SECTION A-9, EXISTING DEVELOPMENT
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-9-9
A-9.2 Commercial Program
The program described in this section was developed pursuant to Section X of the Santa Ana Order and Section 9.0 of the DAMP
A-9.2.1 Pollution Prevention and Program Administration The City of Yorba Linda’s Commercial Component includes specifications for pollutionprevention methods for commercial areas and activities located within the City. Specific pollution prevention practices that are generally recognized for each Discharger’s business, or for that Discharger’s activity, as being effective and economically advantageous, were selected by the City (see Section A-9.2.4). The City through an inspection program summarized in Section A-9.2.5 will verify implementation of pollution-prevention methods by commercial facilities. Inspectors will use a checklist for their inspections, which will also include appropriate pollution-prevention methods for commercial facilities.
The City will implement the Commercial Program through various City departments. These departments, contacts, and principal responsibilities are summarized below.
Figure A-9.2
Commercial Program Organization Chart
Regional Board
City NPDES Program Management
Jevee Tagarao
Assistant Engineer
Orange County Health
Care Agency
Business License Department
Alexandra Karpetian
Business License Clerk
Public Works Department
Armando Jaime
Public Works Superintendent
Code Enforcement
Mary Lewis
Senior Community Preservation Officer
Fire Department
OCFA
SECTION A-9, EXISTING DEVELOPMENT
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-9-10
A-9.2.2 Implementation
The following outlines and describes City departments and staff that are responsible for implementation of the commercial program.
Public Works Department
Armando Jaime
Public Works Superintendent
(714) 961-7189
Responsible for the operation and maintenance of flood control facilities. Field crews receive training to identify commercial facilities and activities that have potential to threaten receiving water quality.
Business License Department
Alexandra Karpetian
Business License Clerk
(714) 961-7145
Staff oversees business development within the City and assists businesses in complying with the commercial program.
Code Enforcement
Mary Lewis
Senior Community Preservation Officer
(714) 961-7133
Code enforcement inspectors are responsible for inspecting commercial facilities for compliance with commercial program and City codes.
Public Agencies
In addition to the City Departments described, the City relies on certain public agencies for successful implementation of the commercial program.
Orange County Health Care Agency
Environmental Health
Certified Unified Program Agency (CUPA)
The Environmental Health Division of the Orange County Health Care Agency inspects businesses within the City that generate hazardous waste for compliance with State and Federal regulations. Proper storage and care of hazardous waste is an important component of pollutant source control.
SECTION A-9, EXISTING DEVELOPMENT
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-9-11
Orange County Health Care Agency
Environmental Health
Food Facility Inspection
Conducts inspections of all food facilities within the City as described in Section 9.7 of the DAMP.
Orange County Fire Authority
Inspects businesses within the City for compliance with the Uniform Fire Code and responds to 911 calls that may involve discharges at commercial facilities such as, spills, chemical emergencies, accidents, etc. Refers problems associated with non-storm water discharges to City for enforcement.
A-9.2.3 Source Identification
The City of Yorba Linda is required to develop, and update annually, a watershed-based inventory of commercial sites within its jurisdiction, regardless of site ownership. The process for conducting the inventory is explained in the Section 9.4.2 of the DAMP. The components that comprise the inventory include:
All commercial facilities listed in Table 9.2 from Section 9.4.2 of the DAMP that are located within the City’s jurisdiction.
Watersheds where each commercial facility is located. Identified potential pollutants and activities with the potential to discharge pollutants. Identified commercial discharges into, or adjacent to, an Area of Special Biological Significance (ASBS).
The City’s inventory database includes the following information about each identified commercial facility within the City’s jurisdiction:
Business Name
Physical Address Information
Mailing Address Information
SIC Code
Industrial-Specific Information
Commercial-Specific Information
Watershed
Local Licensing/Permits
Potential pollutants
Adjacent to and/or discharge to ESA/ASBS
Pollutants of concern into an ESA
Comments/Notes
The current inventory of commercial facilities is provided in Exhibit A-9.I.
SECTION A-9, EXISTING DEVELOPMENT
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-9-12
A-9.2.4 Prioritization for Inspection
To comply with the permit inspection requirements, the City of Yorba Linda prioritized commercial facilities and sources as high, medium, and low priority, based on their respective threat to water quality. A classification of High Priority indicates that the facility contains a site or sources with a high potential threat to water quality. Because the permit requires that high threat prioritized sites and sources be inspected once per permit cycle, the threat prioritization will also be updated once per permit cycle. The prioritization process, which is consistent with permit requirements as outlined in Section 9.4.3 of the DAMP, consisted of assigning a score to each facility based on the following factors:
Type of Commercial Activity
Magnitude of Commercial Activity
Location of Commercial
Potential for Discharge of Pollutants to the MS4
History of Un-Authorized Storm Water Discharge
Commercial facilities that received a score of greater than or equal to 20 were ranked as High Priority, those with a score below 20 and greater than 10 were ranked as Medium Priority, and those with a score less than or equal to 10 were ranked as low priority.
Commercial sites/sources classified as High Priority for inspections are required to receive facility inspections at least once per permit cycle (5 years).
A-9.2.5 BMP Implementation
The City of Yorba Linda has designated a minimum set of activity-specific BMPs for commercial facilities, as set forth in DAMP Section 9.4 and modified according to City requirements. These BMP fact sheets are presented in Exhibit A-9.II. The City selected BMPs that are appropriate to prevent or mitigate pollution generated from the specific activities at each site.
Table A-9. 5
Commercial BMPs
Activities/Sources BMP Fact Sheets
Automobile mechanical repair,
maintenance, fueling, or cleaning
IC18. VEHICLE AND EQUIPMENT FUELING
IC19. VEHICLE AND EQUIPMENT
MAINTENANCE AND REPAIR
IC20. VEHICLE AND EQUIPMENT WASHING
AND STEAM CLEANING
Boat mechanical repair, maintenance,
fueling, or cleaning
IC13. OVER WATER ACTIVITIES
IC18. VEHICLE AND EQUIPMENT FUELING
IC19. VEHICLE AND EQUIPMENT
MAINTENANCE AND REPAIR
IC20. VEHICLE AND EQUIPMENT WASHING
AND STEAM CLEANING
Equipment repair, maintenance, fueling, IC18. VEHICLE AND EQUIPMENT FUELING
SECTION A-9, EXISTING DEVELOPMENT
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-9-13
Activities/Sources BMP Fact Sheets
or cleaning IC19. VEHICLE AND EQUIPMENT
MAINTENANCE AND REPAIR
IC20. VEHICLE AND EQUIPMENT WASHING
AND STEAM CLEANING
Automobile and other vehicle body
repair or painting
IC14. PAINTING, FINISHING, AND COATINGS
OF VEHICLES, BOATS, BUILDINGS, AND
EQUIPMENT
IC19. VEHICLE AND EQUIPMENT
MAINTENANCE AND REPAIR
Mobile automobile or other vehicle washing IC20. VEHICLE AND EQUIPMENT WASHING
AND STEAM CLEANING
Automobile (or other vehicle) parking
lots and storage facilities
IC15. PARKING AND STORAGE AREA
MAINTENANCE
Retail or wholesale fueling IC18. VEHICLE AND EQUIPMENT FUELING Pest control services IC7. LANDSCAPE MAINTENANCE
IC21. WASTE HANDLING AND DISPOSAL
Eating or drinking establishments IC22. EATING AND DRINKING
ESTABLISHMENTS
Mobile carpet, drape or furniture cleaning IC4. CARPET CLEANING Cement mixing or cutting IC5. CONCRETE AND ASPHALT PRODUCTION,
APPLICATION, AND CUTTING
Masonry IC5. CONCRETE AND ASPHALT
PRODUCTION, APPLICATION, AND
CUTTING
Building Maintenance and Light Construction IC3. BUILDING MAINTENANCE IC5. CONCRETE AND ASPHALT
PRODUCTION, APPLICATION, AND
CUTTING
IC6. CONTAMINATED OR ERODIBLE SURFACES
AREAS
Outdoor Activities IC6. CONTAMINATED OR ERODIBLE SURFACES AREAS
IC9. OUTDOOR DRAINAGE FROM INDOOR
AREAS
IC10. OUTDOOR LOADING/UNLOADING OF
MATERIALS
IC11. OUTDOOR PROCESS EQUIPMENT
OPERATIONS AND MAINTENANCE
IC12. OUTDOOR STORAGE OF RAW MATERIALS,
PRODUCTS, AND CONTAINERS
Painting and coating IC14. PAINTING, FINISHING, AND COATINGS
OF VEHICLES, BOATS, BUILDINGS, AND
EQUIPMENT
Botanical or zoological gardens and exhibits IC2. ANIMAL HANDLING AREAS IC7. LANDSCAPE MAINTENANCE
IC8. NURSERIES AND GREENHOUSES
Landscaping IC7. LANDSCAPE MAINTENANCE
SECTION A-9, EXISTING DEVELOPMENT
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-9-14
Activities/Sources BMP Fact Sheets
Nurseries and greenhouses IC8. NURSERIES AND GREENHOUSES Golf courses, parks and other recreational
areas/facilities
IC6. CONTAMINATED OR ERODIBLE SURFACES
AREAS
IC7. LANDSCAPE MAINTENANCE
Cemeteries IC7. LANDSCAPE MAINTENANCE
Pool and fountain cleaning IC16. POOL AND FOUNTAIN CLEANING Marinas IC13. OVER WATER ACTIVITIES
Port-a-Potty servicing IC21. WASTE HANDLING AND DISPOSAL The City requires the implementation of the designated BMPs at each commercial facility based on site-specific conditions in order to limit that facility’s impact upon receiving water quality. If particular BMPs are infeasible at any specific site, other equivalent BMPs will be implemented.
A-9.2.6 Inspection and Enforcement
A-9.2.6.1 Inspection
Inspection frequencies for commercial facilities are based on permit requirements and the priority ranking assigned to each facility in Section A-9.2.3. A summary of required inspection frequencies based on priority ranking is shown in Table A-9.6. In addition to the inspection frequencies described in Table A-9. 6, the City of Yorba Linda will also investigate all complaints of illegal discharges from commercial facilities made by the public or by another agency or those violations arising from the results of dry-weather field screening or analytical monitoring program. In the event that a site is found to be non-compliant, inspection frequency will be increased to, at a minimum, once per month. Once a facility has been brought into compliance, an inspection frequency of once every four months will be maintained for the next calendar year following the date at which the facility is deemed to be in compliance.
Table A-9.6 – Inspection Schedule Based on Priority Ranking Priority Inspection Frequency
High Once per permit
Cycle1
Medium N/A
Low N/A
1. All facilities must be inspected at least once by July 1, 2004.
The City of Yorba Linda will inspect commercial facilities to determine if they are in compliance with ordinances and permits, to review BMP implementation, to assess BMP
SECTION A-9, EXISTING DEVELOPMENT
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-9-15
effectiveness and to verify inventory information used for facility prioritization. Such inspections include review of:
Material and waste handling and storage practices,
Pollution control BMP implementation and maintenance, and Evidence of past or present unauthorized, non-storm water discharges.
The inspection procedures and form provided in Exhibit A-9.III will be used and provides a series of questions about specific activities taking place at a facility, as well as a list of suggested corrective actions that can be implemented should a problem be found.
In general the City of Yorba Linda will conduct one of two types of inspections:
Compliance Inspections
Initial compliance inspections will be announced so that the inspector can meet with responsible facility official(s) (e.g., owner, superintendent, compliance manager, engineering consultant, etc.) in order to provide more efficient communication of the storm water requirements and inspection goals. The inspection will focus on current facility operations and activities, BMPs currently in use, and the effectiveness of those BMPs. This inspection will also focus on verifying inventory spreadsheet information and, whenever possible, provide outreach education to facility staff. All re-occurring compliance inspection will cover the same information as an initial compliance inspection, but will typically be unannounced in order to verify compliance and that BMPs are being effectively implemented.
Follow-up Inspections
For those facilities deemed to be non-compliant, the Permittee will perform compliance inspections once a month until said facilities are shown to be complaint, and then once every four months for a full calendar year after the facility achieves compliance.
Generally, these inspections will be similar to Compliance Inspections except that; a) they will focus primarily on areas where a facility was deemed to be non-compliant and b) the inspections may be announced or unannounced, depending on which course of action the Permittee deems will be most conducive to continued facility compliance.
Should an inspected site demonstrate non-compliance, the City will coordinate the notification of appropriate agencies. An incident or practice of non-compliance that requires a hazardous materials emergency response will be considered a threat to human or environmental health and will be reported to the RWQCB and to appropriate hazardous waste management agencies.
The City will provide oral notification to the RWQCB within 24 hours of the discovery of a noncompliant site meeting the criteria presented below. This will also be followed by written notification within 5 days of the discovery.
Criteria to be used to determine whether an event of non-compliance poses a threat to human or environmental health includes the following:
SECTION A-9, EXISTING DEVELOPMENT
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-9-16
The event poses a significant or imminent threat to the quality of surface or ground waters and/or their beneficial uses.
The event results in a spill or discharge of hazardous materials in excess of reportable quantities (as listed in 40 CFR Part 117 or 302).
The event results in a spill or discharge of hazardous materials requiring a hazardous materials emergency response (see Section 10 of the DAMP).
A-9.2.6.2 Enforcement
City inspectors with enforcement authority will issue enforcement actions to commercial facility owners and operators determined to be out of compliance. The inspectors will document each observed violation. Depending on the severity of the violation, enforcement actions can range from a verbal warning to civil or criminal court actions with monetary fines.
If a significant and/or immediate threat to water quality is observed by a City inspector, action will be taken to require the facility owner and/or operator to immediately cease the discharge.
The enforcement mechanisms available to inspectors, as detailed in Section 9.4.5 of the DAMP, are as follows (in increasing order of severity):
Notice of Non-compliance
Administrative compliance orders
Cease and desist orders
Infractions and misdemeanors
While these measures typically escalate in enforcement action, they are not required to be issued in the exact order presented here. City inspectors will apply or recommend any of the enforcement steps as appropriate based on the enforcement consistency guide (Exhibit 4.I to DAMP Section 4). The City of Yorba Linda will ensure that violations of a similar nature are subjected to similar types of enforcement remedies.
A-9.2.7 Training and Outreach
A-9.2.7.1 Training
A total of six training modules covering different aspects of the Model Existing Development Program have been developed. These modules are provided in DAMP Appendix B, Section B9. The modules that address implementation of the commercial component of the program include the following:
Existing Development Program Management Module (Appendix B, Exhibit B-9.I) This training module is targeted to Storm Water Program Managers. The module includes an overview of the Existing Development Program and then detailed discussions of the
SECTION A-9, EXISTING DEVELOPMENT
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-9-17
requirements that storm water managers must address in their local implementation plans.
Step by step instructions are provided to aid the managers in preparing their LIPs for industry, commercial businesses, residential, and common interest areas.
Field Implementation of Existing Development Program Module (Appendix B, Exhibit B-9.II) This training module is targeted to staff responsible for code enforcement and inspection of industrial and commercial facilities. The module addresses the basic program element requirements and then provides detailed instruction on conducting inspections, including inspection forms, record keeping requirements, and enforcement tools available for code violations.
A-9.2.7.2. Outreach
The outreach strategy for reaching commercial businesses includes efforts such as including storm water information on the County’s webpage (www.ocwatersheds.com), mass mailings, holding workshops, and development and distribution of brochures, posters, fact sheets, etc.
More specific detail on the training and outreach approach is provided in DAMP Section 6, Section A-6 of this LIP, and DAMP Appendix B, Section B-6.
Business-Specific Outreach
The following commercial business-specific train-the-trainer modules which can be found in Appendix B, Section B-9 have been developed to be used by the City to perform training and outreach for local commercial businesses:
Existing Development Program Training – Automobile Mechanical Repair, Maintenance, Fueling and Cleaning Businesses Module (Exhibit B-9.III)
This training module is for business owners and operators of automobile maintenance related businesses. The module explains the overall effort by Orange County to address storm water and what the business can do to improve water quality. The module provides examples of good source control Best Management Practices, including BMPs for fueling, maintenance & repair, and vehicle washing. References are provided for the business owner to pursue for more information.
Existing Development Program Training – Landscape Maintenance Businesses Module (Exhibit B-9.IV)
This training module is for business owners and operators of landscape maintenance related businesses. The module explains the overall effort by Orange County to address storm water and what the business can do to improve water quality. The module provides examples of good source control Best Management Practices in the areas of pest control, yard fertilizing and safer alternatives. References for the business owner to pursue for more information are also provided.
SECTION A-9, EXISTING DEVELOPMENT
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-9-18
A-9.2.8 Program Effectiveness Assessment
The overall Program Effectiveness Assessment (PEA) serves as the foundation for the submittal of the annual progress report that is submitted each year to the Principal Permittee and subsequently to the Regional Boards and serves as the basis for evaluating each municipality’s individual commercial program efforts (See DAMP Appendix C, Section C-8).
The PEA allows each municipality to assess the effectiveness of their individual storm water program components including those focused on addressing storm water and non-storm water discharges associated with commercial activity. The commercial program effectiveness assessment will enable the City to evaluate the effectiveness of the local program by focusing on data collected from the inventorying, prioritization, BMP implementation, inspection and enforcement of commercial facilities as well as training records.
SECTION A-9, EXISTING DEVELOPMENT
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-9-19
A-9.3 Residential Program
The program described in this section was developed pursuant to Section XIII of the Santa Ana Order and Section 9.5 of the DAMP.
A-9.3.1 Pollution Prevention and Administration
The City of Yorba Linda’s Residential Component includes specifications for pollutionprevention methods for residential areas and activities located within the City. Specific pollution prevention practices that are recognized for each residential activity with high potential to pose a threat to water quality, as being effective and economically advantageous, are provided in the activity fact sheets presented in Exhibit A-9.II. The City will use the implementation strategies discussed in Section A-9.3.3 to encourage pollution prevention.
A-9.3.2 Best Management Practices
The City of Yorba Linda has designated a minimum set of activity-specific BMPs for residential activities, as set forth in Section 9.5 of the DAMP and modified according to City requirements.
The City has selected the BMPs shown in Table A-9.9 below that are appropriate to prevent or mitigate pollution generated from the specific activities typical of residences within the jurisdiction. The corresponding BMP fact sheets are included as Exhibit A-9.II. The City encourages the implementation of the designated BMPs at each residence to limit the potential impact of the residential activities on receiving water quality.
Table A-9.8
Designated Residential Activities BMPs
Activity BMP Fact Sheet
Automobile Repair and Maintenance R-1
Automobile Washing R-2
Automobile Parking R-3
Home and Garden Care Activities R-4
Disposal of Pet Wastes R-5
Disposal of Green Wastes R-6
Household Hazardous Waste BMPs R-7
Water Conservation R-8
SECTION A-9, EXISTING DEVELOPMENT
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-9-20
A-9.3.3 Program Implementation
The residential program will rely on education and outreach to notify and urge residents to observe the designated sets of BMPs for each of the high threat activities. The City will encourage the implementation of the designated BMPs for each residence within its jurisdiction by conducting the following as appropriate:
Training City Personnel who have regular contact with residential areas (e.g. park maintenance personnel, street sweepers, code enforcement officers, etc.) to serve as information disseminators.
