Id 1 <1 compla i ke To regisfer TABLE OF CONTENTS -1. DefiningaComplaint . . . . . 2. Emergency Responses (During Regular Work Hours) 0 Field Response to Fuel Spills Follow-up to an Emergency'Response Incident 3. Emergency Response Program . . . . 0 BR Incidents . . . . . . 4. Program Definitions . . - Air Quality Program . 0 Waste Management Program . . 0 Water Management Program . . . . In Water Supply Management Program" . . . 0 Environmental Cleanup Program . . 0 Soil and Waterways . . . . 5. Complaint Procedures 0 Related Complaints . . . . 0 Delegated Counties . . . . . 6. Priority Levels . . . 7. . Defining a Quality 'Response 8. Oil Gas Regulated Complaints . . 9. Non-Regulated Complaints 10. Efacts Guidance . . . . . . . 11. Complaint Flow Chart . . . 12. Complaint Form (Sample) 0 Explanation of Fields . 13. Reports . . . 0 Joint Inspection Report - Log Report . . - . . . . 0 Managers Report . . - . . I OverduefUnresolved Complaints Report . . 0 Response Performance Report . . 0 Statistical Report . . . . 9 Summary Report . . . . 9 Supervisors Summary Report. 14. New Inspector Instructions 15. Complaint Tracking System Screens 19-20 . 21-22 22-23 . 23-24 . 24-25 O3 UK - I--26-31 DEFINING A COMPLAINT A complaint is a formal allegation against a person, company or party requesting an investigation by the Department claiming that an environmental law may have been broken or there is a risk of environmental harm. Complaints are submitted by telephone, letters, e-mail, DEP Web Page, legislative inquiries, referrals from other agencies, DEP employees, etc. \Vhen you receive a complaint and you are unsure Whether the incident is an emergency that is to be responded to by Emergency Response or by a Program, you can contact the Emergency Response Progam Manager, Assistant Emergency Response Program Manager or the Service Representative to make the determination. EMERGENCY RESPONSES (During Regular Working Hours 8:00 -- 4:00): When an emergency is received during regular working hours, it is to be handled through the Service Representative. Any chemical or unknown spills or drums with unknown contents are to be referred to the Emergency Response Program. Obtain as much information as possible from the caller. Most of the time the incident is being reported by County 911's or County EMA's and you are provided with limited information- Before you hang--up with them try to get a contact name and cell phone number from the person in-charge of scene (if they don't have it they will usually call you back with it). You may have to contact the person in-charge of scene to obtain most of the infomiation. 1. Time incident was reported to Department 2. Location such as address, roadway and mile marker 3. Contact person or person in--charge at scene (like fire chief or state police) 4. Contact persons cell phone number 5. Time incident occurred 6. Amount of spill (if it is a liquid) 7. What type of fluid is down and is it contained 8. Is it in a Water course (get name if possible), storm drain, soil or pavement 9. Responsible Party Name, Address, Telephone Number and Contact Person 10. Askif a contractor has been notified to conduct cleanup, if not you may tell them that one may be required to clean up site. (We do have a list of Clean-up Contractors/Consultants if they are not aware of any and you can provide them with names and phone numbers). ,1 1. If so, get name, telephone number and ask if they are en--route to scene 12. Ask if they are requesting DEP Response to scene Once you have obtained the information, you are -to" relay it to the appropriate Program Supervisor or Field Inspector as soon as possible. Do not leave a message on anyone' 5 voice mail or cell phone . voice mail. You must speak with someone. NOTE: When spills are reported to the Department it does not necessarily mean there will always be a field response. In some cases, it depends on the amount of the spill andfor the type of surface affected as to whether a response is required. See instructions below. In addition, some calls are reported because it is a requirement and is considered a "Notification of a Spill" which, would then just go tothe appropriate program as a FYI. Field Response to Fuel Spills: If a fuel spill occurs and it does not require a field investigation per the appropriate supervisor, then it will be entered into CTS with the following procedures. (Only spills larger than 10 gallons, unless a waterway or storm drain has been impacted). I Investigation Information: The outcome of the investigation will determine the procedure you Document the same information as a routine complaint; caller, responsible party (trucking company), county, municipality and location. - Document the time Department received call andfor when it occurred. Document if the spill has been contained. Indicate whether a waterway or storm drain has been impacted. Document who will be conducting the cleanup. Fire department, facility and/or if a cleanup company has or needs to be contacted) If a contractor has been hired or needs to be, obtain contact name, phone number, company name and address. Find out when the cleanup will occur. Assign to the Service Representative. Assign to the appropriate supervisor for that field area. It will be assigned a: 0 Priority 1 -- If the cleanup has been completed within the same day and no reports are required. 0 Priority 2 Ifthe cleanup will be completed within 10 working days and no reports are required. Priority 3 - If the cleanup will require a Final Closure Report to be submitted. will follow in order to properly handle and close out the complaint. Priori1_:y 1 Assigged: Enter in Date First Response (Date action was taken) and Date Resolved (date cleanup completed, which should be the same date as Date of First Response). For Inspection Type field use "Other" and for Inspector use unless otherwise noted. In the Investigation Description, document the details of the spill and the details pertaining to the actiontaken regarding the cleanup. - Prioritv 2 Assigned: Enter in Date First. Response (Date action was taken) and Date Resolved (this will be the date the cleanup has been completed); For Inspection Type field use "Other" and for Inspector use unless otherwise noted. In the Investigation Description, document the details of the spill and the details pertaining to the action taken regarding the cleanup. Priorig 3 Assigged: Enter in Date First Response (Date action was taken) and Date Resolved (date closure report has been