Inspection Activities

INSPECTION ACTIVITIES

QUALITATIVE RESULTS

Municipality: City of LafayettePermit Year: (2008/2009)

Introduction:

Inspection of businesses and investigation of spill incidents in the City of Lafayette is through coordination with the Contra Costa Clean Water Program, the Central Contra Costa Sanitary District(CCCSD) and the Contra Costa County Health Department, Hazardous Materials Program, which provides reports on each spill incident to the City. (See the Program’s Volume I of the Annual Report for agreements with these agencies.) The City’s role is to alert the appropriate responders and contain the situation until the arrival of a HazMat team, if needed.

As requested by the Regional Water Quality Control Board, a revised model of activities response plan has been developed with the Contra Costa Clean Water Program. Training and spill procedures have been refined during this fiscal year and will continue to be evaluated for their effectiveness.

Inspectors from the Health Department and the City are familiar with the existing spill response and clean-up programs that cover the City’s jurisdiction, and coordinate illicit discharge program activities with these existing programs. Through internal communication and public education, the use of “911" is encouraged to report large or hazardous spills. Inspectors from both agencies ensure that adequate spill response supplies are available.

Inspectors investigate spill reports and/or complaints within their jurisdiction and record their activities. An Incident, Notification, and Complaint Report Form (See Volume I, Section 7) containing information about spill incidents is used by the Health Department so that source identification and follow-up actions can be conducted. To date, no spills have entered the City’s storm drain system from neighboring jurisdictions; however, if a spill does enter from another jurisdiction, the procedure established in the Program’s agreements with the Contra Costa Health Department, Hazardous Material Program will be followed. (See the Program’s Volume I.)

Implementation & Evaluation:

Industrial and Commercial Business Inspection Plan

The City of Lafayette utilizes the Model Industrial & Commercial Business Inspection Plan (See the Program’s Volume I, Section 6.) developed with the Contra Costa Clean Water Program and the CCCSD. The City’s plan has been updated to reflect the new

model developed at the Program level. The plan outlines specific steps CCCSD will take to conduct effective facility inspections. The written inspection plan consists ofa review of the types of businesses within the agency’s jurisdiction that account for the variability of business types, complexity, and number; a listing by category of business types that have greater potential to cause stormwater pollution;a target list of businesses or business types that include the number of facilities that will be inspected during the fiscal year; andas appropriate, a summary of efforts to coordinate inter/intra-agency issues.

As requested by the Regional Water Quality Control Board, a revised model of activities response plan has been developed with assistance of the Contra Costa Clean Water Program staff. Emergency and environmental management phone numbers and flowcharts indicating guidance and contact numbers to report spills are included. City staff is using the updated documents to direct calls to Public Works and other appropriate agencies as necessary. Communication and documents have also been provided to the City Police Department, Contra Costa Fire District, and Central Contra Costa Sanitary District as discussed in the illicit discharge controls activities annual report section.

The CCCSD plan requires the inspection of facilities within targeted business areas with potential for impacting stormwater quality at least once in a five-year period. Priority facilities as defined in the inspection plan are inspected at least once per year. Scheduled inspections of businesses by trained experienced professionals have been extremely helpful in uncovering stormwater pollution violations and in reducing violations.

Targeted businesses this year included vehicle repair businesses, restaurants and food service establishments including supermarkets, and commercial nurseries.Inspections will continue to be performed by CCCSD on both a pro-active and a re-active basis. Businesses cited for violations will be inspected again in one year for compliance purposes. When re-inspections indicate further enforcement is necessary, CCCSD will notify the City. Our goal to revise and adopt the City’s stormwater pollution prevention ordinance has been met and the document has been provided to City inspectors and City staff for use and enforcement.

See Attachment IN-1 for a summary of inspections within the City during the 2008/2009year. A total of 38 inspections were performed by the CCCSD in the City of Lafayette. The annual number of scheduled inspections for this year was 32. The number of priority inspections performed this year was 53. 9 follow-up inspections and 12 call-out inspections were also performed in order to achieve desired pollution reducing results and compliance. 10enforcement actions were taken including6 notice of violations and 4 warning notices. Ten of these enforcements actions were for food service businesses and one was at a gas station. The City will continue follow-up regarding a discharge of liquids and business clean up and storage practices at 1 pool company business located on Mt. Diablo Boulevard. See Program detail for samples of educational materials distributed during inspections.

Facility inspectors are adequately trained in the knowledge and skills necessary to conduct effective stormwater inspections with coordination from the Contra Costa Clean Water Program. This includes: stormwater regulations and requirements (including the agency’s ordinance, municipal stormwater permit, and the industrial stormwater general permit); the impacts of non-stormwater discharges to the storm drains; inspection techniques and procedures; follow-up and enforcement procedures; and stormwater BMPs.

Inspectors obtain ongoing training to support inspection activities and to continue to improve program implementation. Inspector(s) representing the agency attended the Program’s inspector training workshops and the Program annually assesses inspector-training needs. See the Quantitative Results Table at the end of this section for the number of training sessions and the number of inspectors trained. See Volume 1 for a discussion of the training sessions provided by the Clean Water Program as well as a description and evaluation of inspector training activities.

In addition to inspection activities, outreach to inform facility representatives about appropriate stormwater BMP information was conducted concurrently with the inspection process. This included responding to telephone calls from business representatives as well as distributing BMP information to businesses, as appropriate.

The City’s and the Program’s additional outreach was effective in increasing the awareness of businesses to the importance of eliminating non-stormwater discharges and the knowledge necessary for the City’s businesses to achieve reduction or elimination of those discharges.

