INSPECTION ACTIVITIES

INSPECTION ACTIVITIES

QUALITATIVE RESULTS

Municipality: Contra Costa County (Unincorporated) Permit Year: 2008/2009

Introduction:

The County Watershed Program (CWP) is responsible for inspecting and overseeing commercial and industrial businesses within unincorporated Contra Costa County to ensure that stormwater pollution prevention practices are being implemented. Facilities are prioritized according to their potential to pollute, as required by our current municipal stormwater discharge National Pollutant Discharge Elimination System (NPDES) permit.

In order to efficiently and cost effectively oversee inspection and corrective action, CWP works cooperatively with other County departments to ensure that businesses remain in compliance with stormwater regulations. The CWP’s main partners in this effort are two divisions of the Contra Costa County Health Services Department (HSD). Under Interdepartmental Agreements, HSD’s Environmental Health Division performs inspections at food service facilities for stormwater issues, while the HSD’s Hazardous Materials (HazMat) Program inspects most other business types, including those that store hazardous materials or that generate hazardous waste above a certain threshold. The County departments and divisions that provide stormwater inspection-related services will collectively be referred to as “the INSP Program” throughout this section of the Annual Report.

Each year, the CWP works with (12) contracted stormwater inspectors from HazMat to select a subset of facilities chosen for inspection from over 550 industrial and commercial facilities doing business in unincorporated Contra Costa County.  During the Permit Year (PY) 2008/09, we prioritized Notice of Intent (NOI) facilities and/or those that have filed to be included in the State Water Resources Control Board’s (SWRCB) General Stormwater Permit for Industrial Activities based on their North American Industrial Classification (NAIC).  Examples of NAIC codes that require permit coverage are: manufacturing facilities, scrap yards and auto dismantlers, transportation facilities conducting vehicle maintenance, chemical manufacturers and industrial warehouses.  Most of these types of NOI facilities are also hazardous waste generators that fall under HazMat’s purview as the California Department of Toxic Substances Control’s (DTSC) Certified Unified Program Agency (CUPA) and are required to be inspected every 3 years for their hazardous waste management. It makes sense to streamline our County’s inspection efforts by conducting our stormwater inspections during these site visits. We estimate there are approximately 220 NOI facilities in unincorporated Contra Costa County.

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During PY 2008/09, the CWP also directed HazMat to focus on vehicle service facilities such as gas stations and auto repair shops. These businesses typically deal with large quantities of petroleum fluids and conduct potentially polluting repair and maintenance activities outdoors. We also inspected nurseries and dry cleaners in our jurisdiction because of the pesticides and solvents used in many of their processes. The remaining facilities chosen for inspection were determined by using that company’s ‘mandatory’ status in our stormwater database (HSDROUT). We also inspected two facilities upon request of the Central Valley Regional Water Quality Control Board--Region 5 in response to their having exceeded certain limits while self-monitoring their own stormwater samples. HazMat continues to provide quarterly (non-formal) inspection services at our five marinas with oil-recycling infrastructures as part of the County’s ongoing commitment to the Keep the Delta Clean (KDC) Program. These informal inspections are intended to assist the KDC marinas in maintaining and continuing their oil-recycling efforts.

In addition to CWP’s Interdepartmental Agreement with HazMat, the CWP also had the pleasure of re-establishing ties with the Department of Health Services, Environmental Health (Env. Health) Division this year for stormwater inspection services at food service facilities. Historically, CWP has entered into annual agreements with Env. Health with the intent to consolidate inspections, whenever possible. Their division’s Food Safety Inspectors already conduct public health inspections of these establishments. Subsequently, it makes sense to partner with them. Through this partnership, a segment of the inspection reviews outdoor stormwater protection activities including; proper disposal of mop/wash water, dumpster management, cardboard recycling and used oil and grease bin storage.