received by the Department). For Inspection Type field use "Other" and for Inspector use unless otherwise noted. In the Investigation Description, document the details of the spill and the details pertaining to the action taken regarding the cleanup. NOTE: Send a copy of Detail Form to assigned supervisor, hold the Detail Form until the Final Closure Report is received, update CTS, attach Final Closure Report to Detail Form and send to file. Follow-up to an Emergency Response Incident: When ER responds to an incident and it's sent to a prograrn(s) for follow up, then the follow procedures will be followed. Emergency Response will enter the incident into CTS, print out Detail Form with their investigation information and forward it to the appropriate progran1(s) for follow up. The appropriate Supervisor will determine whether a field response is required. Field Response Required: Document "No Further Action Required" on the Detail Form, send to SR and it will be entered into CTS. 0 Send the completed Detail Form to the SR for closing it out in CTS (Resolution Date). 0 If no further action is required other than receipt of the final closure report, indicate "No "Further Action Required, Hold for Final Closure Report" on Detail Form and send to SR. SR will hold until report is received and close out complaint in CTS. Field Response Required: a site visit is required, then the SR will re-assign the incident to the appropriate program(s), inspector and supervisor. - "o After your site visit, complete the remaining information on the Detail Form Date First Response and the Investigation Information portion of Detail orrn) just as you would for a routine complaint. . - 0 Send the completed Detail Form to the SR to update into CTS. If no further action is required other.than receipt of the final closure report, then indicate "No Further Action Required, Hold for Final Closure Report" on the Detail Form. SR will hold until final closure report is received,'wi1l update CTS, attach Final Closure Report to Detail Fonn and then send to file. ENIERGEN CY RESPONSE PROGRAM: If the call is deemed an "Emergency", forward it to an Emergency Response Personnel following the . Any spill occurring after regular work hours; 4:00 pm or an excessive amount; 1,000 gallons. Indoor air problems; chemical and! or malodors involving petroleum products. Anything needing an immediate response that a program and/or programs can't provide. chain of command: (Reception area will have who is available for ER) 1. Emergency Response Program Manager 2. Assistant Emergency Response Program Manager 3. Designated employee in-charge of Emergency Response ER Incidents: 1. If the call is determined to be an Emergency Response, it will be registered in the CTS by the Emergency Response Program. 2. If a complaint is received after hours by ER and it is not investigated but requires an investigation by a program, then this is to be logged into CTS by S.R.. Any reports received by ER after hours that the Department does not regulate are the responsibility of ER to inform the caller, refer the incident, etc. It is not the responsibility of the S.R. to make the referral. - PROGRAM DEFINITIONS The following is a general breakdown of what type of complaints each program handles. Management decided what program would handle those types of complaints that would technically fall under two programs. It was based on what program had the more appropriate rule or regulation. Ifthe complaint is difficult to determine what program it should be assiged to, contact a Program Supervisor or Compliance Monitoring Manager and they will be make that determination. Some complaints will result in the assigning of more than one program due to the nature of the problen1(s). Joint investigations should be arranged between the programs at that time. Air Quality Prograxn: Ogen Burning any waste other than residential garbage or any -waste fiom a business that was produced on site. Asbestos removal or demolition from a business or dwelling with five or more apartments or visible asbestos emissions. Dust sandblasting, stone quarry roads, dirt roads or trucks tracking dirt onto a road iiom a business. Fugitive Emissions -- smoke or dust leaking fiorn a process other than a stack or quarry operation. Emissions from "Outdoor Wood Burning Units" that are' affecting a resident. First, point_ of contact is with local government if they have an ordinance in place. Odor any malodor fiom a business but not including odors generated and detected W/in the same building. (Landfills are first covered by Waste Management Sewage Treatment Plants are first covered by Water Quality) . Stack Emissions anyair emissions fi'orn a business such as heavy smoke, soot or particulate matter from a stack or duct. Vapor Recove;p-- from filling of gasoline storage tanks excluding dispensing fuel to a motor vehicle. "Idling of Diesel-Powered Motor Vehicles" for longer than 5 minutes and proper signage is required (see exemptions). Act I 24 Anti-idling Law pertains to diesel--powered motor vehicles with a gross weight of 10,001 or more causing odors or idling for longer than 5 minutes (see exemptions). Outdoor Wood Boiler -- any odors produced by these from a residential or commercial property. - Schools -- odor problem occurring within a school that is not the result of heating system. General -- an issue that may not fall under any of the above. Waste Management Program: Burning -- any waste that is brought from one location to another and burned or any waste that is not normal household generated waste. Disgosa -- municipal waste, residual/industrial, tires and/or infectious Waste that is not properly bagged/contained, and commercial, demolition, hazardous, infectious and sludge--type wastes must be brought to an approved site for that waste type. Dumging/Bufling -- any waste other than clean fill that has been deposited on the surface of the ground or buried in the ground or dumped into a waterway or water body. (Clean fill; trees, grass, stumps and vegetative material fiom same property, ashes, brick, block, concrete, rock stone and used asphalt) Landfill -- odors, litter, tracking of mud on roadways, dust and operational hours or accepting unapproved Waste. Stomg -- hazardous waste stored in drums must be properly marked and labeled, and tires must be stacked and stored properly. - Transgortation -- waste transferred fi'orn one place to another and placed on the ground without being contained. The vehicle hauling