Conducting an Inspection, Evaluating Facility Compliance, and Enforcement

Complaints or referrals from agencies concerning a facility were responded to by either interviewing the caller concerning the specific nature of the discharge, inspecting the site, locating any non-stormwater discharges to the storm drains, informing the facility representative of appropriate stormwater BMPs, and/or conducting follow-up measures to ensure compliance was achieved.

Prior to inspections, the inspectors reviewed existing information on the site and its regulatory history. They reviewed the facility layout to locate the storm drain system and/or stormwater drainage path, storage areas, process areas, vehicle and heavy equipment wash and maintenance areas, and stormwater sampling locations, if applicable. They notified the facility prior to the inspection at their own discretion.

Inspections for potential discharges of pollutants included, but were not limited to, the following areas and activities:

Outdoor process/manufacturing areas,
Outdoor material storage areas,
Outdoor waste storage and disposal areas,
Outdoor vehicle and heavy equipment storage and maintenance areas,

Outdoor parking areas and access roads,
Rooftop down spouts,
Outdoor wash areas,
Outdoor drainage from indoor areas, and
Stormwater conveyance system maintenance and emergency response practices.

Inspections were documented on the stormwater facility inspection forms. (See Volume 1, Section 6 for an example of a completed copy of the form.)

The inspectors determine if the facility is in compliance with the City’s stormwater ordinance (i.e., there are no un-permitted non-stormwater discharges, and pollutant exposure to rain is minimized). Inspectors also use the facility’s SWPPP, if available, as a tool in assessing the facility’s stormwater pollution control activities, but this does not imply a review or approval of the adequacy of the SWPPP.

Inspectors then identify and inform the facility representative about problems and violation(s), if applicable. A schedule for correcting problems identified during the inspection and a means for verifying its implementation is coordinated between the inspector and the facility representative. This information is also noted on the inspection form. (See Volume I, Section 6 for examples of Warning Notices and Notices of Violation.)

Inspectors prioritize facilities for re-inspection as necessary. If a problem is identified during the inspection, inspectors perform a follow-up inspection or initiate a self-certification process where the facility representative certifies in writing that the problem has been removed or corrected within the time specified by the inspector. Inspectors provided facility representatives with appropriate BMP information, education materials, and inter/intra-agency referrals, as appropriate. (See Volume I.)

Inspectors begin enforcement procedures, if appropriate, immediately. The City conducts the enforcement activities per the City’s ordinance and reports these activities as set forth in the Inspection Plan. The number of inspections done and the enforcement and follow-up actions taken are in the Quantitative Results Table at the end of this section. These enforcement procedures have proven effective in reducing the number of violations of the City’s stormwater ordinance.

Enforcement Referral from Contractor POTW, Central Contra Costa Sanitary District (CCCSD) Agency

Several enforcement notices have been given to a pool company located on Mt. Diablo Boulevard. CCCSD has followed up with the company again this past year and have notified them regarding runoff from their property and regarding safe storage practices for their chemicals and wash and waste materials. The City and CCSD will continue monitoring the property to be sure they are not violating the City’s storm water ordinance in the future.

Reporting

The annual review and assessment of the City’s Inspection Plan are summarized here and in previous portions of the Annual Report. Scheduled inspections of businesses by trained, experienced professionals have been extremely helpful and effective in uncovering minor stormwater pollution violations. Follow-up inspections of businesses where there have been problems ensure that compliance has been achieved, and results in ongoing education of violators. The inspectors are good at working with businesses to reach a solution that is reasonable and achieves the desired results. The inspection results for the last fiscal year are summarized in the Quantitative Results Table at the end of the section.

The one NOI facility under the jurisdiction of the City was inspected in 2005. The business is Diamond K Supply, a landscape company. Colleen Henry, inspector, reported no violations and excellent business practices at the site.

Volume I of the Contra Costa Clean Water Program Group Activities included last year, and will include this year, a copy of the executed inspection agreement between the Central Contra Costa Sanitary District and the Contra Costa Flood Control District. Also in Volume I are Definitions of Terms for Reporting/Tracking of inspection information, the fiscal year report results, examples of warning notices, notices of violation, and numerous samples of BMP fact sheets distributed to those businesses inspected throughout the year.

Modifications:

There have been no new or modified INSP Performance Standards this year, nor are any anticipated to be added or modified next year.

Fiscal Year 2009/2010 Goals:

The City’s goals for the next fiscal year include:

1)Continue joint efforts with Central Contra Costa Sanitary District for inspections of businesses and training of inspectors.

2)Provide and evaluate enforcement data from contractor POTW agency. Highlight any enforcement referrals and include whether the City pursued further enforcement.

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 / 32
Number of Facilities Inspected / 19 / 6 / 9 / 4 / 38
Number of Routine Facility Inspections / 53
Number of Priority Facility Inspections / 32
Number of Call-out Inspections / 3 / 3 / 1 / 5 / 12
Number of Follow up Inspections / 4 / 2 / 3 / 9
ENFORCEMENT
Total Number of Enforcement Actions / 3 / 4 / 3 / 10
Number of Notices of Violation (NOV) Issued / 1 / 3 / 2 / 6
Number of Warning/Pollutant Exposure Notices (WN/PEN) issued / 2 / 1 / 1 / 4
Number of Fines Levied / 0
Number of Referrals / 1 / 1
BUSINESS EDUCATION & OUTREACH
Number of Educational Materials Distributed / Educational materials distributed by CCCSD at inspections. City literature available throughout the year at several locations and events.
INSPECTOR TRAINING

Number of Inspector Training Sessions

/ 1

Number of Inspectors Trained

/ 5

(1)Nursery, golf course, grocery, retail gas outlet.

(2)Mobile surface cleaners, corporation yards, contractor’s yards, call out to residential.

INSP - 1