Providing Public Education Materials at public counters, such as City Hall, that target residential activities listed in Table A-9.8, and making available additional materials provided by the County.
Public Service Announcements reminding residents that the stormdrain system conveys untreated water to the ocean using the established theme, “The Ocean begins at your front door.” Announcements shall also include reminders that the County hotline number is a 24-hour service.
A-9.3.4 Training and Outreach
A-9.3.4.1 Training
A total of six training modules covering different aspects of the Model Existing Development Program have been developed. These modules are provided in DAMP Appendix B, Section B9. The modules that address implementation of the residential component of the program include the following:
Existing Development Program Management Module (Appendix B, Exhibit B-9.I) This training module is targeted to Storm Water Program Managers. The module includes an overview of the Existing Development Program and then detailed discussions of the requirements that storm water managers must address in their local implementation plans.
Step by step instructions are provided to aid the managers in preparing their LIPs for industry, commercial businesses, and residential areas.
A-9.3.4.2 Outreach
The outreach strategy for reaching residents includes efforts such as promoting storm water information on the County’s webpage, , mass mailings, holding workshops, and development and distribution of brochures, fact sheets, etc. More specific detail on the training and outreach approach is provided in DAMP Section 6, Section A-6 of this LIP, and DAMP Appendix B, Section B-6.
SECTION A-9, EXISTING DEVELOPMENT
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-9-21
A-9.3.5 Program Reporting and Assessment
The overall Program Effectiveness Assessment (PEA) serves as the foundation for the submittal of the annual progress report that is submitted each year to the Principal Permittee and subsequently to the Regional Boards and serves as the basis for evaluating each municipality’s individual residential program efforts (See DAMP Appendix C, Section C-8).
The PEA allows each municipality to assess the effectiveness of their individual storm water program components including those focused on addressing storm water and non-storm water discharges associated with residential activity. The residential program effectiveness assessment will enable the City to evaluate the effectiveness of the local program by focusing on data collected from the distribution of public education materials as well as training records.
Exhibit A-9.I
Inventory Spreadsheet
Legend
Municipal Facilities
Active Construction Sites
Industrial/Commercial Facilities
Yorba Linda Streets
200 Ft. Buffer Zone
500 Ft. Buffer Zone
Santa Ana River | Reach 2
Yorba Linda City Limits
2003 STORM WATER NPDES FACILITIES INVENTORY
CITY OF YORBA LINDA
Not to Scale
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San Bernardino Co. Orange Co.
IMPERIAL
YORBA LINDA
LAKEVIEW
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Industrial Site Locations
City of Yorba Linda Z
FY 2009/10
11/12/10
1" = 3000'
LegendIndustrial Sites (77 Total)
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San Bernardino Co. Orange Co.
IMPERIAL
YORBA LINDA
LAKEVIEW
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PALOMAS
Commercial Site Locations
City of Yorba Linda Z
FY 2009/10
11/12/10
1" = 3000'
LegendCommercial Sites (331 Total)
Priority
Medium
Low
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Exhibit A-9.II
Best Management Practice (BMP) Activity Fact Sheets
Industrial/Commercial Fact Sheets
IC2. ANIMAL HANDLING AREAS
IC3. BUILDING MAINTENANCE
IC4. CARPET CLEANING
IC5. CONCRETE AND ASPHALT PRODUCTION, APPLICATION, AND CUTTING IC6. CONTAMINATED OR ERODIBLE SURFACES AREAS
IC7. LANDSCAPE MAINTENANCE
IC8. NURSERIES AND GREENHOUSES
IC9. OUTDOOR DRAINAGE FROM INDOOR AREAS
IC10. OUTDOOR LOADING/UNLOADING OF MATERIALS
IC11. OUTDOOR PROCESS EQUIPMENT OPERATIONS AND MAINTENANCE IC12. OUTDOOR STORAGE OF RAW MATERIALS, PRODUCTS, AND CONTAINERS IC13. OVER WATER ACTIVITIES
IC14. PAINTING, FINISHING, AND COATINGS OF VEHICLES, BOATS, BUILDINGS, AND
EQUIPMENT
IC15. PARKING AND STORAGE AREA MAINTENANCE
IC16. POOL AND FOUNTAIN CLEANING
IC17. SPILL PREVENTION AND CLEANUP
IC18. VEHICLE AND EQUIPMENT FUELING
IC19. VEHICLE AND EQUIPMENT MAINTENANCE AND REPAIR
IC20. VEHICLE AND EQUIPMENT WASHING AND STEAM CLEANING
IC21. WASTE HANDLING AND DISPOSAL
IC22. EATING AND DRINKING ESTABLISHMENTS
Residential BMP Fact Sheets
R-1 AUTOMOBILE REPAIR AND MAINTENANCE
R-2 AUTOMOBILE WASHING
R-3 AUTOMOBILE PARKING
R-4 HOME AND GARDEN CARE
R-5 DISPOSAL OF PET WASTES
R-6 DISPOSAL OF GREEN WASTES
R-7 HOUSEHOLD HAZARDOUS WASTE
R-8 WATER CONSERVATION
BMPs for CIAs/HOAs with Publicly-Owned and Maintained Streets and Stormdrains ACTIVITY BMP Fact Sheet1
Parking vehicles on residential streets, in
driveways, or in common area parking lots
Automobile parking BMPs R-3
Washing vehicles in residential driveways
or street
Automobile washing BMPs R-2
Disposal of household hazardous wastes
such as paint, bleach, etc.
Household Hazardous waste BMPs R-7
Cleaning of CIA/HOA sidewalks, plaza,
and entry monuments and fountains
Sidewalk, plaza, and entry monument
and fountain maintenance BMPs
FP-4
Landscape maintenance including irrigation
and fertilization
Landscape maintenance BMPs FP-2
IC-7
Operation and maintenance of community
pools
Pool cleaning BMPs IC-16
Operations and maintenance of recreation
areas such as stables, golf courses, and
parks
Disposal of Pet Waste BMPs
Landscape Maintenance BMPs
Disposal of Green Waste BMPs
R-5
FP-2
R-6
Maintenance Yard BMPs
Activity BMP Fact Sheet
Vehicle maintenance and repair Equipment maintenance and repair BMPs
FF-3
Vehicle fueling Vehicle fueling BMPs FF-4
Storage of vehicles and equipment Vehicle and equipment storage BMPs FF-12 Cleaning of vehicles and equipment Vehicle and equipment cleaning BMPs
FF-11
Storage, handling, and disposal of various
materials such as cleaners
Material storage, handling, and
disposal BMPs
FF-13
Loading and unloading of materials Material loading and unloading BMPs
FF-6
1 Fact sheets labeled with a DF, FF, or FP are included in Section 5.0 BMPs for CIAs/HOAs with Privately-Owned and Maintained Streets and Storm Drains ACTIVITY BMP Fact Sheet1
Street sweeping Street sweeping BMPs FP-3
Trash collection, recycling, and disposal Solid waste handling BMPs FF-13 Inspection and cleaning of storm drains Drainage system operation and maintenance BMPs
DF-1
Operation and maintenance of water and
sewer lined (not controlled by utility
company)
Water and sewer utility operation and
maintenance BMPs
FP-6
1 Fact sheets labeled with a DF, FF, or FP are included in Section 5.0
Exhibit A-9.III
Inspection Procedures
Inspection Procedures
Inspection Form
INSPECTION PROCEDURES
This attachment provides Permittees with a stepwise process for conducting industrial inspections. Permittees should consult the Enforcement Consistency Guide for guidance on enforcement (see Chapter 10 of the DAMP) at sites found to be in non-compliance. An inspection form is also included.
1.0 PRE-INSPECTION PREPARATION
STEP 1: Establish purpose
The inspector needs to establish the purpose and scope of the inspection and to review all pertinent background information. For an advisory inspection, the inspector must contact the industry officials to schedule the inspection. The inspector may also request that relevant documents be available for on-site review (e.g., SWPPP, site plans, spill response plan, etc).
STEP 2: File review
The inspector should review any existing Permittee files or information for the industry, which may include past complaints, permits, monitoring data or submitted SWPPPs.
STEP 3: Database review
The inspector should also review the inventory database to identify the SIC code (for industrial facilities) and determine what type of industrial activity and pollutants may be expected. The inventory database will indicate if the facility has or should have filed a Notice of Intent (NOI) to operate under the statewide General Industrial Permit. The database will also identify the hydrologic unit and proximity to Clean Water Act (CWA) 303(d) water bodies, environmentally sensitive areas (ESAs) or areas of special biological significance. This information should be compared against the current information available in the inventory database in order to verify its accuracy.
2.0 APPROACHING THE SITE
STEP 1: Observations
Before entering the facility grounds, the inspector should make note of the following:
Nearby conveyances or water bodies;
Visible discharge points along the perimeter of the site; Outdoor areas of intensive industrial activity; and
Signs of recent additions or remodeling.
3.0 FACILITY INSPECTION
STEP 1: Entry
The inspector must present proper credentials and request to meet with the appropriate industry officials to discuss the inspection scope and objectives. If the inspector is denied entry into the facility, the inspector must withdraw from the premises and contact the [appropriate legal authority] to determine if court action should be sought to obtain entry.
STEP 2: Opening conference
After authorized entry, the inspector will discuss the inspection scope and objectives. The inspector should attempt to verify and update the Permittee's inventory information, such as:
Changes in ownership or operations
Clarification of observations noted before entering the facility, (any changes in activities, materials, or physical structures should be reflected in the SWPPP) Review of the SWPPP, which should include these elements:
o Site map;
o List of industrial activities, types of pollutants, and existing non-structural and structural BMPs to reduce these pollutants in storm water discharge; o Pollution prevention methods;
o Description of type and location of non-storm water discharges, both authorized and unauthorized; and
o Inventory of materials, including storage and loading/unloading areas. Review of any existing storm water monitoring data.
STEP 3: Outdoor walk-through
The inspector and responsible industry official(s) should walk through all outdoor areas and observe activities, wherever it is safe to do so. Typical areas of activity that might impact storm water quality include are outlined in the BMP fact sheets included in Attachment C.
The inspector should attempt to gain a clear understanding of how runoff leaves the facility site by observing all portions of the storm water conveyance system and site grading, where possible and safe. This includes inlets, outlets, open channel conveyances such as ditches, etc.
The inspector must document the observed conditions, including any BMPs being implemented, and must assess the facility's impact on storm water quality from the outdoor activities. Impact includes the facility's potential to discharge and the facility's actual discharge, which are further described below.
STEP 4: Indoor walk-through
Review indoor activities and areas to ensure that pollutants are not spilled, dumped, or allowed to flow outdoors. The inspector must document the observed conditions, including any BMPs
being implemented, and will assess the facility's impact on storm water quality from the indoor activities.
STEP 5: Assess impact on storm water quality
The inspector should attempt to determine the facility's impact on storm water quality at two levels: the facility's potential to/for discharge and the facility's actual discharge. The difference between potential and actual is determined by whether BMPs are effectively applied. For example, a facility that stores all of its machinery and heavy equipment outdoors or performs certain activities outdoors has a high potential to impact storm water runoff. However, if equipment is well maintained and covered when not in use, the level of pollutant exposure should be minimized and the actual impact of the facility upon storm water runoff quality is greatly reduced. The inspector should note three things on the inspection report:
1) What is the facility's potential to impact storm water quality and non-storm water discharges from exposure to on-site pollutants? Identify areas or activities that require BMPs to be applied to reduce or eliminate potential pollutant discharges to storm drains.
If BMPs are in place, determine what the impact would be if BMPs failed or were no longer applied.
2) Are BMPs effectively applied so that exposure to pollutants is minimized and nonstorm water discharges are eliminated? For each of the facility's areas of activity, observe whether BMPs are in place and effective. The inspector may encounter situations where BMPs are in place but are not effectively applied. The inspector will use their best professional judgment on the imminent impact of the facility and decide how much time to allow the owner/operator to correct the problem. 3) What types of impact does the facility have on storm water quality? Clearly describe on the inspection report whether the impact is from: 1) pollutant exposure to runoff; and/or 2) non-storm water intentionally or accidentally discharged to storm drains.
STEP 6: Document inspection activities
As the inspector observes the outdoor and indoor activities at the facility, they should also take notes and photos as appropriate. The inspector should document the locations and types of BMPs that are currently being implemented and assess areas where BMPs should be implemented in the future. The inspector may also collect samples of illicit discharges or storm water from the facility as appropriate.
An inspection form has been provided for the Permittee’s use in documenting the above information during a site inspection. Use of this form is suggested for all Permittees to maintain consistency in inspection efforts; however, the form may need to be modified to address specific Permittee needs.
STEP 7: Closing Conference
After the walk-through of the facility, the inspector should collect any missing or additional information, including verifying the SIC codes. The inspector may review other documentation to look for indications of discharge problems, such as monitoring data, the Hazardous Materials Release Response Plan and Inventory, permits, manifests, logs and other records required of the facility by local, state or federal laws in order to conduct operations or business on the premises.
The inspector should review the inspection findings and inform the facility officials of follow-up procedures.
The Permittee may also provide educational materials, applicable BMP fact sheets, and any other technical and regulatory information to assist facilities in attaining compliance. 4 RECORD KEEPING
The inspector will update the inventory and complete the inspection report upon return to the office. The inspection report should contain at least the following sections:
General information to update the inventory;
Review of the SWPPP;
Assessment of BMP implementation;
Documentation of violations and time frame for correction; and Signature and confirmation.
Follow-up inspections will be done as needed to confirm BMP implementation and compliance.
CITY OF YORBA LINDA
Commercial/Industrial Inspection/Site Report Form
Site/File
Inspection Work Order (I)
□ First Inspection □ Second Inspection □ New Facility □ Response to Complaint □ Follow up Facility Name: Site Address:. Narrative SIC Description:
Contact Name: Phone: SIC:
Is the facility within the County unincorporated area? □ Yes □ No City Is the facility covered under any other permits? (Check all that apply) □ Air Quality □ Hazmat business plan □ Underground storage tanks □ Above ground storage tanks □ Fire Dept. (Storage) □ Hazardous waste generator □ Other Is the facility covered under a storm water permit? □ Does not need coverage □ No, but may need to refer to Regional Board □ Individual NPDES □ General (filed NOI) Does the facility have a SWPPP? □ Yes □ No Facility's WDID # :
ACTIVITIES ASSESSMENT CHECKLIST
ACTIVITIES -Check each activity present at the site and evaluate its potential for pollutant discharge (PPD): I = low potential, 2 = medium potential, 3 = high potential Circled BMPs require your immediate attention - see back of this report.
APPLICABLE ACTIVITY
Yes No PPD
EFFECTIVENESS
RATING*
A. AIRPLANE MAINTENANCE AND REPAIR BMPs employed: [ ] [ ] [ ] B. BUILDING MAINTENANCE BMPs employed:
C. CONTAMINATED OR ERODIBLE SURFACE AREAS
BMPs employed:
[ ] [ ] [ ]
D. OUTDOOR PROCESS EQUIPMENT OPERATIONS AND MAINTENANCE BMPs employed:
[ ] [ ] [ ]
E. OUTDOOR LOADING/UNLOADING OF MATERIAL
BMPs employed:
[ ] [ ] [ ]
F. CONCRETE AND ASPHALT PRODUCTION, APPLICATION, AND CUTTING BMPs employed:
[ ] [ ] [ ]
G. OUTDOOR STORAGE OF RAW MATERIALS/PRODUCTS/CONTAINERS BMPs employed:
[ ] [ ] [ ]
H. OUTDOOR DRAINAGE FROM INDOOR AREAS BMPs employed: [ ] [ ] [ ] I. PAINTING, FINISHING, and COATING of VEHICLES, BOATS, BUILDINGS, and EQUIPMENT BMPs employed:
[ ] [ ] [ ]
J. LANDSCAPE MAINTENANCE BMPs employed: [ ] [ ] [ ] K. OVER WATER ACTIVITIES BMPs employed: [ ] [ ] [ ] L. PARKING-STORAGE AREA MAINTENANCE BMPs employed: [ ] [ ] [ ] M. VEHICLE AND EQUIPMENT FUELING BMPs employed: [ ] [ ] [ ] N. VEHICLE AND EQUIPMENT WASHING/STEAM CLEANING
BMPs employed:
[ ] [ ] [ ]
O. SPILL PREVENTION AND CONTROL BMPs employed: [ ] [ ] [ ] P. WASTE HANDLING AND DISPOSAL BMPs employed: [ ] [ ] [ ] Q. VEHICLE AND EQUIPMENT MAINTENANCE AND REPAIR
BMPs employed:
[ ] [ ] [ ]
R. NURSERIES and GREENHOUSES BMPs employed: [ ] [ ] [ ] S. CARPET CLEANING BMPs employed: [ ] [ ] [ ] T. ANIMAL HANDLING AREAS BMPs employed: [ ] [ ] [ ] U. POOL and FOUNTAIN CLEANING BMPs employed: [ ] [ ] [ ] V. EATING and DRINKING ESTABLISHMENT BMPs employed: [ ] [ ] [ ] M. OTHER (describe): [ ] [ ] [ ]
* No BMPs used and stormwater pollution likely Some BMPs used but not effective Some BMPs used and moderately effective Source control BMPs used and very effective/structural BMPs needed All necessary BMPs used and very effective This report is furnished to the facility representative as a measure to evaluate the implemented BMP's at your facility to prevent storm water pollution. Your facility may be subject to an enforcement action if the noted deficiencies are not corrected by:________to request reinspection to review the correction of deficiencies noted above. Please call ( ) by ________ between 8:00 a.m. to 9:30 a.m.
Storm water ordinances violated:…………………………………………………………………………………………………………………………………………………………..
Facility Representative Signature: ____________________________________________________________________ Date: _________________________________________ Print name of Facility Representative:__________________________________________________________________ Inspector: _____________________________________
BEST MANAGEMENT PRACTICE (BMP) CHECKLIST
The BMPs listed below arc required measures to control the discharge of pollutants to the stormwater drainage system for the activities assessed on the front of this form. Not all BMPs may be applicable to your facility. You are encouraged to employ additional BMPs if they will control pollutants in an effective manner. If the Inspector has circled a BMP, strong consideration should be given to employing this measure. BMPs indicated by an asterisk (*) may require permits or approval for construction and/or operation. Your Inspector, can assist you In making this determination.
A. Airplane Maintenance and Repair (Factsheet IC1)
1. Only conduct maintenance or repair work in designated areas.
2. Utilize dry cleanup methods (i.e. sweeping), try to avoid washing down work areas.
3. Use drip pans and/or containers where needed.
4. Inspect airplanes for leaks.
5. Dispose of all waste products properly and recycle whenever possible.
6. Paint signs near outdoor drains and post signs at sinks to remind employees and others not to pour wastes down storm drains.
7. Clean storm drain inlet(s) on a regular schedule and after large storms.
8. Store idle equipment under cover.
9. Keep equipment clean and free of excessive oil and grease.
10. Completely drain oil filters before recycling/disposal.
11. Train employees on these BMPs, storm water discharge prohibitions, and wastewater discharge requirements.
OPTIONAL:
12. Use non-toxic chemicals for maintenance when possible.
13. Minimize the use of solvents.
F. Concrete and Asphalt Production, Application, and Cutting (Factsheet IC5)
1. Properly collect and dispose of process water.
2. Protect production, pouring, and cutting areas from stormwater runoff and runon.
3. Sweep the production, pouring, and cutting areas regularly to collect loose materials.
4. Pre-heat, transfer or load hot bituminous material away from storm drain inlets.
5. Use drip pans or absorbent material to catch drips from paving equipment, including equipment that is not in use.
6. Cover and seal nearby storm drain inlets (with waterproof material or mesh) and manholes before applying seal coat, slurry seal, etc.