Together, CWP and HSD work to inspect, educate, and enforce, as necessary, our County’s municipal stormwater discharge NPDES permit provisions. During PY 2008/09, CWP oversaw Interdepartmental Agreements with contract limits of $155,500 for HazMat and $70,028 for Environmental Services. These agreements provide for service categories including; routine industrial and commercial inspections, remedial inspection and enforcement, technical assistance, education for stormwater pollution prevention, illegal dumping incident investigations, and training and administrative costs. It should be noted that the CWP also works, in conjunction with other County inspectors, particularly those in our PWD Construction Division while conducting “pre-rainy season” inspections of construction sites and new developments. For more information regarding this inspection program, please refer to the New Development & Construction Controls (NDCC) Section of this Annual Report.

During PY 2008/09, stormwater inspectors from both agencies were able to establish relationships with business owners and managers, while also observing, firsthand, some of the pollution prevention practices currently being utilized, as well as the issues involved in eliminating potential stormwater impacts associated with their type of business. Most importantly, County inspectors who conduct stormwater inspections are able to explain the goals and objectives of the County’s municipal stormwater discharge NPDES permit. This both educates and helps businesses understand the importance of remaining in compliance with the County’s NPDES permit not only for the sake of

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protecting our infrastructure but, to protect ALL the County’s waterways, including the Delta and the Bay. This admirable goal is presented in such a way that managers and operators can understand that the benefits of these sound environmental protection practices can be good for business.

Contact Charmaine Bernard at (925) 313-2236 or, cbern@pw.cccounty.us, or Peter Inouye at (925) 313-2317 or, pinou@pw.cccounty.us, for more information about the Inspection Section of CWP’s Annual Report.

Implementation & Evaluation:

Analysis of Stated Permit Year 2007/2008 and Annual Report Goals for PY 2008/09

1. Assist the three pilot marinas hosting Keep the Delta Clean oil recycling sheds with updating of customized and site-specific “environmental” and “boat maintenance contractor” policies based on the Clean Marina Toolkit.

During Permit Year 2008/09, CWP continued to work with its three pilot marinas hosting Keep the Delta Clean oil recycling sheds to ensure their infrastructure remains in compliance with all applicable laws. Each quarter, as part of their contract with CWP, HazMat performs an informal inspection of the sites and forwards feedback to CWP and the marinas.

2. Continue to distribute information about Mobile Cleaners and Carpet Cleaners to businesses during inspections.

CWP, HazMat and Environmental Health Stormwater Inspectors have been equipped with both brochures as part of their Best Management Practices (BMP) Car Kits. The brochures are handed out while inspecting these facility types. They were produced several years ago by the Contra Costa Clean Water Program (CCCWP) but their message “Only Rain Down the Drain” is still relevant and useful. The brochures can be viewed here: Wash Water Disposal Practices for Carpet Cleaners and Mobile Surface Cleaners which emphasize appropriate wash water disposal and encourage certification in the Bay Area Stormwater Management Agencies Association (BASMMA) Mobile Surface Cleaning Program.

3. Create new electronic inspection forms for HazMat inspectors after the new performance standards are established in the Municipal Regional Permit (MRP).

Pending finalized MRP. HazMat spent over $600,000 in previous years working with a software company in efforts to develop electronic software for their CUPA inspections. Unfortunately, the company went out of business in mid-development and the project was frozen. Subsequently, HazMat continues to document their stormwater inspections using somewhat outdated forms. CWP and HazMat have begun preliminary discussions for ways to improve the reporting forms on which we plan to work at the start of PY 2009/10 inspection rounds.

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4. Continue to audit and incorporate any new businesses into the existing database.

Ongoing. As we become aware of business closures or, address changes, we update the master list of 550+ businesses in HSDROUT. Though no proactive effort was made to revise our database this year, the ‘overhaul’ of our stormwater facility database is being prioritized for the coming PY 2009/10. Thanks to the GIS overlays (utilized by Env. Health’s Information Technology (IT) Division), we were able to secure an updated list of food service facilities believed to be operating in the unincorporated areas of the County. This ‘new’ information increased CWP’s list of restaurants from 175 to 282.

5. Continue to work with the Contra Costa District Attorney’s (DA’s) Office, Environmental Crimes Unit for all serious and gross violations of the local stormwater ordinance that cannot be resolved through Notice of Violation (NOV) action.

