On the Tennessee River below the confluence of the Holston and French Broad rivers near Knoxville, the EPA lists 24 sub-watersheds. These sub-watersheds represent diverse characteristics and present multiple enforcement challenges. Tennessee Riverkeeper targets each sub-watershed individually or in manageable groups, identifies problem areas or entities, and executes an enforcement strategy designed to achieve maximum effectiveness.
This concentrated approach allows for maximum citizen participation. The Riverkeeper utilizes sophisticated outreach strategies to recruit members in all of these sub-watersheds, thus allowing for an ever growing membership base and high membership interest in enforcement activities.
NPDES permit holders are identified through on-line databases maintained by the EPA and others. Facilities that are indicated to be in non-compliance are prioritized. Discharge monitoring reports and other filings with the state agencies are reviewed to both confirm the on-line findings and to search for and identify other violations. When it appears it would be helpful to the investigation, the facility and/or the receiving stream will be patrolled in the most advantageous fashion, either by air, on the ground, or on the water. Water sampling is conducted where necessary to confirm a discharge or to check water quality.
Problems identified through other means are investigated in a similar manner. These problems may be identified by routine patrol or by citizen reports. Routine patrols are conducted. However, due to the size of the watershed, it is not possible to patrol every mile of every stream in the watershed. Problem areas and suspicious activities will be prioritized. Patrols are important to maintain a presence on the river and to find problems that might otherwise escape detection.