waste must be properly labeled. Odors/leakage -- nuisances and must be enclosed/tarped from Vehicle transporting waste. Vehicles not licensed to haul hazardous waste. Waste hauling vehicles parked in residential areas causing a nuisance and/or parked for more than 4 hours. Contaminated soil fiom tank removals transferred to another location/ site. Water Management Program: Agyg' ultm-e manure improperly stored near a body of Water or water supply from a farming operation. Biosalids sewage/septage problems resulting in nuisances, no prior notification or no permit for land application. . Industrial Waste chemical discharge to a body of water. On-lot Sewage -- NOT refer caller to local municipality, if they indicate that they have and nothing is being done, then refer them to Darryl Fritz. Sewage - any sewage discharge from a main sewer line, pump station, manhole or sewage treatment plant. (Later lines are responsibility of homeowner or municipality). Maloclors from a main sewer-line, pump station, manhole or sewage treatment plant. Water--bod}g fish kills, oil sheens or discoloration on lakes or in streams, or odors in lakes or streams. . . Water Oualitv (General) any fuel gill fiorn vehicles (accidents) or any regulated substance that "is received during normal working hours. '7 Water Supply Management Program: Public Water Sunni}: -- any incident involving or affecting the water supply (15 or more dwellings or 25 people equal a public water supply) including bottled water. School general sanitation problems. Water -- private well if it was affected by a regulated substance or activity. Environmental Clean-up Prog1_*_arn: Abovegzound/Underground Reg' tration all regulated tanks must be registered. Regulated tanks are an aboveground storage tank 250 gallons or greater, underground storage tank 110 gallons or greater containing a regulated substance (see exemptions). Closure/Remand! Installer/Inspector -- the Department must be notified prior to the removal of all regulated aboveground or underground storage tanks. Also, a certified installer must conduct the removal or installation of a regulated tank. Leaking Abovegzound/Undergzound Storoge- Tanks Spill Response -- leak, spill or overfill from any tank regardless of size. . Groundwater -- contamination resulting from a leak, spill 'or overfill fiom any source where a water supply is present and maybe impacted. - General contaminated soil at the site of a tank removal or remediation remaining on site greater than 90 days. Improper contaminated soil storage where soils not placed on or covered by plastic. (N OTE: Waste Management covers contaminated soil transferred to another site). Tank Uggrade any regulated storage tank that has not been improved to meet current regulations. Industrial Waste -- a regulated tank containing a hazardous substance that was not regulated by Waste Mgt. or Water Mgt. would fall under the storage tank act. Soil and Waterways: Dams/Ponds problems with an on stream dam with a drainage area 100 acres or off stream darn 15' deep and 50 acre-feet of volume or constructed without a permit. A pond constructed without a permit or constructed in a wetland. Earth Disturbance erosion and sedimentation problems refer to the County Conservation District. -- excavatingor changing a watercourse, constructing a bridge or culvert, fill placed in a floodway. Wetlands' -- filling, draining, excavating or clearing/grabbing (removing stumps). COMPLAINT PROCEDURES When a complaint is received the Service Representative will make the determination if it is a regulated or non-regulated activity. 1. Regulated Complaint: The required information will be obtained from the complainant when applicable. Required information: detailed Q: the nature of the directiong Lg Qgiciglig and cgmg. Any - additional information you can obtain such as the complainant's name, address, telephone, the responsible party's name, address, telephone will help assist the field inspector in conducting a more proficient investigation. If the nature of the complaint can be covered by local government that has the appropriate ordinance I will refer it to them (I check my list of municipalities to see if they have the ordinance). I instruct them to contact me back with the results of their investigation. If after they investigate it and the situation is beyond the scope of what they can handle I will write it up as a complaint. Their investigation results will be entered and the reason why we are handling it. If it is something that we still should not get involved with then I will inform them of such. At times, I will request the assistance of local government, local police, state police, other state agencies, etc. to respond on behalf of the Department. This is in cases where the Department is unable to make an immediate response or if it is not classified as a priority according to the Department's standards but maybe at a local level, etc. I will informthern of the complaint, instruct them on What assistance the Department is requesting and ask that they . contact me back with the results of their investigation. CTS. If no follow-up by the Department is necessary I will enter the results of their investigation and then close it. out. I will be listed as the inspector with the investigation type as phone call or other. A copy of the complaint will be forwarded to the program for their information. If after their response the Department still needs to investigate it or conduct follow-up, I will assign it to the appropriate program. I will enter the results of their investigation. I will be listed as the initial inspector. with the investigation type as phone call or other. It will be the be forwarded to the program. The complaint will be entered into the NOTE: If the complaint is regarding malodors then all of the following information/criteria are mandatory: . The must be gccurring at gge gme gf the call, (document the time). If the odors are not present at time of call, then instruct the caller to contact the Department the next time they detect the odors also inform them of the below requirements. (DO NOT REGISTER THE COMPLAINT.) Th_e Qgglainant mug he present for the field inspector to conduct the investigation. (Meaning, they must be at the site of where they are detecting the odors) Complainanfs name, address telephone number. 