7. Conduct surface repair work during dry weather to prevent contamination from contacting stormwater runoff.
8. To avoid runoff, use only as much water as necessary for dust control.
9. Do not allow concrete and concrete pumping vehicles to discharge concrete, slurry, or rinse water into gutters, storm drains, or drainage ditches.
10. Train employees on these BMPs, storm water discharge prohibitions, and wastewater discharge requirements.
B. Building Maintenance (Factsheet IC3)
1. Properly collect and dispose of water when pressure washing buildings, rooftops, and other large objects.
2. Properly prepare work area before conducting building maintenance.
3. Properly clean and dispose of equipment and wastes used and generated during building maintenance.
4. Employ soil erosion and stabilization techniques when exposing large areas of soil.
5. Store toxic material under cover when not in use and during precipitation events.
6. Properly dispose of fluids from air conditioning, cooling tower, and condensate drains.
7. Regularly inspect air emission control equipment under AQMD permit.
8. Train employees on these BMPs, storm water discharge prohibitions, and wastewater discharge requirements.
OPTIONAL:
9. Switch to non-toxic chemicals for maintenance when possible.
10. Use chemicals that can be recycled.
G. Outside Storage of Raw Materials, Products, and Containers (Factsheet IC12)
1. Store materials indoors, if feasible.
2. Store materials on paved or impervious surfaces.
3. Protect materials stored outside from rainfall and wind dispersal.
4. Protect materials stored outside from stormwater runon.
5. Minimize pooling of water.
6. All materials stored outside should have a secondary containment system.
7. Properly store and handle chemical materials.
8. Keep outdoor storage containers in good condition.
9. Conduct regular inspections of storage areas.
10. If drums are stored in an area where unauthorized persons may gain access secure them in such a manner as to prevent accidental spillage, pilferage, or any unauthorized use.
11. Train employees on these BMPs, storm water discharge prohibitions, and wastewater discharge requirements.
C. Contaminated or Erodible Surface Areas (Factsheet 6)
1. Protect contaminated or erodible surface areas from rainfall and wind dispersal.
2. Protect materials from stormwater runoff and runon.
3. Minimize pooling of water.
4. Conduct routine maintenance.
5. Train employees on these BMPs, storm water discharge prohibitions, and wastewater discharge requirements.
H. Outdoor Drainage from Indoor Areas (Factsheet IC9)
1. Design operating areas to minimize stormwater exposure.
2. Utilize dry cleanup methods such as sweeping for removal of litter and debris, or use of rags and absorbents for leaks and spills.
3. Use secondary containment or protective barriers for indoor liquid storage.
4. Install a fire sprinkler containment system for hazardous material storage.
5. Train employees on these BMPs, storm water discharge prohibitions, and wastewater discharge requirements.
D. Outdoor Process Equipment Operations and Maintenance (Factsheet IC11)
1. Alter activities to prevent exposure of pollutants to stormwater.
2. Cover process equipment/area with a permanent roof.
3. Design process area to prevent stormwater runon.
4. Design process area to contain spills.
5. Inspect equipment regularly.
6. Train employees on these BMPs, storm water discharge prohibitions, and wastewater discharge requirements.
OPTIONAL:
7. Eliminate or reduce amount of hazardous materials and wastes
8. Recycle wastes whenever possible
I. Painting, Finishing, and Coatings of Vehicles, Boats, Buildings, and Equipment (Factsheet IC14)
1. Use drop/ground cloths.
2. Shelter any blasting and spray painting activities.
3. Maintain a clean working environment.
4. Cover and seal nearby storm drain inlets.
5. Properly clean, store, and dispose of painting, finishing, and coating materials.
6. Train employees on these BMPs, storm water discharge prohibitions, and wastewater discharge requirements.
E. Outdoor Loading/Unloading of Materials (Factsheet IC10)
1. Properly design loading/unloading areas to prevent storm water runon, runoff of spilled liquids, etc.
2. Park vehicles and conduct loading/unloading only in designated loading/unloading areas so that spills or leaks can be contained.
J. Landscape Maintenance (Factsheet IC7)
1. Take steps to reduce landscape maintenance requirements.
2. Properly store and dispose of gardening wastes.
3. Use mulch or other erosion control measures on exposed soils. Page 550 of 740 4. Properly manage irrigation and runoff.
3. Clean loading/unloading areas regularly to remove potential sources of pollutants.
4. Reduce exposure of materials to rain.
5. Use drip pans underneath hose and pipe connections and other leak-prone spots during liquid transfer operations, and when making and breaking connections.
6. Inspect equipment regularly.
7. If possible, conduct loading and unloading in dry weather.
8. Train employees on these BMPs, storm water discharge prohibitions, and wastewater discharge requirements.
5. Properly store and dispose of chemicals.
6. Properly manage pesticide and herbicide use.
7. Properly manage fertilizer use.
8. Train employees on these BMPs, storm water discharge prohibitions, and wastewater discharge requirements.
OPTIONAL:
9. Incorporate integrated pest management techniques where appropriate.
K. Over Water Activities (Factsheet IC13)
1. Move maintenance and repair activities on-shore, if feasible.
2. Use ground cloths and/or secondary containment when painting boats on land.
3. Shelter any blasting and spray painting activities.
4. Post signs to indicate proper use and disposal of residual paints, rags, used oil, and other engine fluids.
5. Boats with inboard engines should have oil absorption pads in bilge areas that are changed when no longer useful or at least once a year.
6. Keep boat motors well-tuned to prevent fuel and lubricant leaks.
7. Recycle used motor oil, diesel oil, and other fluids and parts whenever possible.
8. Maintain a clean working environment.
9. Properly dispose of bilge water, ballast water, and wastewater.
10. Minimize impacts of cleaning products.
11. Train employees on these BMPs, storm water discharge prohibitions, and wastewater discharge requirements.
O. Spill Prevention and Control (Factsheet IC17)
1. Develop procedures to prevent/mitigate spills to storm drain systems.
2. Post “No Dumping” signs with a phone number for reporting illegal dumping and disposal.
3. Conduct routine cleaning, inspections, and maintenance.
4. Properly store and handle chemical materials.
5. Utilize secondary containment systems for liquid materials.
6. Protect materials stored outside from stormwater runon.
7. Secure drums stored in an area where unauthorized persons may gain access to prevent accidental spillage, pilferage, or any unauthorized use.
8. Identify key spill response personnel.
9. Adopt the Orange County Hazardous Materials Area Plan or an equivalent plan.
10. Clean up leaks and spills immediately.
11. Report and track spills.
12. Train employees on these BMPs, storm water discharge prohibitions, and wastewater discharge requirements.
L. Parking-Storage Area Maintenance (Factsheet IC15)
1. Conduct regular cleaning.
2. Properly collect and dispose of wash water.
3. Consider use of source treatment BMPs to treat runoff.
4. Keep the parking and storage areas clean and orderly.
5. When cleaning heavy oily deposits:
6. When conducting surface repair work:
7. Conduct inspections on a regular basis.
8. Keep accurate maintenance logs to evaluate materials removed/stored and improvements made.
9. Arrange rooftop drains to prevent drainage directly onto paved surfaces.
10. Train employees on these BMPs, storm water discharge prohibitions, and wastewater discharge requirements.
P. Waste Handling and Disposal
1. Prevent waste materials from coming in direct contact with wind or rain.
2. Design waste handling and disposal area to prevent stormwater runon.
3. Design waste handling and disposal area to contain spills.
4. Keep waste collection areas clean.
5. Secure solid waste containers when not in use.
6. Regularly inspect, repair, and/or replace waste containers.
7. Do not fill waste containers with washout water or any other liquid.
8. Use all of a product before disposing of the container.
9. Segregated wastes by type and label and date wastes.
10. Label and store hazardous wastes according to hazardous waste regulations.
11. Train employees on these BMPs, storm water discharge prohibitions, and wastewater discharge requirements.
OPTIONAL:
12. Minimize waste.
M. Vehicle and Equipment Fueling (Factsheet IC18)
1. Use properly maintained off-site fueling stations whenever possible.
2. Maintain clean fuel-dispensing areas.
3. Design fueling areas to minimize stormwater exposure.
4. Minimize pooling of water.
5. If conducting mobile fueling, designate mobile fueling areas and bring equipment to these areas.
6. Utilize fueling safeguards.
7. Conduct regular inspections of fueling equipment.
8. Use secondary containment when transferring fuel from the tank truck to the fuel tank and cover storm drains in the vicinity during transfer.
9. Fit underground storage tanks (USTs) with spill containment and overfill prevention systems meeting the requirements of Section 2635(b) of Title 23 of the California Code of Regulations.
10. Equip USTs with spill and overfill protection.
11. Install required AQMD equipment and post a notice.
12. Train employees on these BMPs, storm water discharge prohibitions, and wastewater discharge requirements.
OPTIONAL:
13. Post signs to remind employees and customers not to top off the fuel tank when filling and signs that ban customers and employees from changing engine oil or other fluids at that location.
Q. Vehicle and Equipment Maintenance and Repair (Factsheet IC19)
1. Only conduct maintenance or repair work in designated areas.
2. Utilize dry cleanup methods such as sweeping try to avoid washing down work areas.
3. Use drip pans and/or containers where needed.
4. Inspect vehicles and equipment for leaks.
5. Dispose of all waste products properly and recycle whenever possible.
6. Paint signs near outdoor drains and post signs at sinks to remind employees and others not to pour wastes down drains.
7. Clean storm drain inlet(s) on a regular schedule and after large storms.
8. Store idle equipment under cover.
9. Keep equipment clean and free of excess oil and grease.
10. Completely drain oil filters before recycling/disposal.
11. Remove all fluids from retired, wrecked, or salvaged vehicles.
12. Dispose of per instructions on the container.
13. Train employees on these BMPs, storm water discharge prohibitions, and wastewater discharge requirements.
OPTIONAL:
14. Use non-toxic chemicals for maintenance when possible.
15. Reduce or eliminate use of solvents when feasible.
N. Vehicle and equipment Washing and Steam Cleaning (Factsheet IC20)
1. Consider using off-site commercial washing and/or steam cleaning R. Nurseries and Greenhouses (Factsheet IC8)
1. Properly manage irrigation and runoff. Page 551 of 740 businesses, if feasible.
2. Use on-site commercial washing and/or steam cleaning businesses capable of disposing of wastewater off-site.
3. Designate an impervious indoor or outdoor area to be used solely for vehicle and equipment washing/steam cleaning.
4. Clearly mark the vehicle and equipment washing/steam cleaning area.
5. Design wash area to properly collect and dispose of wash water and/or effluent generated.
6. If the area is outdoors, cover the wash area when not in use to prevent contact with rainwater.
7. Provide trash containers in wash area and empty on a regular basis.
8. Use hoses with nozzles that automatically turn off when left unattended.
9. Train employees on these BMPs, storm water discharge prohibitions, and wastewater discharge requirements.
OPTIONAL:
10. Use biodegradable, phosphate-free detergents if possible.
11. Recycle waste materials, whenever possible.
12. If possible, eliminate or reduce the amount of hazardous materials and waste by substituting non-hazardous or less hazardous material.
2. Properly store and dispose of gardening wastes.
3. Properly store and dispose of chemicals.
4. Properly manage pesticide and herbicide use.
5. Properly manage fertilizer use.
6. Train employees on these BMPs, storm water discharge prohibitions, and wastewater discharge requirements.
OPTIONAL:
7. Incorporate integrated pest management techniques where appropriate.
BUSINESS RELATED BMPS
S. Carpet Cleaning (Factsheet IC4)
1. Discharge wash water to sink, toilet, or other drain connected to the sanitary sewer system.
U. Pool and Fountain Cleaning (Factsheet IC16)
1. Prevent algae problems with regular cleaning, consistent adequate chlorine levels, and well-maintained water filtration and circulation systems.
2. Manage pH and water hardness to minimize corrosion of copper pipes.
3. Discharge pool and fountain water properly.
4. Properly clean and/or dispose of filters.
5. Train employees on these BMPs, storm water discharge prohibitions, and wastewater discharge requirements.
T. Animal Handling Areas (Factsheet IC2)
1. Use dry cleaning methods to clean animal handling areas regularly.
2. Properly collect and dispose of water when water is used for cleaning.
3. Keep animals in paved and covered areas, if feasible.
4. If keeping animals in covered areas is not feasible, cover the ground with vegetation or some other type of ground cover such as mulch.
5. Prevent animals from moving away from controlled areas where BMPs are in use (e.g. fencing, leashing, etc.).Clean storm drain inlet(s) on a regular schedule and after large storms.
6. Train employees on these BMPs, storm water discharge prohibitions, and wastewater discharge requirements.
V. Eating and Drinking Establishments (Factsheet IC22)
1. Practice good housekeeping.
2. Clean equipment (floor mats, grease filters, grills, garbage cans, etc.) indoors or in a covered outdoor wash area that is plumbed to the sanitary sewer or in an area that will contain the wash water.
3. Recycle and/or properly dispose of grease and oil.
4. Block the storm drain when hosing or steam/pressure washing outside dumpster areas, sidewalks, and common areas with hot water, soap, or other cleaning agent.
5. If only tap water and no cleaning agents are used sweep area, clean up spills, direct water to vegetative area or collect and properly dispose of it contaminated.
6. Train employees on these BMPs, storm water discharge prohibitions, and wastewater discharge requirements.
1 Exhibit A-9.IV
Industrial Monitoring Program
2 1.0 Monitoring
1.1 Introduction
The basic approach followed for the monitoring program is to ensure compliance with guidelines developed based upon requirements laid out in the Monitoring and Reporting Program No. R9-2002-0001, NPDES No. CAS0108740 (San Diego NPDES permit), issued by the San Diego Regional Water Quality Control Board (Section F.3.b(5)), and guidelines for industrial monitoring described in the Water Discharge Requirements for Discharges of Storm Water Associated with Industrial Activities Excluding Construction Activities (State General Permit).
Monitoring guidelines take the form of quantitative (i.e., sample collection and laboratory analysis) assessments associated with wet season runoff. The guidelines laid out in this document are not intended to supersede monitoring or visual observation requirements for facilities specified in other applicable permits (for example, a facility subject to requirements of a State General Permit).
This document is organized to provide step-by-step guidance to facilities that must conduct monitoring. Figure 1 outlines each implementation step and references it to the relevant section of this appendix.
1.1.1 Who needs to monitor?
The industrial monitoring program is a generic program designed to be implemented by appropriate Federal, State, municipally-owned, and private industrial facilities that fall under the requirements of the San Diego NPDES permit. All industrial facilities are encouraged by Copermittees to self-monitor and report for any negative impacts upon receiving water quality.
However, not all industrial facilities are required to implement a monitoring and inspection program. Only facilities designated by Copermittees as posing “high threats” to water quality as required under Section F.3.b.(3) of the San Diego NPDES permit must implement the full provisions of the monitoring program. At a minimum, high priority industrial sites include:
Facilities subject to the statewide General Permit (excluding those receiving No Exposure Certification as discussed below)
Facilities subject to section 313 of Title III of the Superfund Amendments and Reauthorization Act of 1986 (SARA)
Facilities tributary to a Clean Water Action section 303(d) impaired water body where the facility generates pollutants for which the water body is listed as impaired Facilities within or directly adjacent to or discharging directly to receiving waters within environmentally sensitive areas
All other industrial facilities that the Copermittee determines are contributing significant pollutant loading to the stormwater system.
Prior to implementing an industrial monitoring program, each facility representative should verify their specific site industrial code (SIC). Specific industrial classifications covered by this monitoring program include:
3 Facilities subject to stormwater effluent limitations guidelines, new source performance standards, or toxic pollutant effluent standards
Manufacturing facilities
Oil and gas / mining facilities
Hazardous waste treatment, storage, or disposal facilities Landfills, land application sites, and open dumps
Recycling facilities
Steam electric power generating facilities
Transportation facilities
Sewage or wastewater treatment works
Manufacturing facilities where industrial materials equipment or activities are exposed to stormwater
1.1.2 Why monitoring of high priority industrial businesses is a necessity By definition, industrial facilities covered by the NPDES permits discharge stormwaters to waters of the United States. These waters support beneficial uses themselves or flow into waters that support them. The Regional Water Quality Control Board designates water quality objectives that protect the most sensitive beneficial uses of specific waters and mandates that these objectives be met by dischargers.
Industrial facilities are classified as high priority industries based on a number of factors, including type of industrial activity, wastes generated, pollutant discharge potential, and proximity to environmentally sensitive areas. For these reasons, it is vitally important for facility representatives to monitor discharge from their facilities to ensure compliance with water quality objectives and therefore protection of designated beneficial uses of receiving waters.
1.2 Monitoring objectives
Monitoring is focused on providing information to assist in characterizing the nature of industrial runoff, tracking changes in these characteristics over time, targeting management actions to address high-priority problems, and assessing the effectiveness of such management actions. Thus, monitoring is an essential part of a long-term, results-based assessment strategy intended to improve water quality through the reduction of problematic industrial discharges.
1.3 Monitoring approach
The monitoring approaches used for stormwater monitoring follow the guidelines described in the San Diego NPDES permit for industrial discharges and depend on straightforward comparisons of monitoring observations and data to relevant criteria, limitations, and/or standards. These comparisons allow judgments about the nature of discharges at the time of monitoring. However, the relatively few number of samples collected per year, combined with the high variability known to be inherent in stormwater data, limit the ability to identify or track trends over the near term. As with all monitoring programs, the design should be evaluated and improved on as experience and data accumulate over time.
1.4 Implementation schedule
All facilities are required to implement a monitoring program consistent with the requirements of this document by February 13, 2003. The monitoring program should be developed based on
4 the site-specific conditions of the facility covered, and should be revised by the facility representative whenever appropriate.
1.5 Monitoring design and methods – discharge sampling
The generic monitoring program was developed based upon the requirements of the San Diego NPDES permit. Figure 1 presents a graphical illustration of the design and implementation procedures involved in developing and implementing an industrial monitoring program.
1.5.1 Select sampling locations
All appropriate stormwater discharge locations must be sampled for each storm event monitored. This does not, however, mean that every point of discharge from the facility must be sampled. Facility representatives should attempt to sample only discharges that emanate from their facility, and avoid discharges commingled with discharges from other areas if possible.
The selection of appropriate sampling sites must, however, reflect site-specific conditions.
Where a drainage exclusively serving a single facility is not able to be safely accessed, samples should be collected from an accessible conveyance as short a distance downstream as possible, which may serve multiple facilities or other sites.
Facility representatives can also limit the number of sample collections and analyses in cases where two or more drainage areas house substantially identical industrial activities and stormwater management BMPs. In this case, representatives may either collect and analyze samples from a reduced number of drainage areas, or may elect to create composite samples by combining equal volumes of discharge within a single sample container for analysis.
Representatives who decrease the number of sampling locations by either of the above methods must document their rationale in their routine reports.
