INSPECTION ACTIVITIES
INSPECTION ACTIVITIES
QUALITATIVE RESULTS
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Municipality: City of Orinda Permit Year: (2007/2008)
Introduction:
The City of Orinda (the City) contracts with the Central Contra Costa Sanitary District (CCCSD) staff to conduct commercial inspections for us in conjunction with their sanitary sewer pre-treatment inspections. This long-term collaboration with CCCSD is augmented by the Clean Water Program's commitment to ensure that it runs smoothly and productively. The Program frequently discusses the Inspection Activities portion of our permit requirements and leads meetings with CCCSD and those municipalities that use their services. CCCSD represents Orinda in the Program's Commercial/Industrial Ad Hoc Workgroup meetings as well as participates in the Program's annual workshop for stormwater inspectors.
When needed, the City requests call-out inspections to respond to illicit discharges. The primary inspector for this program is Colleen Henry with CCCSD (925-229-7347).
Our goal last year for the Inspection Program was to continue the successful education of business owners, managers, and employees and increased compliance with our discharge standards. We have informed those in the commercial business sector that we will not hesitate to take enforcement action for poor practices that result in real and potential discharges to the storm drains. This year, 18 businesses were informed of this policy as part of the Inspection Program.
The CCCSD inspector and the City's Stormwater Program Manager have an excellent working relationship that ensures compliance with the Inspection Activities Performance Standards throughout the year. The City has no industrial facilities so CCCSD focuses solely on commercial business-related BMPs.
On behalf of all co-permittees, the Program worked to update the Model Commercial/Industrial Inspection Plan. A detailed discussion is provided in Volume I, Section 6 regarding this ongoing activity. Work has also been conducted by the Commercial/Industrial Ad Hoc Work Group, including preparation of an Auto Shop poster.
The City's business inspection program focuses on gasoline service stations, auto repair facilities, restaurants, dry cleaners, the grocery store, the nursery, the private golf course, and pool clubs. Minimizing potential stormwater pollution sources through inspections, educational outreach, follow-up visits, and enforcement actions when necessary, has benefited Orinda's creeks and the quality of the water entering San
Pablo Reservoir. No businesses within the City of Orinda drain to Moraga Creek and thus have no potential to impact the quality of the water entering Upper San Leandro Reservoir.
Implementation & Evaluation:
Industrial and Commercial Business Inspection Program
The Stormwater Program Manager reviewed the Commercial Business Inspection Plan that was based on the model plan developed by the Program. No revisions were determined to be needed, and as such, was not revised this year. Colleen Henry, the CCCSD inspector responsible for inspecting businesses in the City, continues to work off of this updated Plan (Attachment IN-2 in the 2004-2005 Annual Report). This Inspection Plan describes steps to be taken by the inspector in order to conduct effective inspections of commercial businesses, especially those that have a high potential to pollute stormwater.
The priority businesses inspected this year included food service facilities and dry cleaners as well as the local golf course and nursery. An assisted living center, a beverages grocery store, a private school and a service/gasoline station were also inspected. Fifteen businesses are targeted for inspected each year but CCCSD actually inspected 18 (plus one residence), several of which were re-inspected one or more times. Vehicle service facilities are inspected on a two to three-year basis and fast food establishments are inspected more often, every year or two. A summary of the annual inspection performed is included as Attachment IN-1.
The only Notice of Intent (NOI) facility in Orinda is the East Bay Municipal Utility District’s (EMBUD) water filter plant. While Susan Suzuki of EBMUD's Environmental Compliance department is responsible for inspecting this plant each year, the CCCSD inspector performed an inspection of the facility last year (see Attachments IN-2 and IN-3 in the FY 2005-2006 Annual Report). EBMUD conducts an annual field audit of the filter plant (usually in January), conducts annual training to the water treatment plant operators on environmental responsibilities, and inspects the underground storage tanks monthly. In addition, the Orinda plant was certified as a Green Business in December 2005.
Both CCCSD and the City have enforcement procedures in place to address illicit discharges to the storm drain system. These enforcement procedures were summarized on pages INSP-3 to INSP-4 of the Inspection section of the FY 2005-2006 Annual Report.
As with last year, no enforcement action was necessary this year. No Warning Notices or Notices of Violation were issued.
The table and chart below summarize the rate of enforcement action taken during commercial business inspections over the past five fiscal years. As can be seen, there was a continued decrease in the number of enforcement action taken to last year’s and this year’s rate of no enforcement action being necessary.