2. Inform the complainant that their information has been logged, approximately how long it could - take for an investigation (this depends on the priority level assigned) and that the fie ect I will contac; ttgem back with the result; 9: mg'; jggegtigatign. NOTE: Any information pertaining to the complainant or infonnation that could identify the complainant is strictly "Confidential" and for no reason should it be gven out. 3. Assign Program(s) and Inspector(s): The S.R. will enter the complaint information into the . Complaint Tracking System and assign the appropriate program(s). The S.R. will determine what program(s) the complaint will be assigned. See Program Definitions if assistance is needed in determining the pro gram(s). Then the Field lnspector(s) will be assigned to the complaint. This is determined by what program(s) it was assigned to and what municipality and/or county it is located in. (See Field Inspector's Assigned Work Area to see what field inspector is assigned to what area(s)). 4. Assign Priority Level: A Priority Level (See "Priority Level Definitions" on pages 11 - 12) will be assigned to every complaint. The level is established by the severity of the complaint. If you think the complaint requires an immediate program response (Priority Level 1) then contact the appropriate supervisor, section chief and/or field inspector via, work phone or cellphone and they will determine if _the complaint warrants immediate attention. 1: it dpes, then you may either give them the information over the telephone if they are not in the office or they may come and pickup the complaint form. Make sure you are informed as to who will be assigned the complaint if theyjcnow. (In some cases the field inspector initially assigned the complaint may not be the one that will be responding because of not being available). If this program has no one available to respond or you cannot get someone from the program then another program should be contacted to see if they have someoneavailable. NOTEyou are unable to get someone then contact the program secretary and ask that they find the person in-charge and haye him or her contact you back. (Only wait a few minutes for a call back, if you have not heard from someone then try again. This will ensure that the complaint is not forgotten and it doesn't allow for too much time to pass, ensuring a more timely response.) If it is determined that an immediate gegonse is pg mmgted then the complaint will be assigned as a routine complaint according to the level indicated for that program. The In the Priority Level AQ WQ WM WSM box l11d1C8.t3S the Priority Level that 1 is to be assigned 2 to a routine complaint. 3 4 NOTE: Some levels may change depending on the type of complaint. Once a level has been assigned to a complaint it can only be changed by a Supervisor's request. A Field Inspector is not authorized to change a Priority Level. -- 5. Print Detail Form Send to Progran1(s): Once all the above information and requirements have been met a Detail Form(s) will be printed. The complaint form(s) will be taken" to the mailroom and placed in the appropriate pro gram(s) mailbox. This will be done twice a day, once before lunch and then before the end of the day. 10 6. Field Inspector(s) Investigates: The assigned field inspector(s) will conduct their investigation. There are three types of investigation responses, Site Visit, Phone Call and Other. The field inspector is required to perform one of those investigation responses. NOTE: cal "othe does 11 titute a "Date Fi nse" it out the Ex. A phone call to the complainant to request directions, additional information or to set up a meeting cannot be used as a Date of First Response. 1. Fills Out Complaint Form: - The field inspector is to write a description of what they found upon their investigation into the complaint. If a site visit was not warranted then the description should include the reason as to Why one was not necessary. 0 Upon their investigation if any additional information or corrections to information reported on the form-was obtained this should be written on the form. The S.R. will make changes in CTS. This would include any information under the Complaint Information, Complainant Information, Responsible Party Information, and Response Information sections. 0 Ifthere is a complainant listed on the complaint form the field inspector is required to notify the complainant of the results of their investigation and the date should be noted on the form. Notification can be done by a phone call, in person, an email, or letter. The type of notification should be noted in the description field 8. Investigation Conclusion: The outcome of theinvestigation will determine the procedure you will follow in order to properly handle and close out the complaint. Below are the different routes you are to follow. Follow the color-coded "Complaint Flow Chart" on Page 14 for assistance. Referral T0: 0 Another DEP Program: The complaint has been investigated and it is determined that it should be referred to another Departmental Program. The field inspector makes note of the Program it is to be referred to in the "Referred field on the complaint form. The S.R. will re-assign the complaint to the new program and a copy of the completed complaint form from the original program it was assigned to will be attached for their information. The field inspector needs to follow the appropriate steps {starting from "Violation) below to ensure the complaint is properly handled and closed out. . - Another Agency, etc: The complaint has been investigated andit is determined that it should be referred to another agency, etc; The field inspector makes note of the agency, etc. they are referring it to in the "Referred Toc" field on the complaint form and the date it was referred. Field inspector is responsible for forwarding the information. The complainant information is not to be referred unless the agency, etc. follows the same "Confidentiality Standards" as the Department. The field inspector needs to follow the appropriate steps (starting fitom "Violation) below to ensure the complaint is properly handled and closed out. I Violation: 0 NO: The complaint has been investigated and it has been determined that there are no violations- Was the complaint against a permitted facility? then this complaint needs to be entered into Efacts first and the Efacts Inspection needs to be written on the form in it's assigned field. It does not matter if the facility is permitted in your program or not, as long as ithas a permit from the Department it needs to be entered. - If then the complaint can be closed. As long as the Complaint Form has been properly filled out (See Ciosing Out a Complaint, Page 12) it can be sent to the S. R. for data entry. (If your supervisor requires that it be sent through them first, then it goes to them and they will route it to me). 