1.5.2 Establish sampling frequency
Facility operators are required to collect stormwater samples from a minimum of two storm events during the wet season (October through May). Samples should meet the following criteria:
Samples should be collected during the first hour of discharge of the storm event Sampling of stored or contained stormwater shall occur at the time of its discharge Sample collection is only required of stormwater discharges that occur during scheduled facility operating hours and that are preceded by at least three working days without stormwater discharge.
1.5.3 Select constituents to be analyzed
There are a minimum set of required analytes that are common to every industrial monitoring program. Additionally, there are analytes that are specific to a facility based on the type of industrial activity, historic monitoring efforts, and analytes required by a facility’s NPDES permit. It is the responsibility of the facility representative to determine the appropriate analytical list based on these requirements, and each facility’s program should include the following:
5 Minimum required analytes (common to all facilities) include:
Total organic carbon (TOC) or greases and oils
Total suspended solids (TSS)
pH
Specific conductance
Analytes based on facility-specific conditions include:
Toxic chemicals possibly present in stormwater discharges Pollutants listed in effluent guidelines subcategories Pollutants that have an effluent limit established by an NPDES permit Other parameters required by the Copermittee
Other parameters determined by facility’s standard industrial classification (SIC) code(s) The parameters shown in Table 1 represent the analytes required to be analyzed by all facilities (TOC/Oil and grease, TSS, pH, and specific conductance) and the parameters recommended according to the the facility’s SIC. Table 2 shows recommended laboratory methods for these analytes.
1.5.4 Sample according to Standard Methods for the Examination of Water and Wastewater “Clean” sampling techniques are required of all sample collectors to minimize the potential for sample contamination and, therefore, the production of skewed results. Clean sampling techniques incorporate a number of sampling best practices to minimize the potential for contaminants to come into contact with the sample or sample container; this is especially important when contaminant concentrations are expected to be at trace levels, as is generally the case for stormwater sampling. A few commonly-observed clean sampling practices include use of approved laboratory gloves at all times when sampling, keeping open sample containers away from any type of exhaust, and avoiding touching the sample, sample container threads, or inside of lids at any time. Facility representatives not familiar with clean sampling procedures may wish to undertake training or employ experienced sample collectors for the task.
All samples collected for subsequent laboratory analyses should be labeled with (at a minimum):
Facility name
Site name (location sample collected)
Analysis requested
Sample collector
Date of collection
Time of collection
Any preservative used
Any other information requested by analytical laboratory All sampling and sample preservation should be conducted in accordance with the current edition of "Standard Methods for the Examination of Water and Wastewater" (American Public Health Association). In addition, all monitoring instruments and equipment employed as part of the monitoring program shall be calibrated and maintained in accordance with manufacturers' specifications. All laboratory analyses must be conducted according to test
6 procedures under 40 CFR Part 136, unless other test procedures have been specified by the Copermittee. With the exception of analyses conducted by facility representatives, all laboratory analyses should be conducted at a laboratory certified for such analyses by the State Department of Health Services. Facilities may conduct their own sample analyses only if the facility operator has sufficient capability (qualified employees, laboratory equipment, etc.) to adequately perform the test procedures.
1.5.5 Use a standard sample collection form
A consistent set of information should be collected for each sample in a standardized way.
Figure 2 illustrates an example sample collection form. In addition to recording the constituents monitored, the form should include any visual observations that may assist in interpreting the data, particularly the presence of any factors that may affect the reliability of the data.
1.6 Sampling exceptions
The facility representative is not required to collect samples at times of dangerous weather conditions, when stormwater discharge begins after scheduled facility operating hours, or when stormwater discharges are not preceded by three working days without discharge. Facility representatives unable to make the required sample collections during the wet season must include an explanation in the Annual Report as to why the sample collection could not be conducted.
The facility representative may conduct sample collection more than one hour after discharge begins if the facility representative determines that the objectives of the monitoring program will be better satisfied. The facility operator shall include an explanation in the Annual Report why the observation / collection was conducted after the first hour of discharge.
1.7 Sampling exemptions and reductions: Types
Under certain conditions, industrial facilities may qualify for an exemption from the required sample collections and analysis as part of their overall monitoring programs. There is currently one existing certification that can exempt facilities from the requirements of collecting and analyzing samples as part of their annual monitoring programs, as discussed below.
The No Exposure Certification is designed primarily for facilities where all industrial activities are conducted inside buildings and where all materials stored and handled are not exposed to stormwater. This certification is pursued through the San Diego Regional Water Quality Control Board. To qualify for this exemption, facility representatives must certify that their facilities meet the following conditions:
There are no unauthorized non-stormwater discharges emanating from the facility All authorized non-stormwater discharges have been identified and are addressed in the facility’s Stormwater Pollution Prevention Plan (SWPPP). All areas if past exposure have been inspected and cleaned, as appropriate There are no significant materials related to industrial activity (including waste materials) exposed to stormwater or authorized non-stormwater discharges No industrial activities or industrial equipment are exposed to stormwater or authorized non-stormwater discharges
7 There is no exposure of stormwater to significant materials associated with industrial activities through other pathways, such as from industrial activities that generate dust and particulates.
A facility representative periodically re-evaluates the facility to ensure that the above conditions are continuously met; this re-evaluation should be conducted at a minimum of once a year
1.8 Records
Records discussed in this section include all documentation associated with sample collection and analysis produced as part of the monitoring program. Additionally, any observations of note and corrective action made as a result of monitoring findings should be documented and maintained as part of the record collection process.
1.8.1 Retain records for at least five years
The facility representative is required to maintain records of all stormwater monitoring information and copies of all stormwater-related reports for a period of at least five years.
1.8.2 Information to be retained
Records should include:
The date, time, and location, of sampling
The individual(s) who performed the sampling
The date, time, and location, for any analyses performed The name of individual(s) who performed the analyses
Laboratory results, analytical methods employed, method detection limits (MDLs), and quality assurance / quality control results associated with the samples analyzed (if using a professional laboratory for analysis, this information will generally be supplied with the results by the laboratory)
Calibration and maintenance records of any instruments used by the facility representative Any applicable sampling and analysis exemption and reduction supporting documentation
1.9 Data analysis / evaluation methods
As mentioned above (Section 1.3), the relatively small number of monitoring events per year, combined with the high variability typical of stormwater data, preclude the use of sophisticated analysis methods. Therefore, the analysis and evaluation of monitoring data should rely on the following three methods:
Comparison of data values with any appropriate regulatory criteria, action levels, or screening values
Plotting of data values to facilitate observation of trends and comparison with relevant criteria, action levels, or screening values
Subjective interpretation of monitoring results that makes use of all available knowledge about the facility and its operation, as well as any visual observations and notes collected during monitoring.
Plotting for each monitored constituent should include all available data, extending back a minimum of ten years, if this length of record is available. Relevant regulatory criteria, action
8 levels, or screening criteria should be shown as a line on the plots. Any data values that are above such levels should be explained in detail.
The data analysis should include an assessment of data quality issues related to both the field sampling and/or measurement and the laboratory analyses. Any issues that may have affected the accuracy or precision of the data, or the interpretability of the results, should be reported and explained.
1.10 Reporting
Each facility shall submit an annual report to the Permittee by July 1 of each year. The report should use the format shown in Figure 2, which may be submitted in either hard copy or as an electronic spreadsheet. Reports, either in hardcopy or as spreadsheets, should use the exact spelling and column order shown in Figure 2, in order to facilitate data aggregation. In addition, monitoring results should be reported with the units shown in Table 3. Any exceptions to these formats should be highlighted in the facility’s annual report.
In addition to the information shown in Figure 2, the facility should provide:
A copy of laboratory reports, where available
An evaluation of analytical results
Any explanations required of why the facility did not implement any activities required by the Monitoring Program (if not already discussed in the evaluation report) Records discussed in Section 1.8.
The purpose of the standardized data reporting format in Figure 2 is to enable Permittees to readily aggregate data from multiple facilities within their jurisdictions and for the County to then aggregate data from multiple Permittees to identify regional trends and patterns in the monitoring results.
9 Table 1. Monitoring Program Analytes by Standard Industrial Classification Code Sector
SIC
Activity
TOC / TOG
TSS
pH
Cond.
Aluminum
Arsenic
Ammonia
Cadmium
Copper
Cyanide
Iron
Lead
Magnesium
Mercury
Phosphorous
Selenium
Silver
Zinc
COD
BOD
N+N
A TIMBER PRODUCTS
2421 General sawmills and planing mills • • • • • • 2491 Wood preserving • • • • • • 2426 Hardwood dimension and flooring mills • • • • • 2429 Special product sawmills • • • • • 243X Millwork, veneer, plywood, and structural wood (except 2434 – wood kitchen cabinet manufacturers) • • • • •
244X Wood containers • • • • • 245X Wood buildings and mobile homes • • • • • 2493 Reconstituted wood products • • • • • 2499 Wood products, not elsewhere classified • • • • • All others • • • •
B PAPER AND ALLIED PRODUCTS MANUFACTURING
263X Paperboard mills • • • • •
All others • • • •
C CHEMICAL AND ALLIED PRODUCTS MANUFACTURING
281X Industrial inorganic chemicals • • • • • • • 282X Plastics materials and synthetic resins, synthetic rubber, cellulosic, and other manmade fibers except glass • • • • •
10 Sector
SIC
Activity
TOC / TOG
TSS
pH
Cond.
Aluminum
Arsenic
Ammonia
Cadmium
Copper
Cyanide
Iron
Lead
Magnesium
Mercury
Phosphorous
Selenium
Silver
Zinc
COD
BOD
N+N
284X Soaps, detergents, and cleaning preparations;
perfumes, cosmetics, and other toilet preparations • • • • • • 287X Nitrogenous and phosphatic basic fertilizers, mixed fertilizer, pesticides, and other agricultural chemicals • • • • • • • • • All others • • • •
D
ASPHALT PAVING / ROOFING MATERIALS MANUFACTURERS & LUBRICANT MANUFACTURERS 29XX All subsectors • • • •
E
GLASS, CLAY, CEMENT, CONCRETE, & GYPSUM MANUFACTURING
325X Structural clay products • • • • • 326X Pottery and related products • • • • • 3297 Non-clay refractories • • • • •
327X Concrete, gypsum, and plaster products except lime (except 3274) • • • • •
3295
Minerals and earths, ground, or otherwise treated • • • • • All others
F PRIMARY METALS
331X
Steel works, blast furnaces, rolling and finishing mill • • • • • • 332X Iron and steel foundaries • • • • • • • • 335X
Rolling, drawing, and extruding of nonferrous metals • • • • • •
11 Sector
SIC
Activity
TOC / TOG
TSS
pH
Cond.
Aluminum
Arsenic
Ammonia
Cadmium
Copper
Cyanide
Iron
Lead
Magnesium
Mercury
Phosphorous
Selenium
Silver
Zinc
COD
BOD
N+N
336X Nonferrous foundries (castings) • • • • • •
All others
G
METAL MINING EXCEPT INACTIVE MINING ACTIVITIES ON FEDERAL LANDS WHERE AN OPERATOR CANNOT BE IDENTIFIED 102X Copper ores • • • • • •
All others • • • •
H COAL MINES AND COAL MINING-RELATED FACILITIES
12XX Coal mines and coal mining-related facilities • • • • • • All others • • • •
I COAL MINES AND COAL MINING-RELATED FACILITIES
13XX All subsectors • • • •
J
MINERAL MINING & DRESSING EXCEPT INACTIVE MINING ACTIVITIES ON FEDERAL LANDS WHERE AN OPERATOR CANNOT BE IDENTIFIED 144X Sand and gravel • • • • •
All others • • • •
K
HAZARDOUS WASTE TREATMENT STORAGE OR DISPOSAL FACILITIES 4953 Hazardous waste treatment storage or disposal • • • • • • • • • • • • • • All others • • • •
L LANDFILLS AND LAND APPLICATION SITES
12 Sector
SIC
Activity
TOC / TOG
TSS
pH
Cond.
Aluminum
Arsenic
Ammonia
Cadmium
Copper
Cyanide
Iron
Lead
Magnesium
Mercury
Phosphorous
Selenium
Silver
Zinc
COD
BOD
N+N
4953 Landfills and land application sites that receive or have received industrial wastes, except inactive landfills or land application sites occurring on federal lands where an operator cannot be identified • • • • • All others • • • •
M AUTOMOBILE SALVAGE YARDS
5015 Facilities engaged in dismantling or wrecking used motor vehicles for parts recycling or resale and for scrap • • • • • • • All others • • • •
N SCRAP RECYCLING FACILITIES
5093 Processing, reclaiming, and wholesale distribution of scrap and waste materials • • • • • • • • • •
All others • • • •
O STEAM ELECTRIC GENERATING FACILITIES
4911 Steam electric power generating facilities • • • • • All others • • • •
P
LAND TRANSPORTATION FACILITITES THAT HAVE VEHICLE AND EQUIPMENT MAINTENANCE SHOPS AND OR EQUIPMENT CLEAN OPERATIONS All subsectors • • • •
13 Sector
SIC
Activity
TOC / TOG
TSS
pH
Cond.
Aluminum
Arsenic
Ammonia
Cadmium
Copper
Cyanide
Iron
Lead
Magnesium
Mercury
Phosphorous
Selenium
Silver
Zinc
COD
BOD
N+N
Q
WATER TRANSPORTATION FACILITIES THAT HAVE VEHICLE AND EQUIPMENT MAINTENANCE SHOPS AND OR EQUIPMENT CLEANING OPERATIONS 44XX Water transportation • • • • • • • •
All others • • • •
R SHIP AND BOAT BUILDING OR REPAIRING YARDS
All subsectors • • • •
S AIR TRANSPORTATION FACILITIES
45XX
Air transportation facilities that have vehicle maintenance ships, material handling facilities, equipment cleaning operations, or airport and/or aircraft deicing / anti-icing operations • • • • • • • All others • • • •
T TREATMENT WORKS
All subsectors • • • •
U FOOD AND KINDRED PRODUCTS
207X Fats and oils • • • • • • •
All others • • • •
V
TEXTILE MILLS, APPAREL, AND OTHER FABRIC PRODUCT MANUFACTURERS All subsectors • • • •
W FURNITURE AND FIXTURES
14 Sector
SIC
Activity
TOC / TOG
TSS
pH
Cond.
Aluminum
Arsenic
Ammonia
Cadmium
Copper
Cyanide
Iron
Lead
Magnesium
Mercury
Phosphorous
Selenium
Silver
Zinc
COD
BOD
N+N
All subsectors • • • •
X PRINTING AND PUBLISHING
All subsectors • • • •
Y
RUBBER, MISC. PLASTIC PRODUCTS, & MISC. MANUFACTURING INDUSTRIES 301X Tires and inner tubes • • • • • 302X Rubber and plastics footwear • • • • • 305X Gaskets, packing, and sealing devices and rubber and plastics hose and belting • • • • •
306X
Fabricated rubber products, not elsewhere classified • • • • • All others • • • •
Z LEATHER TANNING AND FINISHING
All subsectors • • • •
AA FABRICATED METAL PRODUCTS
3429 Hardware, not elsewhere classified • • • • • • • • 3441 Fabricated structural metal • • • • • • • • 3442 Metal doors, sash, frames, molding, and trim • • • • • • • • 3443 Fabricated plate work (boiler shops) • • • • • • • • 3444 Sheet metal work • • • • • • • • 3451 Screw machine products • • • • • • • • 3452 Bolts, nuts, screws, rivets, and washers • • • • • • • • 3462 Iron and steel forgings • • • • • • • •
15 Sector
SIC
Activity
TOC / TOG
TSS
pH
Cond.
Aluminum
Arsenic
Ammonia
Cadmium
Copper
Cyanide
Iron
Lead
Magnesium
Mercury
Phosphorous
Selenium
Silver
Zinc
COD
BOD
N+N
3471
Electroplating, plating, polishing, anodizing, and coloring • • • • • • • • 3494 Valves and pipe fittings, not elsewhere classified • • • • • • • • 3496 Misc. fabricated wire products • • • • • • • • 3499 Fabricated metals products, not elsewhere classified • • • • • • • • 391X Jewelry, silverware, and plated ware • • • • • • • • 3479 Coating, engraving, and allied services • • • • • • All others • • • •
AB
TRANSPORTATION EQUIPMENT, INDUSTRIAL OR COMMERCIAL MACHINERY All subsectors • • • •
AC
ELECTRONIC, ELECTRICAL, PHOTOGRAPHIC, AND OPTICAL GOODS All subsectors • • • •
16 Table 2. Laboratory Standard Methods for Potential Industrial Monitoring Analytes 2a. FIELD SCREENING PARAMETERS
Analyte Method
pH pH Meter
Specific Conductance Conductivity Meter
Turbidity Turbidimeter – Nephelometric Method
Reactive Phosphorous HACH 8048 – Ascorbic Acid Method
Nitrate Nitrogen HACH 8039 – Cadmium Reduction Method
Ammonia Nitrogen HACH 10031 – Salicylate Method
Phenol HACH 8047 – 4 Aminoantipyrine Method
Copper, Dissolved HACH 8506 – Bicinchoninate Method
Chlorine, Total HACH 8167 – DPD Method
Surfactants (MBAS) HACH 8028 – Crystal Violet Method
Total Hardness (as CaC03) HACH 8213 – Digital Titrator Method with EDTA
17 2b. LABORATORY ANALYSES
Analyte Recommended
Method1
Recommended
Volume1
Recommended
Holding Time1
Oil & Grease – partition gravimetric EPA 1664 / Std. 5520B 1 liter 28 days Aluminum EPA 200.8 200 ml 6 months
Arsenic EPA 200.8 200 ml 6 months
Cadmium, Dissolved (ICP-MS) EPA 200.8 / Std. 3125B 200 ml 6 months Copper, Dissolved (ICP-MS) EPA 200.8 / Std. 3125B 200 ml 6 months Lead, Dissolved (ICP-MS) EPA 200.8 / Std. 3125B 200 ml 6 months Mercury EPA Method 1631M 100 ml 28 days
Selenium EPA 200.8 200 ml 6 months
Silver EPA 200.8 200 ml 6 months
Zinc, Dissolved (ICP-MS) EPA 200.8 / Std. 3125B 200 ml 6 months Diazinon & Chlorpyrifos (GCMS) EPA 525.2 1 liter 14 days Enterococcus Bacteria (MF) Std. 9230C 100 ml 6 hours
Total Coliform Bacteria (MF) EPA 9132 / Std. 9222B 100 ml 6 hours Fecal Coliform Bacteria (MF) Std. 9222D 100 ml 6 hours
TSS (Total Non-filterable Residue) EPA 160.2 / Std. 2540D 100 ml 7 days TOC / TOG (Total Organic Carbon /
Total Oil and Grease)
EPA 415 25 ml 28 days
Ammonia EPA 350 400 ml 28 days
Cyanide EPA 335 500 ml 14 days
Iron EPA 236 100 ml 6 months
Magnesium EPA 242 100 ml 6 months
COD (Chemical Oxygen Demand) EPA 410 50 ml 28 days
BOD (Biochemical Oxygen Demand) EPA 405.1 1 l 14 days
Notes:
1 Methods, sample containers, and sample handling details should all be worked out with the selected laboratory in advance of sample collections
18 Table 3. Reporting Formats for Monitored Variables
Field Measurements Laboratory Analyses
Parameter Format/Units Parameter Format/Units
Ammonia Nitrogen mg/l Aluminum g/l
Chlorine, Total mg/l Arsenic g/l
Copper, Dissolved g/l BOD
Nitrate, Nitrogen mg/l Cadmium, dissolved g/l
pH pH units Copper, dissolved g/l
Phenol mg/l Cyanide mg/l
Reactive Phosphorus mg/l as P Diazinon & Chloropyrifos g/l Specific Conductance umhos/cm Enterococcus cfu/100 ml
Surfactants (MBAS) mg/l Fecal Coliform
Temperature degrees C Iron mg/l
Total Hardness (as CaCO3) mg/l Lead, Dissolved g/l
Turbidity ntu Magnesium mg/l
Mercury g/l
Sample Identifiers Oil & Grease mg/l
Date YYMMDD Selenium g/l
Time of Collection Military Silver g/l
Time Since Runoff Began hh:mm TOC mg/l
Total Ammonia mg/l
Total Coliform cfu/100ml
TSS mg/l
Zinc, Dissolved g/l
19 Does facility have "no exposure
certification" from Regional Board?