Ongoing. Both, CWP and Enforcement staff at HazMat, have established an excellent working relationship with our two contacts at the DA’s Office and have received considerable support in resolving discharges prior to needing enforcement or prosecution. The DA usually prosecutes violations of State statutes and has sole authority to prosecute Penal Code and Water Code violations that may be implicated when there are stormwater violations.  They also have direct, as well as indirect, authority to enforce our Stormwater Ordinance Section 1014. In fact, CWP has been informed that this is the only ordinance code provision that gives the DA direct authority to prosecute misdemeanor violations of an ordinance. The DA also has civil penalty authority under the Business and Professions Code Section(s) 17200 and 17206, which they frequently use to prosecute businesses who violate the Stormwater Ordinance and other State law pollution provisions.

6. Facilitate discussions between the Contra Costa Fire Protection District (CCFPD) and the CWP about upcoming cooperative agreements between our two agencies to conduct stormwater inspections for a much broader base of facilities that are routinely inspected for fire prevention purposes.

Based on funding cuts to public health and safety organizations during the current budget crisis, CWP has chosen not to pursue this route at this time. Initially, we were contacted by an ambitious Fire Captain about his concerns with potential stormwater violations which could possibly happen at any number of horse boarding facilities in the County. The idea was to work with his organization; if potential stormwater violations were identified during routine fire safety inspections, they would be forwarded to CWP. The idea was halted after higher management at the CCFPD contacted. Based on these dealings with CCFPD, CWP decided to hold off on putting in the hard work that would be required to pursue establishing cooperative stormwater inspection responsibilities with the Fire Protection District. We of course welcome and follow up on any referrals from their department.

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7. Continue to strive to more efficiently meet the inspection requirements of our NPDES permit, including evaluating the possibility of hiring and training our own CWP stormwater inspector, thereby reducing and/or eliminating the need to contract with other County Departments or outside agencies.

CWP believes our current Inspection Program has been streamlined. Our inspections are now done by HazMat and Env. Health Inspectors as they already have the training, expertise and history, with these regulated businesses, necessary to make all of our inspections in the most cost efficient manner possible.

Inspection Activities During PY 2008/09:

Following is a summary of the industrial and commercial facility and restaurant inspections and subsequent enforcement actions conducted by HazMat and Env. Health, on behalf of the CWP for PY 2008/09:

145 Industrial and Commercial Facility Stormwater Inspections performed by HazMat (same as the 145 completed in PY 2007/08).

153 Food Service Facility Inspections performed by Env. Health (as compared to 48 restaurant inspections completed by CWP in PY 2007/08).

298 Total Stormwater Inspections in PY 2008/09

19 Enforcement Actions taken in the form of Cease and Desist Orders, Notice of Violations and/or Warnings issued.

On the following page is a graph showing the increase in the number of food service facility inspections conducted this year.

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Industrial/Commercial Facility Stormwater InspectionsHazMat Inspectors performed 144 total inspections for the year. This is the breakdown of the types of facilities inspected:

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87 - NOI facilities 32 - Vehicle Service Facilities (VSF) 16 - Commercial Businesses 10 - Miscellaneous, and

153 - Restaurants

Of the 145 stormwater inspections conducted by HazMat, the vast majority of businesses inspected had no violations, observed good housekeeping practices, and either had no outdoor activities or, had no storm drains on-site. Four facilities were inspected twice this PY 2008/09 and 2 are scheduled to be re-inspected to verify corrective action has been taken. Most (89) of the facilities were given a ‘Good’ rating. Only 6 were given a ‘Bad’ rating. Of these 6 facilities, 12 enforcement actions were cited by HazMat. These enforcement actions included the issuance of 6—“Notices of Violation” and 6—“Warnings” given at the following facilities, for the violations indicated:

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Facilities Issued a Notice of Violation Casey’s Auto Body, Brentwood – Wash water goes to stormdrain needs to be

redirected. Contra Costa Airport, Byron – Improvement needed at the aviation fuel line from

tank to pump lying above storm drain. Pinole/Rodeo Auto Wreckers, Rodeo – Needs extra layer of boom around

stormdrain. Frito Lay, Concord – Cover oily parts; use drip-pans/absorbents; samples of run-

off should not be taken from roof water. Orwood Resort, Discovery Bay – Clean but, site must file “NOI” by: 7/26/09. Schwartz Trucking, Clayton – oil drums and used batteries must be removed

from outside.