11 I YES: The complaint has been investigated and it has been determined that there was a violation of the Department's Reguiations. Was enforcement action taken'? If an NOV is being sent then this complaint needs to be entered into Efacts first and the Efacts Inspection needs to be written on the form in it's assigned field. The Responsible Party information is required to be filled in on the form unless the R.P. cannot be determined. . If it was a permitted facility then it must be entered into Efacts first. It does not matter if the facility is permitted in your program or not, as long as it has a permit from the Department it needs to be entered. If a violation exists but not enforcement action (non-permitted only) is being taken, then this to be entered into Efacts, but it need; tg pg; noted ip the ipvestigatiog that "An NQ 32 gas not Waizant". Follow-up Required! - - NO: If no follow-up inspection is required then the complaint can be closed out. See "Closing Out a Complaint", Page 12. It can then be sent to the S. R. for data entry. (If your supervisor requires that it be sent through them first, then it goes to them and they will route it to me). 0 YES: If a follow--up inspection(s) is required then the field inspector will make a copy of the Complaint Form with the information from the initial investigation and send it to the S.R. for data entry. (If your supervisor requires that it be sent through them first, then it goes to them and they will route it to me). 0 Reinvestigate: The field inspector conducts a follow--up investigation(s). The new information and dates are entered on the complaint form. If the violation is "resolved" then the complaint can be closed out. See "Closing Out a Complaint", Page 12. It can then be sent to the S. R. for data entry. (If your supervisor requires that it be sent through them first, then it goes to them and they will route it to me). If the violation has not been corrected then you continue the above steps until the violation is resolved and/or comes into compliance. 9. Closing Out a Complaint: In order to properly close out a complaint certain fields must be filled in. The Date of First Response, Date Resolved, Date Investigated, Type, Inspector, Violation, and Investigation Description are all regujged fields for eveg complaint. Again, if there is .a violation with enforcement action then the Responsible Party field is required (When applicable) and an Efacts Exceptions: If the vio1atis)note are going to tak an outg (than 180 days) amount of time to come into compliance then the complaint can be closed for tracking purposes only. - This should be noted in the investigation description field along with a notation that follow-up is being conducted by the program. . Examples: (1) A tank release that has contaminated a Well. This may take several months or longer for the violation to be corrected. In this case the complaint can be resolved once the complainant and/or responsible party have been notified. (2) An odor complaint comes in against a STP. The odors are documented and the source of the odors is a malfunctioning "scrubber". The scrubber needs to be replaced and it will take a number of months before the problem is corrected. In this case the complaint can be closed after the NOV, etc. has been issued. Any additional complaints' that are registered thereafter will be entered as a new complaint and can be closed out after they have been investigated. 12 . The S.R. is responsible to review the findings to distinguish if the inspector's investigation results are I what the Department considers to be a "Quality Response". (See "Defining a Quality Response" on page 15.) All information will be entered into the CTS and any additional instructions by the inspector(s) and/or supervisor will be followed. NOTE: The S.R. will only refer complaints via. e- mail or by telephone. No letters will be sent. The S.R is responsible for entering the Resolution Date when they feel the complaint is completely closed. At this time the S.R. will forward the Complaint Form to Records Management for filing. If for any reason a complaint needs to be re- opened, the S.R. is the only one that can reactive it into an "Open Status". NOTE: When a complaint is assigned to a field inspector it is their responsibility to make sure that the form is filled out correctly and returned to the Service Rep. for updating. If a Supervisor assigns a complaint to another field inspector rather then the one whom covers that area normally, they must notify the S.R. This will ensure that the appropriate field inspector is listed on the complaint fonn, which will prohibit complications that could arise later. If a complaint appears on the Overdue/Unresolved Reportit is up to the field inspector it was assigned to track down any information in order to properly close out the complaint. A helpful hint; If you get a complaint that was assigned to you while you were on vacation or other type of leave, you should check with your supervisor to see if it had been assigned to another inspector for any reason. N013: The CTS is used DEP Regions, District Mining Offices, and Bureaus. So all procedures that apply in this region may not apply in others. Also, fields in the system and on the detail form are not all for the sole purpose of regional office use. Related Complaints Registered in the same day or within a few days of one another: Same Complaint: If complaints are received on the same day, against the same responsible party and are of the same nature, they' are to be recorded as one complaint with additional complainants. The time of each call should be documented. If a complaint is received on one day and an additional "complaint comes in after that, as long as it is prior to the field inspector conducting the initial investigation it is to be. logged as the same complaint. Document the additional complainant(s), the new date(s) and tirne(s). New Complaint: If a complaint comes in one day and it has been investigated, then another complaint comes in regarding the same or different activity it is to be logged as a new complaint. The exception is if the R.P. had not yet been notified by the Department. The rule of thumb to use is that once the complaint has been investigated and another complaint comes in after that it should be logged as a new complaint. - Delegated Counties for Soil Waterways Complaints: Counties that have been entrusted the responsibility to investigate Soit Waterways complaints are "Delegated County Conservation District's"" and are not to be entered into the CTS. The complaint andfor caller should be referred to the appropriate conservation district- The only time these complaints are to be entered into CTS is after the District conducted the initial investigation and cannot get compliance or if seeking assistance fiom the Department. 