2007-2008 / 18 / 0 / 0 / 0/18 (0 %)
2006-2007 / 19 / 0 / 0 / 0/19 (0 %)
2005-2006 / 17 / 2 / 0 / 2/17 (12 %)
2004-2005 / 18 / 1 / 3 / 4/18 (22 %)
2003-2004 / 22 / 1 / 6 / 7/18 (39 %)
The Stormwater Program Manager met with Elisa Wilfong of the Program and Tim Potter of CCCSD in September 2007 to discuss the status of the inspection program and goals for expanding it. It was agreed to continue with the more frequent inspection of fast food restaurants and food service facilities in general, as based on previous year inspections, these are the facilities that required enforcement action. The secondary focus would be dry cleaners. It was also discussed that the private swim clubs would be the focus of the next fiscal year’s inspections.
CCCSD inspectors are thoroughly trained by their agency and other agencies including EPA and CWEA, as noted in the Quantitative Results section below. CCCSD inspectors attended the following conferences/symposiums:
§ CWEA P3S Annual Conference – 3 staff attended a total of 5 days
§ CWEA Northern Regional Training Conference – 2 staff attended a total of days
§ Western Regional Pollution Prevention Conference – 1 staff attended a total of 3 days
§ CalEPA Cross-Media Enforcement Symposium – 1 staff attended a total of 1 day
The absence of enforcement actions taken this year demonstrates that Orinda is achieving its goal of educating business managers and employees to effectively minimize and prevent illicit discharges to the storm drain system and creeks. We have observed that most commercial business employees have been trained in the laws and regulations that pertain to their operations and are willing to learn and correct their actions. In fact, one of the service stations that was inspected this year was awarded a Pollution Prevention Award by CCCSD (Attachment IN-2).
Due to the fact that there are relatively few commercial businesses, and only one NOI facility that is not inspected by CCCSD (the EBMUD's filter plant) in Orinda that have the potential to affect the quality of stormwater, it is unnecessary to formally update the list of inspected facilities using lists from such resources as inter/intra-agency referrals, the fire or police departments, business licenses, or utility bills. The Stormwater
Program Manager and the CCCSD inspector are familiar with the practices of each restaurant, each vehicle service facility, the only private golf course, the only nursery and the only supermarket.
Education of commercial and other businesses is a major component of business inspections. Although the City has only 15 targeted businesses each year, the inspectors distributed approximately 43 educational outreach materials, developed by CCCSD and the CWP, pertaining to the type of business (e.g. restaurant, gas station, or vehicle service facility). In general, 5 items of information material are handed out during Vehicle Service inspections, and 3 items are handed out at Food Service inspections; for other inspection types, at least 1 item of information material is distributed. These materials explain the need to prevent pollution and that describe BMPs to employ. The CWP commercial business brochures are included in Volume I, Section 6.
Last fiscal year, the City renewed its contract with the CCCSD for business inspections. Attachment IN-5 of the 2006/2007 Annual Report is a copy of the executed Second Amendment to the Inspection Agreement among the Contra Costa County Flood and Water Conservation District (on behalf of the Contra Costa Clean Water Program), CCCSD, the Delta Diablo Sanitation District, and EBMUD. The 1986 Joint Exercise of Powers Agreement with the Contra Costa County Building Inspection Department is included in Attachment PP of the FY 2001-2002 Annual Report.
Modifications:
No modifications to the Performance Standards were necessary.
Fiscal Year 2008/2009 Goals:
The goals for the 2008-2009 fiscal year are pending issuance of the Municipal Regional Permit.
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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 / 0 / 7 / 1 / 3 / 4 / 15
Number of Facilities Inspected / 0 / 10 / 1 / 3 / 5 / 19
Number of Routine Facility Inspections / 0 / 8 / 1 / 3 / 4 / 16
Number of Priority Facility Inspections / 0 / 0 / 0 / 0 / 0 / 0
Number of Call-out Inspections / 0 / 1 / 0 / 0 / 1 / 2
Number of Follow up Inspections / 0 / 1 / 0 / 0 / 0 / 1
ENFORCEMENT
Total Number of Enforcement Actions / 0 / 0 / 0 / 0 / 0 / 0
Number of Notices of Violation (NOV) Issued / 0 / 0 / 0 / 0 / 0 / 0
Number of Warning/Pollutant Exposure Notices (WN/PEN) issued / 0 / 0 / 0 / 0 / 0 / 0
Number of Fines Levied / 0 / 0 / 0 / 0 / 0 / 0
Number of Referrals / 0 / 0 / 0 / 0 / 0 / 0
BUSINESS EDUCATION & OUTREACH
Number of Educational Materials Distributed / 0 / 30 / 5 / 3 / 5 / 43
INSPECTOR TRAINING
Number of Inspector Training Sessions
/ 4Number of Inspectors Trained
/ 1(1) Nursery, golf course, grocery, retail gas outlet.
(2) Mobile surface cleaners, corporation yards, contractor’s yards, call out to residential.
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