Facilities Issued a Warning D’Anna Yacht Center, Bethel Island – Needs proof of State Permit, Stormwater

Pollution Prevention Plan (SWPPP) and rain event samples. Sugar Barge Resort and Marina, Bethel Island – Needs NOI and SWPPP. Yellow Cab, Pacheco – Missing SWPPP. Lazy M Marina, Discovery Bay – Must determine if NOI has been filed. Diablo Boat Works, Bethel Island – Water samples should be tested for metals. Carol’s Harbor, Bethel Island – Materials need to be removed from dock.

  Industrial/ Commercial    NOI Other VSF MISC TotalEnforcement actions 11 0 1 0 12NOV issued 5 0 1 0 6Warnings 6 0 0 0 6"good" 49 13 21 6 89"bad" 5 0 1 0 6Reinspections 3 0 0 0 3Reinsp corrected 1 0 0 0 1

Of the 145 stormwater inspections conducted by HazMat, many of them were found to be in excellent order and were employing numerous BMP’s to protect the stormwater.

Some notable facilities were: Concord Auto Dismantler, Concord – Exhibiting excellent organization and

cleanliness with all drains being protected by wattles. This facility has gone above and beyond to protect the stormdrain.

Contra Costa Transfer Recovery, Martinez - Debris basket in each storm drain, maintenance on each before the rainy season. Western apron of site drains to oily water separator connected to sanitary, rest of site run-off is captured at sumps and pumped to leachate tanks that are picked up by waste hauler.

Carone & Company, Martinez – Concrete-asphalt recycling facility with 4 storm drains throughout site that are protected with filter fabric and sandbags to prevent silt build-up.

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Maxim Crane Works , Martinez – Company has good, clean-water practices and trains employees on spill prevention and countermeasures.

This PY 2008/09, the majority of stormwater facility inspections were conducted in following unincorporated County areas in order: Richmond (22) due to heavy industry in the area; Bethel Island (18) due to significant number of marinas; Martinez (13); Oakley (11) and Concord (11).

Area No. InspAlamo 3Antioch 5Bay Point 6Bethel Island 18Blackhawk 0Brentwood 7Byron 9Clayton 3Clyde 0Concord 11Crockett 4Danville 1Discovery Bay 2El Sobrante 3Kensington 1Knightsen 1Lafayette 1Martinez 13N. Richmond 0Oakley 11Orinda 6Pacheco 4Pittsburg 0Pleasanton 0Richmond 22Rodeo 8San Pablo 8San Ramon 1Walnut Creek 1

Food Service Facility Stormwater InspectionsOf the 153 restaurants inspected by Environmental Health during PY 2008/09, forty (40) required a re-inspection due to findings of stormwater violations or, a lack of best management practices. Some of the most common types of violations were: dumpster related (47), either due to dumpsters being left open when not in use or, for leaking;

poor grease management (30), resulting in leaks to the tallow bin or pavement; wash water violations (30); and, finally, excess trash accumulation (26) around dumpsters or, debris in the vicinity of the trash enclosure.

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Some notable findings from this year’s restaurant stormwater inspections include: 7 enforcement actions, 5 Notice of Violations (issued to 3 facilities), and 2 Warnings. All of the restaurants that were issued an NOV were located in the community of Alamo, according to the following breakdown:

Restaurants Issued a Notice of Violation Courtyard Café, Alamo – Wash water discharge, outdoor washing and improper

mop water disposal, which has been rectified by a required modification of the kitchen area and installation of a dedicated mop sink.

Ha Ra Sushi, Alamo – Improper mop water disposal and dumpster left open; mismanagement resolved but, facility requires follow-up.