Section 1.1
Is facility "high priority?"
Section 1.1
Contact City representative
to determine status No monitoring required
yes
no
Initiate monitoring program
yes
yes no
Identify sampling locations
Section 1.5.1
Coordinate with lab (e.g.,
lab methods, sampling
methods, reporting
requirements)
Section 1.5.4
Determine analytes
Section 1.5.3
Wait for appropriate storm
event
Section 1.5.2
Is storm event causing runoff
at sampling location?
Section 1.5.1
Can sampling be conducted soon
after runoff begins?
Section 1.5.2
no
yes
no
Sample using clean
techniques
Section 1.5.4
yes
Have two events been
sampled?
no
Produce report
Section 1.10
yes
Figure 1: Monitoring Implementation Procedures
20 Figure 2a. Standardized Data Reporting Form for Field Measurements Field Measurements
Ammonia Nitrogen Chlorine, Total Copper, Dissolved Nitrate Nitrogen pH Phenol Reactive Phosphorus Specific Conductance Surfactants (MBAS) Temperature Total Hardness (as CaCO3) Turbidity
(Facility Name)
(SIC Code(s))
(Date)
(Time)
(Time since runoff
began)
(Site)
(Sampler)
Entries shown in parentheses, e.g., (Date), should simply include the parameter value.
Thus the entry in the date field would be 112602, NOT Date: 112602.
21 Figure 2b. Standardized Data Reporting Form for Laboratory Analyses Laboratory
Analyses
Aluminum Arsenic BOD Cadmium, Dissolved COD Copper, Dissolved Cyanide Diazinon & Chlorphyrifos Enterococcus Fecal Coliform Iron Lead, Dissolved Magnesium Mercury Oil & Grease Selenium Silver TOC Total Ammonia Total Coliform TSS Zinc, Dissolved
(Facility
Name)
(SIC
Code(s))
(Date)
(Time)
(Time
since
runoff
began)
(Site)
(Sampler)
Entries shown in parentheses, e.g., (Date), should simply include the parameter value. Thus the entry in the date field would be 112602, NOT Date: 112602.
Local Implementation Plan
Section A-10
Illegal Discharges/Illicit
Connections Component
SECTION A-10, ILLEGAL DISCHARGES/ILLICIT CONNECTIONS
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-10-1
A-10.0 ILLEGAL DISCHARGES/ILLICIT CONNECTIONS COMPONENT A-10.1 Introduction
Since illegal discharges and illicit connections can be a significant source of pollutants from the municipal storm drain system, the City’s LIP includes a comprehensive program for detecting, responding to, investigating and eliminating these types of discharges/connections in an efficient and timely manner. In order to ensure that the program is efficient and effective, the City has instituted regular documentation procedures for their water pollution complaint and spill response activities.
The City of Yorba Linda has incorporated the Illegal Discharges/Illicit Connections (ID/IC) program as described in Section 10 of the Orange County Drainage Area Management Plan (DAMP) as the basis for its Local Implementation Plan (LIP). Subsequent sections of A-10 describe and outline guidelines, procedures and requirements for the City of Yorba Linda.
The ID/IC Program provides practical guidance for City staff when identifying, responding, mitigating and enforcing the ID/IC Program component for the protection of public health and the environment. The ID/IC Program provides the framework and a process for conducting the following NPDES permit compliance activities for illegal discharges and illicit connections:
• Program administration
• Detection of illegal discharges and illicit connections • Responding to water pollution incidents and complaints • Inspections/investigations
• Education/Enforcement
• Assessments of program effectiveness; and
• Annual training
In order to be effective, the ID/IC program has been integrated with the municipal, industrial, commercial, residential and construction inspection programs so that if an illegal discharge or illicit connection is discovered during an inspection it can be properly addressed and eliminated. In addition, on behalf of the Permittees, the Principal Permittee implements the water quality monitoring programs which can also assist in identifying illegal discharges and illicit connections.
SECTION A-10, ILLEGAL DISCHARGES/ILLICIT CONNECTIONS
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-10-2
A-10.1.1 Legal Authority
As was previously stated in the Legal Authority Section of the Local Implementation Plan (Section A-4), in order to effectively prohibit non-storm water discharges from entering the municipal storm drain system, in 1997 the City of Yorba Linda adopted a water quality ordinance. The ordinance is included as an attachment to Section A-4.
The legal authority for this LIP is referenced in DAMP Sections 4 and 10.
A-10.1.2 Overall Program Management
The LIP is provided to assist municipal staff in complying with the municipal storm water permits. The key staff responsible for overseeing, implementing, and enforcing the ID/IC storm water program component are identified in Figure A-10.I, and described in further detail below.
SECTION A-10, ILLEGAL DISCHARGES/ILLICIT CONNECTIONS
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-10-3
Figure A-10.I
Regional Board
City NPDES Program Management
Jevee Tagarao
Assistant Engineer
Parks and Recreation
Brad Skeen
Parks & Facilities Maintenance Superintendent
Public Works Department
Armando Jaime
Public Works Superintendent
Engineering Division
Regina Hul
Principal Engineer / Public Works
Department of Community Development
David Brantley
Community Development Director
Code Enforcement
Mary Lewis
Senior Community Preservation Officer
SECTION A-10, ILLEGAL DISCHARGES/ILLICIT CONNECTIONS
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-10-4
A-10.1.3 Program Implementation
The City of Yorba Linda has available resources to implement the spill response and Ordinance enforcement portions of the storm water program. The City provides 24-hour in-house response to Ordinance violations and spill incidents.
Figure A-10.II is the City of Yorba Linda’s flow chart to be utilized as a guide to determine the proper procedures for notification and response.
SECTION A-10, ILLEGAL DISCHARGES/ILLICIT CONNECTIONS
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) Page 579 of 740 A-10-5
SECTION A-10, ILLEGAL DISCHARGES/ILLICIT CONNECTIONS
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-10-6
Roles and Responsibilities
Authorized Inspectors
The Authorized Inspector(s) (AI) are assigned to investigate compliance with and detect incidences of violations of the Ordinance.1 The designated authorized inspectors are:
Contact Name: Mary Lewis
Title: Senior Community Preservation Officer
Telephone: (714) 961-7133
Contact Name: Travis Dizol
Title: Code Enforcement Officer
Telephone: (714) 961-7148
Contact Name: Karim Guerra
Title: Code Enforcement Officer
Telephone: (714) 961-7136
Contact Name: Jim Sowers
Title: Building Official
Telephone: (714) 961-7125
Contact Name: Regina Hu
Title: Principal Engineer / Public Works
Telephone: (714) 961-7170
Contact Name: Jevee Tagarao
Title: Assistant Engineer
Telephone: (714) 961-7170
Contact Name: Armando Jaime
Title: Public Works Superintendent
Telephone: (714) 961-7189
Contact Name: Daniel Mason
Title: Maintenance Contract Administrator
Telephone: (714) 961-7164
Contact Name: Brad Skeen
Title: Parks and Facilities Maintenance Superintendent
1 All City staff conducting field inspections/investigations are considered Authorized Inspectors. This list names the primary AIs in each relevant City Department.
SECTION A-10, ILLEGAL DISCHARGES/ILLICIT CONNECTIONS
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-10-7
Telephone: (714) 961-7168
Spill Responder
The Spill Responder (SR) can be an AI or other authorized personnel responsible for coordinating with the fire department for the immediate response to any accidental spills, leak or prohibited discharge of pollutants requiring clean-up. The designated spill responder is:
Contact Name: Armando Jaime
Title: Public Works Superintendent
Telephone: (714) 961-7189
Enforcing Attorney
The Enforcing Attorney is the City Attorney acting as counsel for the Permittee, and their appointee. For purposes of criminal prosecution, only the District Attorney or designee and/or City Attorney should act as the Enforcing Attorney.
A-10.2 Detection of Illegal Discharges and Illicit Connections The City of Yorba Linda has a number of programs that facilitate the detection of sources of illegal discharges and illicit connections.
These programs include the following:
• Municipal Activities (DAMP Section A-5) – field inspectors and facility managers assist in the identification of illegal discharges and illicit connections during their daily activities. For example, during the routine maintenance of a drainage facility, a field inspector will report any dumped materials and/or undocumented connections to the NPDES representative.
• Public Education (DAMP Section A-6) – assists with the distribution of public education materials that provide phone numbers and encourage the reporting of spills. • Construction Activities (DAMP Section A-8) - assists with the identification of illegal discharges from construction sites.
• Existing Development Programs (DAMP Section A-9) – assists with the identification of actual or threatened illegal discharges from industrial, commercial and residential areas. • Water Quality Monitoring Program (DAMP Section A-11) – assists with the identification of problem areas through the collection of water quality data. • Encourage the public to report water pollution problems to the countywide problem reporting hotline at (714) 567-6363.
SECTION A-10, ILLEGAL DISCHARGES/ILLICIT CONNECTIONS
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-10-8
A-10.3 General Spill Response Procedures (Excluding Sewage Spills) In addition to the proactive detection and elimination of threatened or occurring discharges, a large portion of the City of Yorba Linda’s ID/IC program is responding to water pollution complaints and incidents.
While all spills to municipal storm drain system are important and responses are often the same, sewage spills have merited special regulatory attention as coordination with other public agencies as well as private owners is often involved; for this reason sewage spill response procedures are covered separately.
The response procedures consist of the following elements:
• Record Keeping
• Notifications and Response Requests
• Response
o On-Scene Assessment/notifications
o Containment
• Investigations
• Clean-Up
o Decontamination
o Waste Storage and Disposal
o Cost Recovery
• Reporting
• Education and Enforcement
• Program Effectiveness Evaluation
A-10.3.1 Record Keeping
Information from a complaint, notification, or response request is accurately documented throughout the entire process in order to:
• Provide accurate information for any personnel involved in the incident; • Allow the data to be analyzed in order to determine if there are repeat offenders, problematic areas, problematic types of businesses, etc. • Ensure that the required regulatory notification and/or reports are completed; • Provide the required information for any enforcement actions and/or cost recovery; • Assist with the annual reporting and program effectiveness evaluations; and • Allow for better decision making when improving upon the program.
To ensure that the necessary information from a complaint, notification, or response request is accurately documented throughout the entire process, the City of Yorba Linda uses forms similar to the County’s Pollution Notification and Investigation Request (PNIR) form (Exhibit A-10.I)
SECTION A-10, ILLEGAL DISCHARGES/ILLICIT CONNECTIONS
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-10-9
This form collects information on the:
• Initial notification/response request;
• The location and specific details about the complaint or spill; • Information about the alleged responsible party;
• The results of the investigation; and
• The actions that were taken as a result.
Documentation may also include photographs, the collection of samples, detailed notes on observations, witness interviews, discussions on decisions made and other information relevant to the investigation.
After the initial entry of the information on the PNIR or related form, the information is entered into a database (HdL Code Enforcement System) so that the data can be analyzed and future enforcement activities focused on either problematic responsible parties, locations or constituents. In addition, the use of the database allows the city to quickly and accurately provide the information that is necessary for the annual progress reports.
A-10.3.2 Notifications and Response Requests
In order to have a successful ID/IC program, the City of Yorba Linda needs to obtain information about potential or existing complaints and spills as soon as possible so that the problem can be mitigated as quickly as possible.
In order to facilitate the reporting of problems by the general public, the city advertises the County’s 24 hour water pollution problem reporting hotline number (714-567-6363) as well as the website reporting form (www.ocwatersheds.com) on all of the public education brochures and posters.
In addition, the County’s 24-hour hotline number and web address are included in all Pacific Bell Regional Phone Directories. The hotline number is located in the Government Section of the White Pages while the web address can be found in the Internet Section of the Yellow Pages.
The city also coordinates with internal staff and other agency and emergency response personnel so that they understand how to identify a problem and who to report it to.
A-10.3.3 Response
After receiving a notification of a water pollution problem or spill, City of Yorba Linda either refers the problem to their internal Authorized Inspector and/or Spill Responder or to the County’s Authorized Inspector and/or Spill Responder. Each complaint or spill is investigated
SECTION A-10, ILLEGAL DISCHARGES/ILLICIT CONNECTIONS
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-10-10
as soon as possible and according to DAMP Section 10 to ensure that valuable information is not lost.
The Response includes the following elements:
• On-Scene Assessment;
• Notifications; and
• Containment
After conducting an on-scene assessment, several notifications may be necessary.
Notifications may include:
• Notification to Other Agencies—Notifications need to be made to any agencies or entities that may be affected by or have jurisdiction over the pollutant or discharge. • Requesting Assistance—If it is determined that the incident requires a multi-agency response, it may be necessary to request additional assistance from the other agencies.
The Agency Notification List is included in Exhibit A-10.I.
A-10.3.4 Investigations
The City of Yorba Linda’s Inspector or Responder carefully documents the investigation to ensure that accurate information is obtained and all evidentiary requirements are met. The types of equipment, supplies and forms that may be used in the field during the investigations are listed in Exhibit A-10.I.
The actual investigation may include one of more of the following:
• Collection of Samples and the submittal of a Chain of Custody form to the laboratory conducting the analyses;
• Photographs - If it is deemed necessary to take photographs to record visual observations and to document evidence for possible future enforcement action. The city uses a form to document the photographs taken; and
• Interviews – If it is deemed necessary to conduct interviews, the city uses a form to document the key pieces of information.
A-10.3.5 Clean-Up
The main objective in the clean-up operation is to restore the impacted area back to its original state (to the extent practicable) and prevent further environmental degradation in the surrounding area of the incident. It is important that the clean-up is completed in a timely and cost-effective manner.
SECTION A-10, ILLEGAL DISCHARGES/ILLICIT CONNECTIONS
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-10-11
During this phase of the response, the Inspector or Responder is generally overseeing and directing the cleanup and should re-evaluate the resources necessary to perform the clean-up and ensure that they are being prepared and sent to the site. The general responsibilities are:
• Provide list of clean-up companies for the RP to contact (Exhibit A-10.I); • Oversee clean-up—Provide clean-up directions and verify pollutant removal; • Document clean-up company’s activities (proper and safe procedures) to verify appropriate clean-up charges;
• Document amount of waste or pollutant removed to verify disposal costs The Authorized Inspector may also deliver to the owner or occupant of any property, or any other Person who becomes subject to an Administrative Remedy such as a Notice of Noncompliance or Administrative Order, an Invoice for Costs. The Invoice for Costs is immediately due and payable to the City of Yorba Linda for the actual costs incurred by the City in responding to, overseeing the clean up of and issuing and enforcing any notice or order.
A-10.3.6 Reporting
The ID/IC program has a number of reporting requirements. The requirements include:
• Proposition 65 Notification – Health and Safety Code 25180.7 provides that “Any designated government employee who obtains information in the course of his official duties revealing the illegal discharge or threatened illegal discharge of a hazardous waste within the geographical area of his jurisdiction, and who knows that such discharge or threatened discharge is likely to cause substantial injury to public health or safety, must, within 72 hours, disclose such information to the local health officer.”
The Proposition 65 Hotline telephone number is (714) 6567-3765 • Regional Board Notifications – If a spill, leak or illegal dumping is determined to pose a threat to human or environmental health the Permittees provide oral notification to the Regional Board by phone or e-mail within 24 hours of the discovery followed by a written report within 5 days.
Santa Ana Regional Board
At a minimum the items that are reported include:
o All sewage spills that reach surface waters and/or could impact water recreation o All reportable quantities of hazardous waste spills per 40 CFR 117 and 302 o Oil spills that could impact wild life
o Hazardous substance spills where residents are evacuated
SECTION A-10, ILLEGAL DISCHARGES/ILLICIT CONNECTIONS
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-10-12
The oral notifications are submitted within 24 hours to:
o Adam Fischer
Santa Ana Regional Water Quality Control Board
Telephone: (909) 321-4584
E-Mail: [email protected]
The key pieces of information that are included with the oral notification include:
a) The date and time of the incident
b) Reporting party contact information
c) A description of the incident
d) The location
e) Alleged responsible party contact information
f) Status on actions taken
The written reports are submitted within 5 days to:
Adam Fischer
Santa Ana Regional Water Quality Control Board
3737 Main Street, Suite 500
Riverside, CA 92501
In order to comply with this requirement, a completed PNIR or similar form is submitted to the Board.
A-10.4 Sewage Spill Response Procedures
While all spills to the municipal storm drain system are important and responses are often the same, sewage spills have merited special regulatory attention as coordination with other public agencies as well as private owners is often involved.
While the protocols used in responding to any type of spill are essentially the same, in compliance with Order No. R8-2009-0030, NPDES No. CAS618030 (Amended 2010, Fourth Term Permit), the City of Yorba Linda has developed and submitted an Overflow Emergency Response Plan to ensure that sanitary sewer overflows are responded to in a timely and efficient manner.
The city will utilize this Plan when responding to sewage spills.
A-10.4.1 Program Responsibilities
Although there are some instances where the municipal storm drain and sanitary sewage collection systems are under the same public agency (City) ownership, there are also many situations where the jurisdictions are not the same. Responding to overflows that reach the municipal storm drain system is, in these instances, a joint or shared responsibility of both (storm water and waste water) Permittees.
SECTION A-10, ILLEGAL DISCHARGES/ILLICIT CONNECTIONS
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-10-13
The Orange County Sanitation District currently has jurisdiction within the City of Yorba Linda’s service area and is responsible for preventive and corrective sewer maintenance programs. This program consists of procedures and methodologies provided for the operation, maintenance, repair and replacement of sewer mains, manholes, and pump stations. The program provides for routine monitoring, inspection, cleaning, and related maintenance of all components of the municipal sanitary sewer system in order to reduce the potential of sanitary sewer overflows (SSOs) and structural failures.
Regardless of where the spill originates, if the spill has entered or may enter the storm drain system the Permittees respond to assist with the cleanup and remediation of the area.
A-10.4.2 Record Keeping
To ensure that the necessary information is collected, the City of Yorba Linda uses forms similar to the County’s Pollution Notification and Investigation Request (PNIR) form (Exhibit A-10.I).
This form collects information on the:
• Initial notification/response request;
• The location and specific details about the complaint or spill; • Information about the alleged responsible party;
• The results of the investigation; and
• The actions that were taken as a result.