13- PRIORITY LEVELS Priorigg 1 -- Refers to complaints requiring an immediate program response. This is a same day response. This does not include Emergency Responses. Ex: Date Received l/01/2010 - First Response 1/ 01/2010 - I Priority 2 - Refers to complaints that are serious but are not likely to escalate within 7-10 days but pose an existing or potential adverse impact on the environment or public health. They must be investigated within 10 working days. Ex: Date Received l/01/2010 First Response 1/15/2010 Priority 3 - Refers to complaints that would not result in environmental harm if not investigated within a few weeks. These complaints require a phone call within 10 days and if the complaint is not resolved by that phone call, then an investigation of the site must follow within the initial 30 days. Ex: Date Received l/'01/2005 -- First Response 2/ 1 2/2005 Priorigg 4 - Refers to complaints that are ongoing and require a long-term solution. Ifa complaint was received and initially investigated under a Priority 1, 2, or 3 and will require a long-term solution it will then be down graded to this level. Also, a complaint that the Department is aware of and is going to take time for it to become resolved will be assigned this level. The complaints are_to be left open until they are completely closed. They must be investigated within 40 working days. phone call or a letter must be sent to the complainant explaining the conditions surrounding the complaint. Ex: Date Received -- First Response 2/26/2005 DEFINING QUALITY RESPONSE: A Quality Response will consist of the following: All required fields on the Detail Form are properly filled in. Investigation description clearly indicates the problem was inspected. Investigation description is clearly explained. Complainant was advised accordingly of findings and notification type, date and time documented. A message left on an answering machinefvoice will suffice. If complainant has neither and several attempts were made with no answer, then no additional attempts are required. Document date and times of attempts. (Exceptions: Anonymous, no phone number)- - Responsible Party information is complete when there is a violation. Efacts Investigation is filled when the Responsible Party is permitted or enforcement action has been taken. 0 If the location could not be found, documentation should me noted as to additional measures taken to try to locate the site. - Timely response. 0000 The S3, will view the inspector' findings and differentiate if the response is adequate and acceptable by the Department or not. The guidelines the S.R. will be following are those listed above. If the SR. deems the response inadequate she will notify the Assistant Regional Director. He and the inspector's supervisor will make the final determination if the response is adequate. The Detail Form will be returned to the inspector if the decision was deemed inadequate. He or she will then make the proper corrections. - 14 OIL GAS REGULATED COMPLAINTS: When an Oil Gas call is received by this region, the following criteria will determine what region will handle the investigation. NOTE: If it is determined that the complaint will be handled by this region then you will follow the procedures for handling a routine complaint. Northeast Region's ERT will investigate all after hours and weekend 0 complaints and emergencies. Northcentral Region: - 0 An incident when it is a result of the actions on a well site, access roads, spills on Well site, private property roads, water withdrawals, malodors, or problems dealing with the preparation of a well site. 0 Ifit is determined to be handled by the Northcentral Regional Ofiice you are to forward the caller to the Scranton District Office at (570)346-5530 and then follow up with an email with the callers name and phone number to Alice Adams, Jennifer Means and Marc Cooley. Northeast Region: All spills that occur off the well site, access roads, private roads, etc. - Malodors from compressor station emissions. 6 ERT will investigate unknown substance discharges into ditches, streams, etc. I Tirnbering conducted on a property "rumored" to be a future pad site will be investigated by the County Conservation District. . NON-REGULATED -COMPLAINTS: When a complaint is received by the S.R. and it is determined the Department does not regulate it, one of the following methods are conducted. The cornplainant is notified that this is not a regulated activity. They will be informed of what agency has jurisdiction (in some cases they will be informed it is a civil matter) and they will be provided their telephone number when it is available. In other cases, the S.R. will respond back via e-mail or letter informing them of the same. If no complainant information is available, the S.R. will forward the complaint directly. The S.R. will not forward complainant information unless the complainant has authorized it or if the receiving agency is state or federal and they follow the same confidentiality policy as ours. 15 See below Guidance Document via 'Field Operations Policy. 