Xenia Bistro, Alamo – Oily grease bin, leaking dumpster needs replacement; referred to food service inspector, who brought the facility into compliance this spring, following numerous site visits.

Restaurants Issued a Warning Safeway, Rodeo – Garbage and debris around dumpster adjacent to Rodeo

Creek. This violation has been corrected. Blackhawk Grille, Blackhawk – Outside washing and grease build-up on

pavement.

We continue to have ongoing issues with one mini-mall along Grayson Creek, whose unsecured dumpsters are used by several businesses and are accessible to the public. They are left open and are often riffled through by local vagrants. CWP did not include violations at this complex since it is shared by half a dozen restaurants. Violations at this location were included in the IDCA Section of this Annual Report. Last PY 2007/08, we were informed by the property management company that they were in the process of securing permits to build a permanent, locked enclosure on the opposite side of the complex, away from the creek. Unfortunately, at the writing of this report, CWP staff continues to observe open dumpsters and trash on the ground, in their vicinity. CWP will prioritize gaining corrective action, at this location, this upcoming Permit Year.

It should be noted that many of the restaurants inspected this year had minor or no stormwater violations (106). Click on the link to view an example of a typical restaurant inspection report. Env. Health Inspectors worked with restaurants throughout unincorporated County to help bring them into compliance. During their rounds, inspectors handed out several CWP and CCCWP publications that will remind business owners and managers of the reasons “Why?” their efforts are important-- all year long:

We All Live in a Watershed (29) Restaurant BMP NPDES Fact Sheet (102) Tips Poster (89) 2009 Watershed Calendar (70)

Stormwater Inspection Interdepartmental Agreements

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This PY 2008/09, the CWP completed negotiations of the contract terms for Interdepartmental Agreements between both CWP and HazMat and CWP and Env. Health. As in previous years, both contracts include, as part of their Service Plans, requirements for performing the following inspection activities:

Routine Stormwater InspectionsPerform routine aboveground stormwater inspections at approximately 170 industrial and commercial facilities and 100 retail food facilities. Health Services staff will also work with CWP to update our inspection facility database. Inspections are to be specific to stormwater pollution prevention and will include checking outside trash, storage and work areas, along with drainage inlets and proximal storm drain systems, for evidence of spills, poor management practices, illegal dumping and/or illicit discharges. At the start of the Permit Year’s inspections, CWP will train the two inspectors from Env. Health, who will be conducting stormwater inspections, to ensure consistency with the way CWP has performed these types of restaurant inspections in the past. (Inspection sessions were held on July 23, 2008 and August 28, 2008.)

Stormwater inspectors will explain the goals and objectives of CWP’s Municipal Stormwater Discharge NPDES Permit, educate facilities about the County’s Stormwater Management and Discharge Control Ordinance (County Code §1014), and provide information on BMPs to prevent stormwater contamination. Records and documentation of each inspection will be maintained and delivered to CWP staff on a quarterly basis, along with each invoice. Click on SW-BMP Inspection Form to see an example of the document HazMat uses to record their inspection results and give to the inspected facility. The backside lists practical BMPs they can employ around their sites. Click on Env. Health SW inspection Form for an example of the document used by Env. Health’s Inspectors for food service facility inspections.

Each year before inspections begin, CWP staff will work with HazMat and Env. Health Inspectors to come up with a subset of facilities to inspect, from our industrial and commercial facility database, HSDROUT. Facilities will be prioritized according to their potential to pollute stormwater. Food service facilities will be selected based on the date they were last inspected, with less recently inspected facilities given priority.

Follow-up Inspections with Enforcement ActionOur current Service Plans included a clause to allow follow-up inspections, or re-inspections, at an estimated 13 industrial and commercial facilities and 33 retail food service facilities to confirm that corrective action measures have been taken. Data collected this PY 2008/09 confirmed in future contracts, the number of allowed re-inspections can be considerably reduced. This year, inspectors returned to a total of 145 industrial and commercial facilities and 153 restaurants.