In addition to the information that is collected on the PNIR form, the following pieces of information are collected when documenting a sewage spill:
• Information regarding whether a sewage spill entered a storm drain (i.e. where sewage is observed running into a drain, or directly to a receiving water, creek, channel, etc. or there is residual evidence thereof), including the location and name of the receiving water;
• Determination of spill start and stop time;
• A determination of spill volume
A-10.4.3 Response
If not already completed upon arriving on scene, the discharge or release of sewage should be discontinued and contained as close to the originating site as possible after the initial assessment has been completed. This is critical in preventing further contamination or degradation downstream and will ultimately result in an easier and less expensive cleanup effort.
The order of preference for the containment would be:
SECTION A-10, ILLEGAL DISCHARGES/ILLICIT CONNECTIONS
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-10-14
• On-site at the point of origination
• In the curb/gutter or street
• In the catch basin
• In the storm drain system
• In the channels/streams
A-10.4.4 Clean-Up
The main objective in the clean-up operation is to restore the impacted area back to its original state (to the extent practicable) and prevent further environmental degradation in the surrounding area of the incident. During this phase of the response, the Inspector or Responder is generally overseeing and directing the cleanup and should re-evaluate the resources necessary to perform the clean-up and ensure that they are being prepared and sent to the site.
The general responsibilities are:
• Coordinate with sanitation districts or others for clean-up actions; • Provide list of clean-up companies for the responsible party (RP) to contact; • Secure spill site to prevent contact by the public;
• Oversee clean-up—Provide clean-up directions and verify pollutant removal. No readily identified residue, e.g., sewage solids, papers, etc. should remain; • Ensure that any debris that the wastewater was in contact with is removed for proper disposal;
• Disinfect where appropriate. If disinfected, the wastewater must be contained and disposed of properly;
• Document clean-up company’s activities (proper and safe procedures) to verify appropriate clean-up charges;
• Document amount of waste or pollutant removed to verify disposal costs; A-10.4.5 Reporting
Sewage spill reporting to various regulatory agencies has parallel and overlapping requirements. However, reporting spills to one regulatory agency will not necessarily satisfy the requirements of the other. Therefore, the City of Yorba Linda reports to the following agencies:
Storm Drain Discharges
• Regional Board Notifications – If a spill, leak or illegal dumping is determined to pose a threat to human or environmental health the Permittees report this information to the Regional Boards by phone or e-mail within 24 hours of the discovery followed by a written report within 5 days. (See Section A-10.5.6 above)
SECTION A-10, ILLEGAL DISCHARGES/ILLICIT CONNECTIONS
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-10-15
Sewage Discharger Notifications
• Orange County Health Care Agency (HCA) - California Health and Safety Code Section 5411.5 requires that all sewage spills be immediately reported to the HCA 24- hours a day. During standard work hours (M-F, 8:00 a.m. to 5:00 p.m.) sewage spills that may impact beaches or the ocean should be called in by phone directly to Regulatory Health Services, Environmental Health, Ocean Water Protection Program staff personnel at (714) 667-3660. After hours reports for emergency spills can be phoned in through the County Communications number (714) 628-7008. • State Office of Emergency Services (OES) - California Water Code Section 13271 and the CCR Section 2250 require that the State OES be notified immediately of all sewage spills of 1,000 gallons or more from public sewer systems by telephone • Santa Ana Regional Board - Order No. 2002-0014 requires that sewage dischargers immediately report all SSOs entering a storm drain, drainage channel, or surface water body to the Board by telephone, voice mail, e-mail, or FAX. Completed SSO Report Forms, or equivalent, for each and every overflow event must be submitted within five days of the initial notice. Full reports for each SSO occurrence including photos and mitigation measures must be submitted electronically to the RWQCB at the end of each month. Submittal of SSO Summary Reports and certification statements are also required 30 days following the spill report period.
A-10.5 Illicit Connections
As part of the municipal storm water program, the City of Yorba Linda detects and eliminates illicit connections within its municipal storm drain system.
Any illicit connection identified by the City of Yorba Linda during routine inspections is investigated. Appropriate actions are then taken to approve undocumented connections by permit procedure and/or pursue removal of those connections that are determined to be illicit connections and not permissible.
If evidence of an illegal discharge is detected and the source does not appear to be evident a source investigation may be conducted to determine if the discharge is being conveyed through an illicit connection.
A-10.5.1 Source Investigations
Source investigations may be conducted when an ID/IC is detected or suspected, and the source is not readily identifiable. The purpose of the investigation is to locate the source so that measures to eliminate the ID/IC can be implemented. Source investigations will be initiated when appropriate information suggests evidence of an ID/IC.
In order to assist in determining when source investigation studies are warranted, the Dry Weather Monitoring Program (DAMP Section 11.0) includes a set of criteria that will trigger focused IC/ID studies by the City when the monitoring data indicate the presence of a problem.
SECTION A-10, ILLEGAL DISCHARGES/ILLICIT CONNECTIONS
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-10-16
When the County has identified a site that meets the criteria, it will notify the City that followup IC/ID efforts may be necessary. However, if the monitoring program finds extreme conditions that represent a clear and immediate risk to human health or receiving water quality, or that provide unambiguous evidence of a substantial upstream problem, then this routine procedure will be bypassed and the relevant inspector for that City will be notified immediately.
In both kinds of instances, if the monitored site is near a jurisdictional boundary and the upstream drainage network for the site extends into a neighboring jurisdiction, both the jurisdiction containing the site as well as the jurisdiction containing the upstream portion of the drainage network will be notified.
A-10.5.2 Tracking a Pollutant Upstream
Once the City Authorized Inspector is notified of the potential problem and it is determined that a source investigation is warranted, the approach used for tracking a pollutant source upstream or identifying an illicit connection will primarily involve the steps as outlined in the DAMP Section 10 including:
• Step One - Initial Screening
• Step Two - Source Evaluations and Inspections
• Step Three – Monitoring
• Step Four – Document, Notify and Report
A-10.5.3 Elimination of ID/ICs
Depending on the type of ID/IC detected, the City will eliminate any discharge or connection by means of appropriate legal procedures. ID/ICs will be eliminated by contacting the appropriate supervisor who oversees the activities resulting in the discharge and notifying the individual of necessary actions.
The activities necessary will be directed by the Authorized Inspector (AI). A deadline for correcting the infraction with the required activities will be provided by the AI. In the event that the AI determines that the individual responsible for the ID/IC is incapable of performing the actions by the compliance date, or if the individual chooses not to perform the activities, the City may conduct the necessary measures, and charge the resulting costs to the individual.
Follow-up will be conducted to ensure that abatement activities have been successfully and adequately implemented.
A-10.6 Education and Enforcement
SECTION A-10, ILLEGAL DISCHARGES/ILLICIT CONNECTIONS
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-10-17
Enforcement activities within the City of Yorba Linda are undertaken according to the adopted Water Quality Ordinance and accompanying Enforcement Consistency Guide (DAMP Exhibit
4.I). Water pollution cases may be handled administratively or in more serious instances, be prepared for prosecution.
The City of Yorba Linda has formerly designated the staff responsible for carrying out the enforcement services according to the Enforcement Consistency Guide and updates these designations every year as a part of Annual Progress Report.
The City of Yorba Linda generally utilizes four types of remedies including:
• Educational letters;
• Administrative Remedies - Notices of Noncompliance, Administrative Compliance Orders, Cease and Desist Orders;
• Criminal Remedies – Misdemeanors, Infractions, Issuance of Citations; and • Other civil or criminal remedies as appropriate
A-10.6.1 Choosing the Type of Enforcement
The Enforcement Consistency Guide provides a framework to the Permittees for selecting the type of enforcement that should be pursued. Some of the factors that influence this decision include the duration and significance of the violation of threat, the cooperativeness and willingness of the responsible party to remedy the conditions, whether the incident is isolated or re-occurring and whether the violation or threat will affect or harm human health or the environment.
In order to be consistent countywide, the City of Yorba Linda staff use the Enforcement Options Diagram along with the Enforcement Response Matrix (Exhibit A-10.II) to assist them in determining which type of enforcement action should be used for any given incident.
The Enforcement Response Matrix
• Identifies common types of complaints and violations; • Identifies a range of initial and follow up responses; • Defines a range of enforcement actions based on the nature and severity of the violations; and
• Designates personnel responsible for administering each of these responses.
Although the discussion below provides some guidelines on the use of various enforcement tools, the Enforcement Consistency Guide is the primary document for the enforcement procedures and processes and is consulted when enforcement options are being considered or appeals of enforcement remedies have occurred.
A-10.6.2 Educational Letters
SECTION A-10, ILLEGAL DISCHARGES/ILLICIT CONNECTIONS
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-10-18
Although the Authorized Inspectors primarily rely on the administrative remedies as discussed below, there are still a few occasions when the City of Yorba Linda uses enforcement letters.
These situations may occur when:
• An authorized inspector believes that the water pollution complaint may be valid, but does not have evidence to substantiate it; and/or
• A second party, or resident, hires a contractor who causes an incident. In this case the contractor should receive the administrative remedy and the resident should receive an educational letter.
Exhibit A-10.II provides examples of the type of enforcement letter that the city sends to businesses and residents and includes information on language that can be inserted when providing information on alternative methods of disposal for a particular type of material.
Educational brochures, pamphlets, posters, magnets, etc. are included with the letter so that the responsible party has additional information regarding the proper handling/disposal of the materials involved in the complaint (e.g. pool water, concrete, dog waste, etc.).
Examples of the types of educational materials that are distributed include the following:
Carpet Cleaners
Restaurant Cleaning
Automotive Service Center
Gas Station
Horse and Livestock
Dog Waste
Mobile Car Wash
Pool Maintenance
Waste Oil Collection
Pest Control Products
Permitted Lot and Pool Drains
Car Wash Fundraisers
A-10.6.3 Administrative Remedies
The City of Yorba Linda generally utilizes four types of administrative remedies (Exhibit A10.II) including:
• Notices of Non-compliance – This is the least onerous enforcement tool and constitutes a basic request that the RP rectify the condition causing or threatening to cause noncompliance with the Ordinance.
The Notice of Non-compliance may be issued when one or more of the following circumstances exist:
o The violation or threat is not significant and has been short in duration o The RP is cooperative and has indicated a willingness to remedy the conditions o The violation or threat is an isolated incident
SECTION A-10, ILLEGAL DISCHARGES/ILLICIT CONNECTIONS
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-10-19
o The violation or threat does not affect and will not harm human health or the environment
Prior to the issuance of an Administrative Compliance Order or a Cease and Desist Order to a responsible party (RP), the Permittee first issues a Notice of Non-compliance, which states the act or acts constituting the violation and directs that the violation be corrected.
The Notice of Non-compliance should provide the RP with a reasonable time period to correct the violation before further proceedings are brought against the RP. However, a Notice of Non-compliance should not be the first enforcement method used if egregious or unusual circumstances indicate that a stronger enforcement method is appropriate. • Administrative Compliance Orders – This is an appropriate enforcement tool in the following circumstances:
o An actual condition of Non-compliance exists, but the condition cannot be remedied within a relatively short period of time
o The owner of the property or facility operator has indicated willingness to come into compliance by meeting milestones established in a reasonable schedule o The violation does not pose an immediate threat to human health or the environment
• Cease and Desist Orders – This is appropriate when the immediate action of the RP is necessary to stop an existing discharge, which is occurring in violation of the Ordinance.
The cease and desist order may also be appropriately issued as a first step in ordering the removal of nuisance conditions, which threaten to cause an unauthorized discharge of pollutants if exposed to rain or surface water runoff.
The cease and desist order may be issued when one or more of the following circumstances exist:
o The violation or threat is immediate in nature and may require an emergency spill response or immediate nuisance abatement if left unattended o The violation or threat exhibits a potential situation that may harm human health or the environment
o The AI's contacts with the property owner or facility operator indicate that further authority of the City [OC] may need to be demonstrated before remedial action is forthcoming
o The AI's prior Notices of Non-compliance have not obtained a favorable response
• Other Administrative Procedures or Civil Actions
SECTION A-10, ILLEGAL DISCHARGES/ILLICIT CONNECTIONS
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-10-20
o Where the city has issued a local permit, the AI may elect to initiate administrative proceedings to suspend, revoke or modify the permit if the permit terms are violated or if changed conditions occur.
o In consultation with the Enforcing Attorney, the AI may also consider the use of an injunction or other civil enforcement proceedings
A-10.6.4 Criminal Remedies
Criminal enforcement is appropriate when evidence indicates that the responsible party has acted willfully with intent to cause, allow to continue, or conceal a discharge in violation of the Ordinance.
The Permittees generally utilize three types of criminal remedies • Issuance of Citation - Where criminal enforcement is indicated, the AI may cause issuance of a citation to the responsible party. The citation shall include:
o The name and address of the violator
o The provisions of the Ordinance violated
o The time and place of required appearance before a magistrate The responsible party must sign the citation thereby promising to appear. If the cited party refuses to sign the citation, the AI may cause the arrest of the discharger, or may refer the matter to the Enforcing Attorney for issuance of a warrant for arrest. • Infractions - At the discretion of the Enforcing Attorney, misdemeanor acts may be treated as infractions. Factors that the EA may use in determining whether the misdemeanor is more appropriately treated as an infraction may include:
o The duration of the violation or threatened violation o The compliance history of the person, business or entity o The effort made to comply with an established compliance schedule o The existence of prior enforcement actions
o The actual harm to human health or the environment from the violation An infraction is punishable by a fine of not more than $100 for a first violation, $200 for a second violation, and a fine not exceeding $500 for each additional violation occurring within one year.
• Misdemeanors – Criminal enforcement is appropriate when evidence of non-compliance indicates that the violator of the Ordinance has acted willfully with intent to cause, allow to continue or conceal a discharge in violation of the Ordinance. Included in Exhibit A10.II is the case template that the City of Yorba Linda uses when developing a case against a responsible party.
SECTION A-10, ILLEGAL DISCHARGES/ILLICIT CONNECTIONS
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-10-21
A-10.6.5 Administrative Hearings
The ordinance provides for appeals of the Authorized Inspector’s decisions to a designated Hearing Officer. The final decisions of Hearing Officers are appeal able to the court with proper jurisdiction under statutory review procedures. For further information on the administrative hearing process see the Enforcement Consistency Guide.
A-10.7 Training and Outreach
Education and training of municipal and/or other agency staff is one of the keys to a successful storm water program. This is especially true with the ID/IC program because the Permittees will be in the public eye when conducting extensive investigation efforts and proceeding with enforcement actions. To assist the City of Yorba Linda municipal and/or other agency staff in understanding the Illegal Discharges and Illicit Connections Program, several different annual training sessions have been or are being developed (DAMP Appendix B-10).
In addition to Permittee sponsored training, staff are also encouraged to attend training seminars or workshops related to storm water management and water quality conducted by other organizations.
A-10.7.1 Training Modules
In order to adequately address the different areas of the Illegal Discharge and Illicit Connection Program element, four training modules have been developed.
The four training modules are:
• ID/IC Program Management Training (Exhibit B-10.I)
This training module is generally targeted for storm water program managers and will address the overall program framework, objectives and approach so that they may gain a broader understanding of how the program is developed and implemented at a local level. It also includes the tools necessary to determine program responsibilities, conduct investigations, utilize proper enforcement procedures and report incidents of noncompliance. • ID/IC Program Authorized Inspector Training (Exhibit B-10.II) This training module is generally targeted for authorized inspectors, spill responders and/or code enforcement officers and will address the responsibilities of the field personnel implementing the ID/IC Program. This training will include reporting requirements, spill response, inspection, clean-up and enforcement procedures. • ID/IC Program Sewage Spill Response Training (Exhibit B-10.III)
SECTION A-10, ILLEGAL DISCHARGES/ILLICIT CONNECTIONS
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-10-22
This training module is generally targeted for municipal authorized inspectors or spill responders as well as sanitation district staff and specifically focuses on the responsibilities of the field personnel in responding to sewage spills. The training will address a sewage spill from both the sanitation and municipal perspective and provide a framework for the responders to follow when responding to ensure that both sets of objectives are met.
• ID/IC Emergency Personnel Responders Training (Exhibit B-10.IV) This training module is generally targeted for fire and police department responders and focuses on the responsibilities that they have in responding to various types of water pollution complaints. The training will discuss the general response framework for the ID/IC program and discuss BMPs that should be used in emergency and nonemergency incidents.
A-10.7.2 Record Keeping
Records of training provided to staff are maintained to allow for a better determination of:
• Which staff require which training
• When training sessions were conducted
• Compliance with the permit requirements
A-10.8 Program Effectiveness Assessment
The overall Program Effectiveness Assessment (PEA) serves as the foundation for the submittal of the annual progress report that is submitted each year to the Principal Permittee and subsequently to the Regional Boards and serves as the basis for evaluating each municipality’s individual ID/IC efforts (See DAMP Appendix C-10).
The PEA allows each municipality to assess the effectiveness of their individual storm water program components including those focused on the detection and elimination of illegal discharges and illicit connections. The ID/IC program effectiveness evaluation will allow the City to assess the effectiveness of their local program by focusing on the data collected from the spill response, investigation and enforcement activities.
Exhibit A-10.I
Illegal Discharges/Illicit Connections
Water Pollution Complaints
Investigative/Notification Forms
Pollution Notification/Investigation Request Form
Agency Notification List
Field Investigation Equipment and Supplies
Sample Collection Log Sheet
Chain of Custody Form
Photographic Log Sheet
Witness Interview Form
List of Clean Up Companies
City of Yorba Linda
DEPARTMENT OF PUBLIC WORKS
Category: Notification Complaint Response Request Reconnaissance From: (name) (title/position) phone: ( )
( Federal/State Local Private company Public)
Company/Agency: Division:
Contact address: city: state: zip:
Comments: (other contacts; confidentiality, etc.) phone: ( ) Affected address: city: state: zip:
Extent of impact: (street, stormdrain, flood channel, etc.) (channel\facility name) map page/grid:
Reference: (distance from landmark/cross street(s); u/s or d/s from) GPS: lat: lon:
Complaint/Incident:
Notification/Request received by: date: __ __ /__ __ /__ __ Suspect/RP: (company/entity name) phone: ( )
Contact: (title/position) (name) phone: ( )
Address: city: state: zip:
Investigated by: date: __ __ /__ __ /__ __ time: ___ ___ : ___ ___ Material/Waste involved: (see back of form for waste categories) Estimated volume/quantity:
Investigation results:
Hours spent on investigation: (response) (documentation) (follow-up) Job Code: OC RH
Complainant/Requestor contacted in person by telephone date: __ __ /__ __ /__ __ Hazardous Materials Incident - HMI Report:
Enforcement: Enforcement letter Notice of Non-compliance Adminstrative Compliance Order Date: __ __ /__ __ /__ __ Cease and Desist Order Prosecution case Correction required:
Non-ER responsibility - referred to: (Agency/Dept.)