6/30/2003. Office of Field Operations GUIDANCE Kris Lutz 717-787-9240 epconfs93fField Ops/fieidopslCon1plaint 6/30/2003 Tracking System I. Guidance A policy for input of complaints into Efacts was issued August 24, 1999 by Terry Fabian, Deputy Secretary for Field Operations. Based upon input of this data since 1999, this policy is being updated to provide finther guidance on entering the data. II. POLICY The following methodology should eliminate duplicate tracking of open complaints, prevent the creation of Efacts sites and clients that We do not regulate or against Whom we have NOT taken an enforcement action, and ensure that Efacts accurately reflect our enforcement efforts. Complaints that we receive about a regulated Site should be referred to the appropriate program on the Complaint Tracking System and they should be entered in as a complaint inspection type on Efacts and tracked there. The Complaint ID field is available in the Efacts inspections screen and the Inspection ID field fi'om Bfacts is available on the CTS Response screen. These two fields in the future will be auto populated so that you will be able to toggle back and forth between Bfacts and CTS. Both systems should be populated with the appropriate ID number. The detailed description data about the results of the inspection still must be documented in the CTS system. Based upon the regional office's business process, either the Service Representative or the field inspector will enter this data. Complaints that we receive about non-regulated (non-permitted) sites should be retained on the Complaint Tracking system for closure when the site has come back .into compliance unless an enforcement action (including an NOV) is taken. If an enforcement action is taken, the details of the enforcement action for this complaint should be in the Complaint Tracking System and the inspection and enforcement record created in Efacts. HI. APPLICABILITY Applicable to all Field Operations regional staff that inputcomplaint data into the Complaint Tracking System and into Efacts. IV. Effective This Policy will take effect and be implemented immediately. I Sends To S.R. REGULATED NON-REGULATED Complaint Information When applicable A Ass1gn Pr0gran1(s) Inspector(s) provide complainant with appropriate agency, etc. Assign Priority Level information. If anonymous complainant S.R. Print Form Send to Progam "'i11 make the referral. 1 Field Inspector Investigates tifi Fills Out Complaint 01111 Another DEP 4 Referral To: Investigation_Conclusion: 1 Another Agency, etc. 10 anon 1 Inspector Makes Referral Fill Out Permitted Complaint Facility FOIT11 NOV Make No NOV Sent, Efacts Envy but if permitted YES facility make Re1nvest1gate Efacts Entry I Make copy Followup YES ofform Make Required send to g_R_ Efacts Entry 17 COMPLAINT .. -. . .. . .. . .. . Pm>> 1 cm fl NE F-{grit 55.193 -Home . Lacmwamrxa at fiwfi - :4 marmm Bats-nacaimad: iBfls - %fiQifiiL.%mE mWKf$i. -- SE3 -- .3 "meat ET 7:17-2:52-ism - fldafitmaiimatvm: - ivlamafiaonnr -- - em: - - Rama: RA GO -- gampfidmaga: I - ma. an-x $4143? mm? PA tam com-:3: . lime Bat'? amsacaeazc - mfipadm mmwmammxm - Srlvaa El: 533% 01511.11' 9.- . wnsmamaas warm an COMPLAINT FORM FIELDS: . Complaint Information Section: Id: This is a system-generated number for the purpose of tracking the complaint. Related Id: If a previous complaint was registered by the same complainant and against the same R.P., this is where you would put the other Complaint lD#. Municipality: This is the local Township, Borough or City that the complaint is located. County: This is the County in which the complaint is located. Entered By: This is the name of the S.R. that entered the complaint into the CTS. ER Related (Y This would indicate if this is an Emergency Response (Field used by ER). After Hours Ind (Y This would indicate if the call was reported after working hours (Field used by ER). Confidential All regional complaints are "Confidential", this is a n/a field for our region. Source: How the complaint was received by the Department. The choices: Email, Fax, Legislative Contact, Letter, Other, Phone Call, Web Page Date Received: This is the day in which the Department received the complaint. Date Acknowledged: If the field inspector contacted the complainant prior to their investigation they may document the date in this field. Abbrv Description: This is a brief description of the nature of the complaint. Long Description: This is a more detailed description of the nature of the complaint. Site Location: This is where directions, street address, etc. to the site location would be documented. Complainant Information Section: Seq No: This is the number used 'to identify the complainant throughout the remainder if the complaint when there is more than one complainant associated to the same complaint. Company: if the complainant is associated with a municipality, company, etc. this is where the name would be documented. - Name: This is the name of the person whom registered the complaint. There can be more than one complainant. Also, if this entire section is blank then the complainant was anonymous. Address: This is the address of the complainant. e-Mail: This is used to document the complainant's email address if they submitted their complaint via the web page, etc. Mobile Phone: This is the cell phone number of the complainant. Home Phone: This is the home phone number of the complainant. Work Phone Ext: This is the work phone number of the complainant. Confidential (Y This will always be "Yes" because complainant information is not to be accessible to anyone other than the Deparunent. Date/Time Received: This is the date and time the complaint was received by the Department. Responsible Party Information Section: Name: is the name of the person whom the complaint is against or contact person. There can be more than one responsible party. Home Phone: This is the R.P.'s home phone number. Work Phone Ext: This is the R.P.'s work phone and ext. -Company Name: This is the facility or organization of the alleged violator. Address: This is the address of the RP. Permits': This is the permit number of the RP. if they have one. Municipality: This is the local Twp. or Boro the responsible party is located. County: This is the county the RP. is located our region or the state. Response Information Section: . Priority: This is the love! in which the complaint was o:s'sz'gned; it determines the amount ofrime the inspector has to investigate the Complaint. - . - Program: 177211: is the program that was assigned the complaint. There car: be more than one program assigned to a complaint. Complaint Type: 2723 coding that is used to categorize the nature ofthe complaint. They are dfyfercnz per program. Date Resp Assigned: Thz'.s'- is the date the complaint was assigned to the field inspector. 