Enforcement action will be taken against those businesses that have been inspected three times (for the initial inspection and two re-inspections) and continue to fail to implement the BMPs necessary for compliance. CWP’s enforcement action typically begins with NOV letters and can be expanded to include legal action, through the District Attorney’s Office, Environmental Crimes Unit, which has direct, as well as

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indirect, authority to enforce our County’s Stormwater Ordinance Section 1014. This is the only ordinance code provision that gives the DA direct authority to prosecute misdemeanor violations of an ordinance.

The DA also commonly prosecutes violations of State statutes having sole authority to prosecute Penal Code and Water Code violations that may also be implicated when there are stormwater violations.  The DA also has civil penalty authority under the Business and Professions Code Section(s) 17200 and 17206, which they frequently use to prosecute businesses who violate the ordinance and other State law pollution provisions. CWP will also elevate recalcitrant or chronic dischargers to the attention of the State to seek administrative penalty assistance by the Regional Water Quality Control Boards.

Technical AssistanceUnder our existing Service Plans, HazMat provides technical assistance to the industries and commercial businesses regarding compliance with the General Industrial Activities Stormwater (NPDES) permit, development of SWPPPs and guidance about their bi-annual, self-monitoring and stormwater sampling requirements. Both, HazMat and Env. Health, will provide suggestions for BMPs that will allow facilities to remain in compliance with the County’s Stormwater Management and Discharge Control Ordinance (County Code §1014), our Municipal Stormwater Discharge NPDES Permit, as well as other applicable local stormwater and clean water regulations. See The Haz Mat Recorder’s First Quarter 2009 Newsletter for an article about ‘Stormwater Discharges’ aimed at providing the regulated business community guidance about “when” they have to file an NOI (and its associated requirements of an annual fee), preparation of a SWPPP and, the submission of 2 run-off samples taken during the rainy season.

General Stormwater Pollution Prevention (SWPPP) ActivitiesPerform administrative, management and training activities necessary for the implementation of the CWP stormwater pollution prevention objectives. Tasks will include: training of inspectors, design of forms, program meetings with CWP staff, attending CCCWP Industrial Commercial Advisory Committee meetings, bi-annual IND/COMM Program workshops, research topics of special concern, and other coordination and training events with CWP, CCCWP, sanitary districts/Publicly Owned Treatment Works(POTW), and inspectors from other jurisdictions.

At the writing of this Annual Report, both of our Interdepartmental Agreements have expired. CWP hopes the current budget situation is resolved so that we can revise our Service Plans and draw up new contracts for PY 2009/10. This is the Inspection Billing Summary for PY 2008/09 inspection activities by HazMat and Env. Health which will be useful for reallocating funding for future Service Plans’ activities, in a manner that will make the most of our INSP Program budget.

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TrainingThis PY 2008/09, two (2) CWP staff and several HazMat and Env. Health Inspectors attended a Commercial and Industrial Stormwater Inspection Training Workshop on October 9, 2008 at the Centre of Concord Facility, sponsored by the Contra Costa Clean Water Program. The agenda included an overview of the Municipal Regional Permit Inspection Requirements, shared information about the City of Walnut Creek’s After-Hours Inspection Program and the City of San Pablo’s Enforcement Program. The District Attorney presented on current enforcement cases of local businesses engaged in polluting practices. The workshop also included various “How to Inspect” segments for pesticide operations, provided by the Tru-Green Company and pool facilities. The training offered a “hands-on” afternoon site visit to the Concord Community Pool’s facility maintenance area for attendees to have an opportunity to network and observe BMPs “in action”.

CWP, our Health Services Stormwater Inspectors and local sanitary districts also participated in CCCWP’s IND/COMM Subcommittee’s quarterly meetings where we networked with other stormwater inspection staff, from other municipalities and discussed training and outreach, including the annual workshop. The PY 2008/09, we developed outreach materials, such as the Trash and Autobody brochures to assist stormwater inspectors in conveying proper BMPs. We planned for the proposed additional requirements of the MRP and received updates on the latest stormwater regulations.