Contact: (name) phone: ( ) date: __ __ /__ __ /__ __ time: ___ ___ : ___ ___ Incident
Date: __ __ /__ __ /__ __
Time: ___ ___ : ___ ___
Form #________________
POLLUTION NOTIFICATION/INVESTIGATION REQUEST FORM
Agency Notification List
Situation Notify
Emergency Local Fire Dept. – 911
State Office of Emergency Services (800) 852-7550
Orange County Control One – (714) 628-7000
National Response Center – (800) 424-8802
NPDES Notification/Reporting
Regional Water Quality Control
Boards
Marc Brown
Santa Ana Regional Water Quality Control Board
3737 Main Street, Suite 500
Riverside, CA 92501
Telephone No. (909) 321-4584
E-mail - [email protected]
County Stormdrain/Flood channels County/PFRD
(714) 567-6363
Creeks & Streams California Department of Fish & Game
(310) 590-5412
Hazardous waste/Private Property
Impacts
County of Orange Health Care Agency
(714) 667-3700
Proposition 65 Notifications County of Orange Health Care Agency (714) 667-3765
Air Impacts Air Quality Management District
(909) 396-2360
Soil Impacts Department of Toxic Substances Control
(714) 484-5396
Sewage Spills Orange County Sanitation District
(714) 593-7025
Criminal Offense District Attorney - (714) 347-8716
Best Best & Krieger LLP – (949) 263-2400
Field Investigation Equipment and Supplies
Activity Equipment/Supplies # of
Items
Location
Safety Latex gloves
Leather gloves
Protective eyeglasses or goggles
Rubber boots
Elbow length nitrite gloves
Gas monitor (dependent on investigation)
First aid kit
Steel toed boots
Drinking water
Hat
Sunglasses
Sunscreen
Cell Phone/Radio
Field
Equipment
Measuring tape
Tool kit with nuts, bolts, screws, tie wraps
Automatic sampler/bottles
Paper towels
Duct tape, cellophane tape
Bungee cords
Folding ruler (measure flow depth)
Stop watch
Plastic bucket and rope
Sampling rod to collect samples
Extra batteries for all meters
Manhole cover puller
Field
Screening
Analysis
Portable field kits-colorimeters,
spectrophometer, and all reagents kit
(optional)
Waste disposal bottles
pH paper
Sample bottles
Multi-parameter or individual probes for
temperature, conductivity, and pH
Deionized water
Field Investigation Equipment and Supplies (cont’d)
Activity Equipment/Supplies # of
Items
Location
Laboratory
Analysis
Sample bottles with labels and
preservatives
Cooler with ice or cold packs
Chain of custody forms
Sample collection equipment described
above
Documentation Camera (digital preferred)
Field notebook
Pens-regular and waterproof, pencils
Enforcement forms
Educational materials
Clipboard
Inspection forms
Reference
Materials
Municipal Storm Drain System map
Street map
Emergency contact phone numbers
Data summary from previous
investigations/sampling results
Form#:
Sheet of
SAMPLE COLLECTION LOG SHEET
Sample
Time
Location / Notes Sampler Test Method
Sample
Log Book
Number Date
1 WR
2 WR
3 WR
4 WR
5 WR
6 WR
7 WR
8 WR
9 WR
10 WR
PAGE of
LOCATION: Analyzed samples disposed of after days.
Analyzed samples returned to OC/PFRD.CONTRACT LAB:
CONTACT: (714) - PA #
PNIR # JOB #
SAMPLE # DATE & TIME # CONTAINERS MATRIX DESCRIPTION ANALYSES REQUIRED REMARKS City of Yorba Linda
CHAIN OF CUSTODY
PHONE FAX
Address
ORGANIZATION DATE TIME
/ / :/ / :/ / :/ / :/ / :/ / :/ / :/ / :
AQ Aqueous GW Groundwater C Composite
SW Seawater RW Rainwater ID Integrated Depth
Received by
SIGNATURE PRINT NAME
Relinquished byRelinquished byReceived byRelinquished byReceived by SF Surface
BT Bottom
Relinquished byReceived by
MATRIX DESCRIPTION
SW Seawater RW Rainwater ID Integrated Depth
SO Soil SD Sediment
BT Bottom
G Page 603 of 740 Grab
Form#:
Sheet of
PHOTOGRAPHIC LOG SHEET
Inspector(s):
Photo Time Date 35MM,
Digital, or
Polaroid
Location/Description
1 2
3 4
5 6
7 8
9 10
11 12
13 14
15 16
17 18
19 20
21 22
23 24
25
Form#:
Sheet of
WITNESS INTERVIEW FORM
1. Last Name: First Name: Middle:
Home Address: City: State/Zip:
Home Phone: Business Phone: Cellular/Pager:
Witness Statement:
Interviewed by: Date: Time:
2. Last Name: First Name: Middle:
Home Address: City: State/Zip:
Home Phone: Business Phone: Cellular/Pager:
Witness Statement:
Interviewed by: Date: Time:
LOCAL EMERGENCY RESPONSE CLEAN-UP COMPANIES
MAJOR CLEAN-UP SPECIALTY/COMMENTS
ADVANCED CLEANUP TECHNOLOGIES, INC. (A.C.T.I) Complete service/24 hrs 20928 Lamberton Avenue
Carson, CA 90810
(800)334-ACTI (2284) or
(310)763-1423
CLEAN COASTAL WATERS, INC. Marine spills/24 hrs
190 S. Pico Avenue
Long Beach, CA 90802-1097
(562)432-1415
(562)437-1510 – fax
ECOLOGY CONTROL INDUSTRIES Complete service/24 hrs
20846 Normandy Avenue
Torrance, CA 90502
(800)262-1900
(800)236-7324 – 24 hr #
SAFETY KLEEN (LOS ANGELES) Complete service
East D Street
Wilmington, CA 90744
(562)590-8531 – pgr. Reggie Pestano, Tech. Sales Rep.
(562)499-6961
(562)495-1845 – fax
OCEAN BLUE ENVIRONMENTAL SERVICES Complete service/24 hrs 925 West Esther St. contact Scott Tracy, GM
Long Beach, CA 90813
(562)624-4120
(562)624-4127 – fax
SMALL TO MEDIUM SIZED CLEAN-UP
ADVANCED ENVIRONMENTAL Complete service24 hrs
13579 Whittram Avenue
Fontana, CA 92335-2950
(909)356-9025
ANCON MARINE Complete service/24 hrs
1010 S. Cabrillo Avenue Marine spills
San Pedro, CA 90731
(310)548-8300
(310)548-8357 – fax
CAL HAZARDOUS SERVICE Complete service/24 hrs
1431 E. St. Andrew Place 7 man crew handle small
Santa Ana, CA 92705 spills
(714)434-9995
CONSOLIDATED WASTE INDUSTRIES, INC. Complete service/24 hrs 10680 Silicon Avenue drug labs
Montclair, CA 91763
(800)233-3748 or
(909)625-6645
ENVIRONMENTAL DYNAMICS Complete service/24 hrs
22222 S. Wilmington Avenue
Carson, CA 90745
(310)952-9812
ENVIRONMENTAL TRANSLOADING SERVICES Complete service/24 hrs 1313 E. Sixth Street
Los Angeles, CA 90021
(213)628-8000 or
(800)628-8000
(213)628-0106 fax
LOCAL EMERGENCY RESPONSE CLEAN-UP COMPANIES (cont’d)
SMALL TO MEDIUM SIZED CLEAN-UP (Cont’d)
ENVIRONMENTAL SERVICES Complete service/24hrs
1801-B E. Parkcourt Place, Ste.120
Santa Ana, CA 92701
(800)49-WASTE or (714)569-0909
GRAY, THOMAS & ASSOCIATES, INC. Radioactive and chemical waste 1205 W. Barclay Avenue 24 hr service
Orange, CA 92668
(714)997-8090
(714)997-3561 – fax
HAZPAK, INC. Complete service/24 hrs
9980 Cherry Avenue
Fontana, CA 92335
(800)326-1011
(909)822-7552 – fax
INDUSTRY WASTE UTILIZATION
5601 State Street
Montclair, CA 91763
(909)984-9984
(909)984-1510 – fax
MARTIN ENVIRONMENTAL SERVICES Complete service/24 hrs
P. O. Box 1128
Canyon Country, CA 91386-1920
(800)624-9136
(714)212-2048 Judy Weston/pager
NEITO AND SONS Pumping/24 hrs
1281 Brea Canyon Road
Brea, CA 92821
(714)990-6855
(714)990-4862 – fax
OILFIELD TRUCKING & TRANSPORTATION Vacuum truck & high
1300 N. Lakeview pressure steam cleaning
Anaheim, CA 92807 24 hrs – transport only
(714)693-7088
ORANGE COUNTY SEPTIC SERVICE & SANITATION CO. Pumping
P.O. Box 10415 24 hr emergency only with
Santa Ana, CA 92711 permission to dump from
(714)540-5181 or sanitation department
(714)505-9662
(714)505-9610 – fax
PHILIP WEST INDUSTRIAL SERVICE Complete service/24 hrs
2222 E. Sepulveda Blvd.
Carson, CA 90810-1941
(562)595-1000
(800)275-3660
PORT- A-POTTIE Pumping
(800)638-1233 x302 regular business hrs M-F, 6-6.
STERICYCLE Medical waste/bio-hazard
1201 N. Barsten Way 8-5, M-F only
Anaheim, CA 92806
(714)666-2092
UNITED PUMPING SERVICE Complete service/24 hrs
14016 E. Valley Blvd.
Industry, CA 91746
(626)961-9326
Exhibit A-10.II
Illegal Discharges/Illicit Connections
Water Pollution Complaints
Education/Enforcement Forms
Enforcement Options Diagram
Enforcement Options Matrix
Sample Educational/Enforcement Letters
Notice of Non-Compliance Form
Administrative Compliance Order Form
Cease and Desist Order Form
Case Template
Enforcement Options Diagram
CRIMINAL ACTIONS
NOTICE OF NON-COMPLIANCE ADMINISTRATIVE COMPLIANCE ORDER CEASE & DESIST ORDER INFRACTIONS AND MISDEMEANORS
COMPLIANCE STRATEGY
Threat Level Insignificant Not Significant Might be Significant Significant Environmental Harm None Not Immediate Potential/Immediate Actual/Immediate Event Duration Short Short Long/Continuous Long/Continuous Event Frequency Isolated Infrequent Frequent/Ongoing Frequent/Ongoing
ADMINISTRATIVE ACTIONS
ENFORCEMENT OPTIONS
EDUCATE VIOLATOR
AUTHORIZED
INSPECTORS'
JUDGEMENT
CRIMINAL
PROSECUTION
Cooperation Readily Complies Working to Comply Uncooperative/Slow to Comply Non-Responsive Intent Unknowingly Not Wilfull Possible Willful Willful
Enforcement Response Matrix
Illicit Connection
Type of Response Nature of Violations Enforcement Responses Personnel
1. Non-Emergency RP unaware of connection,
cooperates with mitigation
Notice of Non-compliance Admin Compliance Order Recovery of Costs AI
RP unaware of connection, does not cooperate with mitigation Notice of Non-compliance Admin Compliance Order Cease and Desist Order Recovery of Costs Citation AI, CA
RP aware of connection, cooperates with mitigation
Notice of Non-compliance Admin Compliance Order Recovery of Costs Citation AI, CA
RP aware of connection, does not cooperate with mitigation Notice of Non-compliance Admin Compliance Order Cease and Desist Order Recovery of Costs
AI, CA, DA
2. Emergency Illicit connection causing harm
to storm drain system, RP cooperates with mitigation
Notice of Non-compliance Admin Compliance Order Cease and Desist Order Recovery of Costs
AI, CA, DA
Illicit connection causing harm to storm drain, RP does not cooperate with mitigation Cease and Desist Order Recovery of Costs Citation
AI, CA, DA
Enforcement Response Matrix
Illegal Discharge
Type of Response Nature of Violations Enforcement Responses Personnel
1. Non-Emergency RP unaware of requirement; no
harm to storm drain or environment, RP cooperates
Education Notice of Non-compliance Recovery of Costs AI
RP unaware of requirement; no harm to environment, RP does not cooperate Education Notice of Non-compliance Recovery of Costs AI, CA
RP unaware of requirement; harm to storm drain or environment, RP cooperates Admin Compliance Order Cease and Desist Order Recovery of Costs AI, CA
RP unaware of requirement; harm to storm drain or environment, RP does not cooperate Admin Compliance Order Cease and Desist Order Recovery of Costs Other Civil Actions
AI, CA, DA
RP aware of requirement; no harm to storm drain or environment, RP cooperates Admin Compliance Order Cease and Desist Order Citation Recovery of Costs AI, CA
RP aware of requirement; no harm to storm drain or environment, RP does not cooperate Cease and Desist Order Recovery of Costs Citation Other Civil Actions
AI, CA, DA
RP aware of requirement; harm to storm drain or environment, RP cooperates Recovery of Costs Cease and Desist Order Citation AI, CA
RP aware of requirement; harm to storm drain or environment, RP does not cooperate Cease and Desist Order Recovery of Costs Citation/ Other Civil Actions
AI, CA, DA
Enforcement Response Matrix
Illegal Discharge
Type of Response Nature of Violations Enforcement Responses Personnel
2. Emergency Hazardous waste discharge RP
cooperates, no discharge to storm drain
Notice of Non-compliance Cease and Desist Order Recovery of Costs AI, CA
Hazardous waste discharge RP does not cooperate, no discharge to storm drain Notice of Non-compliance Cease and Desist Order Recovery of Costs Citation
AI, CA, DA
Hazardous waste discharge RP cooperates, discharge to storm drain Notice of Non-compliance Cease and Desist Order Recovery of Costs Citation AI, CA
Hazardous waste discharge RP does not cooperate, discharge to storm drain Notice of Non-compliance Cease and Desist Order Recovery of Costs Citation Other Civil Actions
AI, CA, DA
AI – Authorized Inspector CA – City Attorney DA – District Attorney
SAMPLE LETTER FOR A RESIDENT
[On Letterhead]
[Date]
[Resident’s Name (“Resident”, if not available)]
[Resident’s Address]
Subject: [Type of Discharge] Discharge
Dear [Resident’s Name (“Resident”, if not available)]:
On [date], this Department received a complaint of a [type of discharge] discharge originating from your home located at [resident’s address], in [city]. Upon inspection, staff observed [inspection results]. This letter is to explain why this discharge is of concern to public agencies and to suggest that an alternate method for the proper disposal of this material be used henceforth.
Federal, State and local laws prohibit non-stormwater discharges into the stormdrain system. Non-stormwater releases, which include chemicals, detergents, paints, construction materials and automotive wastes, contribute to non-point source pollution.
These pollutants are washed into stormdrains by rain and irrigation run-off and occasionally, deliberate flushing, impacting rivers, streams and ultimately, the ocean. A brochure entitled "Do You Know Where The Water In Your Storm Drain Goes? [or appropriate brochure title]", enclosed with this letter, more fully explains the issue of nonpoint source pollution and the reason for its focus as a municipal control program.
You and your contractor [if appropriate] are commended for the cooperation and prompt action in removing the [type of discharge] from the street. However, in the future, [insert appropriate alternative method of disposal]. By ensuring the careful disposal of your waste, you will make a significant contribution toward keeping pollutants out of Orange County's creeks, streams, and sensitive receiving waters.
Please direct any questions regarding this letter to [investigator’s name] at [phone number].
Enclosure: "Do You Know Where The Water In The Storm Drain Goes? [or appropriate brochure title]" Brochure
cc: ex: Santa Ana Regional Water Quality Control Board
[include other interested parties where appropriate]
SAMPLE LETTER FOR A BUSINESS
[On Letterhead]
[Date]
[Owner’s or Business Contact’s Name (“Business Owner” if not available)] [Business Name]
[Business Address]
Subject: [Type of Discharge] Discharge
Dear [Owner’s or Business Contact’s Name (“Business Owner” if not available)]:
On [date], this Department received a complaint of a [type of discharge] discharge originating from a residence located at [customer’s address], in [city]. Upon inspection, staff observed [inspection results]. This letter is to explain why this discharge is of concern to public agencies and to suggest that an alternate method for the proper disposal of this material be used henceforth.
Federal, State and local laws prohibit non-stormwater discharges into the stormdrain system. Non-stormwater releases, which include chemicals, detergents, paints, construction materials and automotive wastes, contribute to non-point source pollution.
These pollutants are washed into stormdrains by rain and irrigation run-off and occasionally, deliberate flushing, impacting rivers, streams and ultimately, the ocean. A brochure entitled "The Ocean Begins At Your Front Door [or another appropriate brochure]", enclosed with this letter, more fully explains the issue of non-point source pollution and the reason for its focus as a municipal control program.
You and your employees are commended for the cooperation and prompt action [if appropriate] in removing the [type of discharge] from the street. However, in the future, you should [insert appropriate alternative method of disposal]; in addition, develop a series of operational guidelines for environmental protection and regularly train your employees on their implementation. By ensuring the careful disposal of your waste, you will make a significant contribution toward keeping pollutants out of Orange County's creeks, streams, and sensitive receiving waters.
Please direct any questions regarding this letter to [investigator’s name] at [phone number].
Enclosure: "The Ocean Begins At Your Front Door [or appropriate brochure title]" Brochure
cc: ex: Santa Ana Regional Water Quality Control Board
[include other interested parties where appropriate]
ALTERNATIVE METHODS OF DISPOSAL FOR ENFORCEMENT LETTERS Cement Discharge
Business & Resident:
- allow the material to dry prior to disposing it with household solid waste Carpet Cleaning Waste Discharge
Business & Resident:
- disposal to a sanitary sewer (upon approval from your local sanitary district) Degreasing Washwater
Business:
- disposal to a sanitary sewer (upon approval from your local sanitary district) Paint Wastes
Resident:
- latex paint, allow the paint to dry and dispose of it with household trash - oil-based paint, dispose of the paint as a hazardous waste at the nearest Household Hazardous Waste collection center
Business:
- latex paint, allow the paint to dry and dispose of it with solid waste - oil-based paint, dispose of the paint as a hazardous waste Swimming Pool Water
Business & Resident:
- pool water can be discharged provided the water quality meets certain criteria Oil Residue
Business & Resident:
- placing a drip pad underneath the car to collect the oil - promptly cleaning up any spills
Steam Cleaning Discharge
Business:
- wastewater needs to be contained, collected and either disposed of to the sanitary sewer (upon approval from your local sanitary district) or disposed of as hazardous waste
Vehicle Washwater
Business:
- all vehicle washing should be conducted at a facility that is routed to the sanitary sewer (upon approval from your local sanitary district)
CITY OF YORBA LINDA
ORANGE COUNTY, CALIFORNIA
[PNIR NUMBER]
NOTICE OF NON-COMPLIANCE
DATE TIME A.M. DAY OF WEEK
P.M.
NAME (FIRST, MIDDLE, LAST) DELIVERED TO (IF DIFFERENT)
RESIDENCE ADDRESS CITY ZIP
BUSINESS ADDRESS (if applicable) CITY ZIP
EMPLOYED BY (if applicable) OCCUPATION (if applicable)
Violation(s) of City’s Water Quality Ordinance
On or about , the undersigned Authorized Inspector identified the following violation(s) of the City’s Water Quality Ordinance, existing at or near:
1. Illicit Connection (Section 4-13-40 (a) (1))
2. Prohibited Discharge (Section 4-13-40 (a) (2))
3. Agent/employee/independent contractor Illicit
Discharge/Prohibited Discharge (Section 4-13-40 (a) (3))
4. Discharge Exception inapplicable (following 30 day written notice ) (Section 4-13-40 (d))
5. Failure to Comply with New Development/Significant Redevelopment Conditions: (Section 4-13-50 (f)(1))
6. Litter (Section 4-13-52)
7. Failure to Comply with Administrative Compliance
Order/Cease & Desist Order issued ,
20 (Section 4-13-73)
8. Failure to comply with terms of Discharge permit
(Section 4-13-80 (c) (1)): (specify provisions of permit which violated):
9. Other (specify section and violation):
Conditions Observed
1. 2.
