLC) codes to increase the efficiency and
Submitted application for extension. Extension granted to the end of September 2014. Equipment has been purchased and installed. Company is in testing phase. (WWT)
Staff Report for action on Sewers and Water Supply By-laws 2014 Compliance and Enforcement Annual Report 44
Improving Waste Water Treatment System (WWTS) and Identifying manufacturing process control measures to enable synchrony of all operations with WWTS; Mechanical Process Control for processing operations.
Company has implemented a series of process changes with the waste water treatment system to control discharge of effluent. Sample results have shown 2 exceedances of compliance limits. Ongoing (WWT)
Winsun Laundry & Linen Supply Ltd. **
689 Warden Avenue
35 Dec 9, 2013
Feb 14, 2014
Chloroform 0.5 Introduced chloroform scavenger product to the washing cycle.
Trial of scavenger product did not produce the results they anticipated, however, did achieve good results with hydrogen peroxide. (P2)
1 Of the total cross connections found, 35 were residential, 7 were commercial and 8 were industrial. 2 Of the total cross connection corrected, 8 were residential, 4 were commercial and 4 were industrial.
Table 2: Priority Outfalls removed / de-listed from the Priority Outfall List in 2014
Outfall ID Watershed Ward
DR289 Don River 8
DR396 Don River 34
HC19 Highland Creek 44
HC23 Highland Creek 44
HC50 Highland Creek 44
HC61 Highland Creek 43
HCW215 Highland Creek 40
HCW219 Highland Creek 40
HR102 Humber River 4
HR103 Humber River 4
HR337 Humber River 1
LO04 Lake Ontario 6
LO07 Lake Ontario 6
LO14 Lake Ontario 6
LO129-1 Lake Ontario 44
MC27 Mimico Creek 5
MC105 Mimico Creek 4
TC20 Taylor Massey Creek 31
46
Outfall ID Watershed Ward
TC24 Taylor Massey Creek 31
TC40 Taylor Massey Creek 35
TC41 Taylor Massey Creek 35
TC53 Taylor Massey Creek 35
TC71 Taylor Massey Creek 35
TC72 Taylor Massey Creek 35
TC78 Taylor Massey Creek 35
TC79-1 Taylor Massey Creek 35
TC107 Taylor Massey Creek 37
TC112 Taylor Massey Creek 40
Table 3: Comparison of Priority Outfalls and De-listed Outfalls in 2013 and 2014.