Restaurant and Pools BMPs for Plan Check DocumentsAs part of the Interdepartmental Agreement with CWP, County Health Services Department, Environmental Health Division disseminated clean water requirements for applications with plan-check documents for new and remodeled pools and food service facilities, which are handled by their office. A rudimentary document was constructed by CWP, which listed BMPs for NPDES Compliance for Pools and Restaurants, Env. Health staff gave this document out to over 95 applications this PY2008/09 from all jurisdictions, throughout Contra Costa County, because they lacked any other Clean Water handouts or brochures and, were eager to include pollution-prevention information with their permits.

This spring, work began to create two professional publications that separate the above document into booklets specific to NPDES Compliance for Pools and NPDES Compliance for Restaurants. Both list storm water BMPs according to categories: General Operational and General Site Design and Type-Specific (Pool or Restaurant) Operational and/or Type-Specific Site Design. Useful feedback for improving these draft versions has been received from Env. Health staff and from CWP management. Due to recent budget uncertainties, this project is “on hold”, since future restaurant inspections may be performed in-house by CWP staff and CWP may suspend its contractual agreement with Heath Services Department for their inspection services. CWP hopes to continue working at producing these useful publications in the near future, as there is still a need for disseminating this information, whether it is done via Environmental Health or, by CWP staff during inspections or by mass-mailings.

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Modifications:

None.

Fiscal Year 2009/2010 Goals:

1. Update and reorganize HSDROUT and consider changing the format from Excel to an Access database. NOI facility information needs to be updated from the PY 2008/09 inspection verification of Waste Discharge ID #s. Business addresses need to be researched and updated after receiving 135 ‘Return to Sender’ notices from the “trash” brochure mailing.

2. Create a Notice of Violation for Stormwater Discharges that will allow CWP to cite, for the dollar amount listed in our Government Ordinance Section 36900(b). CWP is in need of more enforcement tools for gaining compliance from chronic and recalcitrant dischargers. 

3. Complete the inspection of the remaining 107 food service facilities that will be inspected in PY 2009/10 in an efficient and cost-effective manner.

4. Revise our Service Plans with HazMat and Env. Health and draw-up new contracts for PY 2009/10 inspections by these agencies. Discuss possibility of adding dog kennels and horse boarding facilities into the inspection contract with Env. Health. Ensure all inspectors conducting stormwater inspections are familiar with the Service Plans and are aware of non-payment for response vehicles and overtime.

5. Work with HazMat to redesign their stormwater inspection forms to include more space for comments and to add boxes to make the distinction between issuance of Notice of Violations vs. Warning Notices.

6. Prioritize gaining corrective action for ongoing open dumpster issues, with a focus on problem areas.

7. Work with HazMat to ensure all violations given NOVs or had Warnings issued have been followed-up on and/or re-inspected.

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INSPECTION ACTIVITIES – QUANTITATIVE RESULTS

Description Industrial/ NOI

Commercial Misc.(2) Total

Restaurants Vehicle Service Facility

Other(1)

INSPECTION SUMMARY

Number of Facilities scheduled for Inspection

100 170 270

Number of Facilities Inspected 87 153 16 32 10 297

Number of Routine Facility Inspections 80 112 14 30 10 246

Number of Priority Facility Inspections 4 0 2 2 0 8

Number of Call-out Inspections 2 0 0 0 0 8

Number of Follow up Inspections 3 40 0 0 0 43

ENFORCEMENT

Total Number of Enforcement Actions 11 7 1 0 0 19

Number of Notices of Violation (NOV) Issued 5 5 1 0 0 11

Number of Warning/Pollutant Exposure Notices (WN/PEN) issued

6 2 0 0 0 8

Number of Fines Levied 0 0 0 0 0 0

Number of Referrals 0 0 0 0 0 0

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Description Industrial/ NOI

Commercial Misc.(2) Total

Restaurants Vehicle Service Facility

Other(1)

BUSINESS EDUCATION & OUTREACH

Number of Educational Materials Distributed 1 290 0 0 0 291

INSPECTOR TRAINING

Number of Inspector Training Sessions 1

Number of Inspectors Trained 14

(1) Nursery, golf course, grocery, retail gas outlet.(2) For consistency, includes non-NOI Marinas.

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