19 Date Response Due: This is the date the field inspector needs to have the investigation conducted by. Date First Response: This is the date the field inspector conducted their investigation. Date Resolved: This is the date the complaint is closed out by the program. Date Referred: This is the date the program referred the complaint, 9' applicable. Referred To: This is the name of the agency, program, etc. that the compiaint is being referred to. Comments: This is an area that confidential information may be documented and it would only be privy to DEP personnel, it does not print out on the complaint form. Inspector: This is the field person assigned to investigate the complaint. Supervisor: This is the field inspector 's superior. Investiaation Information Section: Date Investn Assigned: This is the date the field inspector receives the complaint. Date Investigated: This is the date the complaint was investigated,' it is ztsuaiiv the same date as the First Response Date. Type: This is the kind of investigation that was conducted'. Site Visit, Phone Call or Other, they are the only choices. Inspector: The name of the field inspector who conducted the investigation. It may vary if this is not the person initialbi assigned. Violation" (Y This is the field to indicate whether a violation existed during the investigation or not. EFACTS Inspection Id: This is the associated with the inspection that is entered into Efacts as a result of the compiaint. Investigation Id: This is the associated to the investigation that is entered into the CTS. Investigation Description: This is the narrative that is written by the field inspector indicating the outcome of their investigation. REPORTS Listed below are the system--generated reports that are available to all Management and Inspectors. The name of the report, a description of what the report produces, the report parameters and the fields on the report are listed for each one. Each report will provide only data that falls under the criteria requested for that time frame. Also, S.R. was trained in Discoverer and has the capability of designing and creating reports at anyo_ne's request. Joint Inspection Report: This report is used to View those complaints that have been assigned to more - than one program where a combined investigation was conducted. Report Parameters": Region 0 County .- Responsible Party I Program I Date Range ields' on Report: 0 County - Program I Complaint ID 0 Date Received (The day the complaint was received by the Department) 0 Joint Inspection (The other progta:m(s) assigned to the complaint) - Complaint Type (The program code type identifying the classification) I hfunicipality (Local Twp. or Boro the complaint is located) 0 Responsible Party (The alleged person/company) 0 Inspection ID (The number that is used to identify the investigation that is associated with a complaint) 20 Log Report: This report is primarily used to View complaints assigned to a particular inspector in a specified time frame. It gives related data concerning those complaints. Report Parameters: I Region I Program I County I Supervisor I Inspector I Date Received From Date Received To Fields on Report: I Region I Program I Complaint ID I Dare Assigned (Date complaint was appointed to inspector) I Complainant (The person Whom reported the complaint) I Responsible Party (The alleged person/company) I County I Abbreviated Description (Brief explanation of the complaint) I Inspector I First Response (The date the inspector responded to the complaint) I Date Resolved (The date the program closed the complaint) Managers Report: This report is used to view the number of complaints assigned to each inspector, if they were investigated, resolved or referred. Report Parameters: I Region I Program I Supervisor I Inspector I Date Received From Date Received To Fields on Report: I Region I Program I Supervisor I Inspector I Assigned (Number of complaints assigned to inspector according to date range) I First Responses (Number of complaints inspector investigated) I 0fFirst Responses Investigated.' Before Due Date: How many were investigated before the due date 0 After Due Date: How many were investigated beyond the due date I Resolved (The number of con1plaint's that are closed out) 21 Referred (The number of complaints forwarded to another agency, etc.) 0 Violations (The number of complaints resulting in violations) 0 Supervisors orals (The total number of each column for supervisors staff) 0 Program Totafs (The total number of the each column for program) Grand Totals (The total number of the each column for the entire region) Overdue/Uni resolved Complaints Report: This report is used to check on those complaints that have not been investigated and/or have not been closed out. NOTE: The complaints that Show up on this report are not all due to not being investigated; it is mostly that the complaint form was not sent to the SR for updating. Report Parameters: 0 Region 0 Program 0 County - Responsible Party 0 Supervisor - Inspector 0 Date Received From Date Received To Fields on Report: 0 Region 0 Program 0 Supervisor 0 County I 'Complaint ID I Inspector 0 Date Assigned "(Date complaint was appointed to inspector) - First Response (The date the inspector responded to the complaint) - Due Date (The date the complaint must be investigated by) 0 Days Overdue (The of days the complaint is beyond the Due Date) 0 Days Unresolved (The #of days the complaint remains open) 0 Complainant (The person Whom reported the complaint) 0 Responsible Party (The alleged person/company) 0 Mum'cz'_paZz'ty (Local Twp. or Boro the complaint is located) 0 Abbreviated Description (Brief explanation of the complaint) Response Performance Report: This report is used to View how programs 1'esponse'tirnes are for investigating and resolving complaints. Fields are based on averages. Report Parameters: a Region 0 Program 0 Supervisor Inspector 22 -0 Date Received From Date Received To Fields on Report: - Region - Program I Complaints Received (The number of complaints received per program) 0 Responses (The number of investigations performed out of number received) 0 Average Initial Response one (Average of days to conduct a First Response) 0 Responses Resolved (The of closed complaints out of number investigated) 0 Average Time Resoived (Average of days to close out a complaint) - Program Totals (The totals of the above columns per program) 0 Region Totals (The totals of the above columns for a regional office) 0 Grand Totals (The totals of the above columns if report requested for more than one region) Statistical Report: This report shows programs performance based on priority levels assigned to the I complaints. It shows the number investigated before the due date, after the due date, those that are overdue, not yet overdue and the number of violations. Report Parameters: 0 Region 0 Program 0 County 0 Supervisor 0 Date Received From Date Received To Fields on Report: 0 Program a Level" (The Priority <