3. Notice of Noncompliance
The Party identified above is hereby notified that the continuance of the conditions above stated, whether ongoing or intermittent, will result in additional enforcement action in accordance with the City’s Water Quality Ordinance.
Compliance Date
(Not to exceed 90 days, unless the Authorized Inspection determines that good cause exists for an extension) On or before , 20 , Party shall correct the above conditions by:
1. Eliminating the Illicit Connection;
2. Eliminating the Prohibited Discharge
3. Coming into compliance with conditions of approval of New Development/Significant Redevelopment; or 4. Coming into compliance with a permit issued by the County. 5. Other:
Signed: Date:
Authorized Inspector
Environmental Resources
1750 S. Douglass Rd., Anaheim, CA 92806
Phone: ( 714) 567-6363
Appeal Rights
Any appeal from issuance of this Administrative Compliance Order must be filed within thirty (30) days of receipt of this compliance order by filing a written request for an administrative hearing with the Office of the Orange County Board of Supervisors, located at 10 Civic Center Plaza, Room 465, P.O. Box 687, Santa Ana, CA 92702, with a copy of the request for administrative hearing mailed on the date of filing to the Director of Public Facilities and Resources Department at P.O. Box 4048, Santa Ana, CA 92702-4048. (Section 4-13-70 (g) of Ordinance)
CITY OF YORBA LINDA
ORANGE COUNTY, CALIFORNIA
[PNIR NUMBER]
ADMINISTRATIVE COMPLIANCE ORDER
DATE TIME A.M. DAY OF WEEK
P.M.
NAME (FIRST, MIDDLE, LAST) DELIVERED TO ( IF DIFFERENT)
RESIDENCE ADDRESS CITY ZIP
BUSINESS ADDRESS (if applicable) CITY ZIP
EMPLOYED BY (if applicable) OCCUPATION (if applicable)
Legal Authority
The following findings are made and order issued pursuant to the authority vested in the undersigned Authorized Inspector, under Section 4-13-70 (b) (1) of City’s Water Quality Ordinance. This order is based on the following violation(s) of the Water Quality Ordinance.
1. Illicit Connection (Section 4-13-40 (a) (1))
2. Prohibited Discharge (Section 4-13-40 (a) (2))
3. Agent/employee/independent contractor Illicit
Discharge/Prohibited Discharge (Section 4-13-40 (a) (3))
4. Discharge Exception inapplicable (following 30 day written notice ) (Section 4-13-40 (d))
5. Failure to Comply with New Development/Significant Redevelopment Conditions: (Section 4-13-50 (f)(1))
6. Litter (Section 4-13-52)
7. Failure to Comply with Administrative Compliance
Order/Cease & Desist Order issued ,
20 (Section 4-13-73)
8. Failure to comply with terms of Discharge permit
(Section 4-13-80 (c) (1)): (specify provisions of permit which violated):
9. Other (specify section and violation):
Conditions Observed
On or about , 20 ,the following conditions existing at or near (“Location”), constituted a violation of the City’s Water Quality Ordinance, as follows:
1. 2.
3. Order
THEREFORE, BASED ON THE ABOVE CONDITIONS, THE PARTY IS HEREBY ORDERED TO:
1. 2.
3. Notices
All reports, data, information or other documentation required to be provided pursuant to the terms hereof shall be sent, in writing to the following address:
Terms of Issuance
This order does not constitute a waiver of any provisions of the County’s Water Quality Ordinance, or of any plan or permit issued pursuant thereto, which remain in full force and effect. The City reserves the right to seek any and all remedies available to it under the Water Quality Ordinance for any violation cited by this Order.
This order, issued this day of , 20 , shall be effective upon receipt by Party, and all rights of review and appeal shall be as provided in the City’s Water Quality Ordinance.
Signed: Date:
Authorized Inspector
Environmental Resources
1750 S. Douglass Rd., Anaheim, CA 92806
Phone: ( 714 ) 567-6363
Appeal Rights
Any appeal from issuance of this Administrative Compliance Order must be filed within thirty (30) days of receipt of this compliance order by filing a written request for an administrative hearing with the Office of the Orange County Board of Supervisors, located at 10 Civic Center Plaza, Room 465, P.O. Box 687, Santa Ana, CA 92702, with a copy of the request for administrative hearing mailed on the date of filing to the Director of Public Facilities and Resources Department at P.O. Box 4048, Santa Ana, CA 92702-4048. (Section 4-13-70 (g) of Ordinance)
CITY OF YORBA LINDA
ORANGE COUNTY, CALIFORNIA
[PNIR NUMBER]
CEASE AND DESIST ORDER
DATE TIME A.M. DAY OF WEEK
P.M.
NAME (FIRST, MIDDLE, LAST) DELIVERED TO ( IF DIFFERENT)
RESIDENCE ADDRESS CITY ZIP
BUSINESS ADDRESS (if applicable) CITY ZIP
EMPLOYED BY (if applicable) OCCUPATION (if applicable)
Legal Authority
The following findings are made and order issued pursuant to the authority vested in the undersigned Authorized Inspector, under Section 4-13-70 (b) (1) of City’s Water Quality Ordinance. This order is based on the following violation(s) of the Water Quality Ordinance.
1. Illicit Connection (Section 4-13-40 (a) (1))
2. Prohibited Discharge (Section 4-13-40 (a) (2))
3. Agent/employee/independent contractor Illicit
Discharge/Prohibited Discharge (Section 4-13-40 (a) (3))
4. Discharge Exception inapplicable (following 30 day written notice ) (Section 4-13-40 (d))
5. Failure to Comply with New Development/Significant Redevelopment Conditions: (Section 4-13-50 (f)(1))
6. Litter (Section 4-13-52)
7. Failure to Comply with Administrative Compliance
Order/Cease & Desist Order issued ,
20 . (Section 4-13-73)
8. Failure to comply with terms of Discharge permit
(Section 4-13-80 (c) (1)): (specify provisions of permit which violated):
9. Other (specify section and violation):
Conditions Observed
The Party identified above has violated the City’s Water Quality Ordinance and continuing and/or intermittent violations may occur in contravention of the Water Quality Ordinance due to the following facts and circumstances:
1. 2.
Order
UPON RECEIPT OF THIS ORDER, PARTY SHALL IMMEDIATELY CEASE THE ABOVE ACTIVITIES AND THE
OPERATIONS RELATED THERETO SHALL NOT RECOMMENCE UNTIL SUCH TIME AS PARTY IS ABLE TO DEMONSTRATE THAT IT WILL COMPLY WITH THE CITY’S WATER QUALITY ORDINANCE AND ANY PLAN OR PERMIT
ISSUED PURSUANT THERETO AND THE CITY PROVIDES WRITTEN AUTHORIZATION TO ALLOW RESUMPTION OF ACTIVITIES.
THEREFORE, BASED ON THE ABOVE CONDITIONS, THE PARTY IS HEREBY ORDERED TO:
1. 2.
3. Terms of Issuance
This order does not constitute a waiver of any provision of the City’s Water Quality Ordinance, or any plan or permit issued pursuant thereto, which remain in full force and effect. The City reserves the right to seek any and all remedies available to it under the Water Quality Ordinance for any violation cited by this order.
Failure to comply with the requirements of this order shall constitute a further violation of the Water Quality Ordinance and may subject the Party to civil or criminal penalties or such other appropriate enforcement response as may be appropriate.
This order, entered into this day of , 20 , shall be effective upon receipt by Party, and all rights of review and appeal shall be as provided in Section 4-13-70 (h) of the City’s Water Quality Ordinance.
Signed: Date:
Authorized Inspector
Environmental Resources
1750 S. Douglass Rd., Anaheim, CA 92806
Phone: (714 ) 567-6363
Administrative Hearing Unless otherwise waived in writing by the party who is subject to this Cease and Desist Order, an administrative hearing regarding the issuance of this Cease and Desist Order shall be held on ,20 or at a time to be determined by separate notification, at the Office of the Orange County Board of Supervisors, located at 10 Civic Center Plaza, Room 465, P.O. Box 687, Santa Ana, CA 92702. At that time, the party who is subject to this order shall be entitled to present evidence in opposition to the issuance of this Cease and Desist Order. (Section 4-13-70 (i))
(Case Transmittal must be in 1” three-ring binder, with labeled tabs) Department of Public Works
4845 Casa Loma Avenue
P.O. Box 87014
Yorba Linda, CA 92886
SUBJECT: Name of Business
SUSPECT(S): Name of Suspect
Name of Suspect
VIOLATIONS: Examples - Clean Water Act, Section 13387(a)(1-7), Fish and Game Code Section 5650, Penal Code Section 374.7(a), (b), etc…
PNIR #: List all relevant PNIR’s
INVESTIGATIVE REPORT
SUBJECT #1: Name of Business
DBA:
Business Address: Street Address
City, State Zip
Business Telephone #:
Contractor License #: List State Contractor License if applicable
Business License #: List State Business License if applicable (Other important identifying information)
Owner of Record: Owner of business
SUSPECT #1: Suspect’s full name Physical Description
Suspect’s Address Height: X’ XX”
Phone Number Weight: XXX lbs.
Eyes: color Hair: color
Licenses
Driver’s License #: AXXXXX State: XX
Type: Commercial, Class A, B, C, etc.
DOB: XX/XX/XXXX
Contractor License: Trade licenses State: XX
SUSPECT #2: Suspect’s full name Physical Description
Suspect’s Address Height: X’ XX”
Phone Number Weight: XXX lbs.
Eyes: color Hair: color
Licenses
Driver’s License #: AXXXXX State: XX
Type: Commercial, Class A, B, C, etc.
DOB: XX/XX/XXXX
Contractor License: Trade licenses State: XX
SUBJECT:
PNIR #:
SYNOPSIS
The Synopsis section should include a summary of the illegal activity and the specific codes violated. Key information would be the laws and regulations that were violated as well as a description of how they were violated. Indicate how we verified that the laws were violated (i.e.: surveillance, monitoring, etc).
In committing these acts, the aforementioned named subjects and suspects violated the following laws and regulations: (list sections and a brief description of violation) Federal Clean Water Act
Section: 13387(a)(1-7), 13350(a), 13350(b), etc.
Violation: Describe violation
Department of Fish and Game Code
Section: 5650, 5650.1, 5652, etc.
Violation: Describe violation
California State Penal Code
Section: 374.7(a),(b), 374.8, etc.
Violation: Describe violation
County of Orange Water Quality Ordinance
Section: 4-13-40, 4-13-50, 4-13-52, 4-13-73, 4-13-80, etc.
Violation: Describe violation
SUBJECT:
PNIR #:
BACKGROUND:
The Background section should include a detailed summary of the process(es) that are utilized by the suspect and what occurred to cause the violations.
HISTORY
This section of the background is a chronological explanation of past incidents. Make reference to old PNIR’s and include them in the Exhibits List. Any other key pieces of information you have regarding the history of the individuals or business should be made reference to and their supporting documents included with the other exhibits. Information from the Hazardous Material Incident Report would also be useful in this section.
NARRATIVE:
The Narrative is a personal witness account by the investigator. Key pieces of information include the investigator’s name, position, employment location, investigation experience, how the investigation was conducted (including specific time, date and references to Exhibit information), and a conclusion. Try to look at how the violations have impacted the bigger picture.
Format:
- Key Info
- Narrative – if possible, use narrative from HMI
ENVIRONMENTAL IMPACTS:
A one-page description of what occurs when this type of material is introduced in the environment and the human health issues surrounding the material should be included. Talk about what the sample results mean. A good place to begin your research would be the EPA Standards for handling the material. All sources of information should be referenced.
Based on the evidence presented, there are clear violations of the regulations and laws of the State of California.
List which violations occurred.
SUBJECT:
PNIR #:
Witness List
1. Last Name: First Name: Middle:
Home Address: City: State/Zip:
Home Phone: Business Phone: Cellular/Pager:
Brief Summary of Witness Statement:
2. Last Name: First Name: Middle:
Home Address: City: State/Zip:
Home Phone: Business Phone: Cellular/Pager:
Brief Summary of Witness Statement:
3. Last Name: First Name: Middle:
Home Address: City: State/Zip:
Home Phone: Business Phone: Cellular/Pager:
Brief Summary of Witness Statement:
SUBJECT:
PNIR #:
RECOMMENDATIONS
We recommend that this case be filed through the Orange County District Attorney’s office for [criminal or civil] prosecution. A copy of this case should also be forwarded to the Attorney General’s Office for disciplinary action against all licensees involved.
Submitted By: Signature:
Authorized Inspector
Report Reviewed By:
Signature:
Authorized Inspector
Signature:
Program Manager
SUBJECT:
PNIR #:
EXHIBITS
These are the specific exhibits separated into sections and labeled with their exhibit number and name. Any piece of evidence that has relevance to the case should be included within the proper exhibit. All photographic evidence should be one exhibit, all sample information should be one exhibit, etc. The following list is just an idea of likely exhibits. Not all cases may contain these exhibits.
Exhibit 1 Case Chronology (list all events in chronological order)
Exhibit 2 Hazardous Material Incident Report
Exhibit 3 Photographs (give description of what each photo is showing, include a map or diagram) Exhibit 4 Samples (include everything from chain of custody to lab results) Exhibit 5 Maps/Diagrams (use detailed maps and diagrams, utilize graph paper if necessary) Exhibit 6 Witness Interviews (this is where any statements taken from witnesses will be) Exhibit 7 Past PNIR’s (any past PNIR’s related to the subject will go here) Exhibit 8 Past Letters (letters and communication sent to the subject in the past) Exhibit 9 Material Safety Data Sheets (if possible include MSDS’ for the materials involved) Exhibit 10 Property Value (provide the current value of the property if applicable) Exhibit 11 Newspaper Articles (include any articles past or present related to the case)
Local Implementation Plan
Section A-11
Water Quality Monitering
Component
SECTION A-11, WATER QUALITY MONITORING
City of Yorba Linda July 1, 2003
Local Implementation Plan (LIP) A-11-1
A-11.0 WATER QUALITY MONITORING
In response to EPA Clean Water Act regulations, in 1990 the County of Orange, the Orange County Flood Control District, and incorporated cities (Permittees) obtained NPDES Stormwater Permits (First Term Permits) from the Santa Ana and San Diego Regional Water Quality Control Boards. First term permits were superseded by new permits issued in 1996 (Second Term Permits) and 2002 (Fourth Term Permits).
The Permittees developed a Drainage Area Management Plan (DAMP) to assist in implementing stormwater pollution control measures. Through this DAMP, the Permittees intend to continue to improve existing stormwater quality management practices and, where necessary, to address identified problems and to implement new practices.
The DAMP details monitoring efforts to be implemented throughout the San Diego and Santa Ana regions of Orange County over the course of the Fourth Term Permits (DAMP Section
11.0). As discussed in the Santa Ana Regional Water Quality Control Board Municipal NPDES Stormwater permit, Order No. R8-2009-0030, NPDES No. CAS618030 (Amended 2010, Fourth Term Permit), the relevant Fourth term monitoring program for the City of Yorba Linda includes participation in a monitoring program with the following components:
• Mass Emissions Monitoring – Measure loads in order to estimate the total mass emissions, assess trends over time, and determine if emissions are contributing to exceedances of water quality objectives
• Estuary / Wetlands Monitoring – Monitor the Upper Newport estuary, Talbert Marsh, and Bolsa Chica wetlands areas to determine the effects of runoff associated with increased urbanization on these areas.
• Water Column Toxicity Monitoring – Analyze mass emissions samples for aquatic toxicity to determine the impacts of runoff on toxicity of receiving waters • Bacteriological / Pathogen Monitoring – Obtain and analyze monitoring data on bacteria in sampled waters to determine the impacts of runoff upon existing beneficial uses within receiving waters.
• Bioassessment – Cooperate with the Southern California Coastal Water Research Project (SCCWRP) in efforts to evaluate the biological index approach for Southern California and to design a research project for developing an Index of Biological Integrity (IBI) for the region
• Reconnaissance - Develop new reconnaissance strategies to identify and prohibit illicit discharges
• Land Use Correlations - develop and implement strategies for determining the effects of land use on the quality of receiving waters
• TMDL/303(d) Listed Waterbody Monitoring - Continue to participate in the Regional Monitoring Program for the San Diego Creek Nutrient TMDL, and evaluate the impacts of runoff on all impairments within the Newport Bay watershed and other 303(d) listed waterbodies
Wet and dry season monitoring programs are currently under development and are anticipated by mid-2003.
Exhibit A-11.I
Santa Ana Region
Water Quality Monitoring Program
1.0 Introduction............................................................................................................................. 1
1.1 Introduction......................................................................................................................... 1
1.2 Report Overview ................................................................................................................ 1
1.3 Permit and Monitoring Background................................................................................ 1
1.3.1 Permit history............................................................................................................... 1
1.3.2 Past monitoring programs and findings .................................................................. 2
2.0 Program Overview................................................................................................................. 3
2.1 Approach to Monitoring Design and Implementation ................................................. 3
2.2 Objectives and Program Overview.................................................................................. 4
3.0 receiving waters monitoring program elements................................................................ 6
3.1 Long-Term Mass Emissions Monitoring......................................................................... 6
3.1.1 Core monitoring...........................................................................................................7
3.1.2 Regional monitoring ................................................................................................. 11
3.1.3 Special studies............................................................................................................ 12
3.2 Estuary / Wetlands Monitoring..................................................................................... 14
3.2.1 Core monitoring......................................................................................................... 14
3.2.2 Regional monitoring ................................................................................................. 17
3.2.3 Special studies............................................................................................................ 18
3.3 Bacteriological / Pathogen Monitoring......................................................................... 18
3.3.1 Core monitoring......................................................................................................... 19
3.3.2 Regional monitoring ................................................................................................. 20
3.3.3 Special studies............................................................................................................ 20
3.4 Urban Stream Bioassessment Monitoring..................................................................... 22
3.4.1 Core monitoring......................................................................................................... 23
3.4.2 Regional monitoring ................................................................................................. 25
3.4.3 Special studies............................................................................................................ 25
3.5 Reconnaissance Monitoring ............................................................................................ 26
3.5.1 Core Monitoring ........................................................................................................ 26
3.5.2 Regional monitoring ................................................................................................. 29
3.5.3 Special studies............................................................................................................ 29
3.6 Land Use Correlations ..................................................................................................... 29
3.6.1 Core monitoring......................................................................................................... 29
3.6.2 Regional monitoring ................................................................................................. 30
3.6.3 Special studies............................................................................................................ 30
3.7 Nutrient TMDL Monitoring............................................................................................ 31
3.8 Relationship to the Bight ’03 Study................................................................................ 31
4.0 summary ................................................................................................................................ 31
4.1 Program Philosophy ........................................................................................................ 32
4.2 Program Structure ............................................................................................................ 32
4.3 Specific Program Elements.............................................................................................. 32 Appendix 1: San Diego Region Dry Weather Reconnaissance ............................................ 34 Appendix 2: San Diego Region Dry Weather Analysis Methods........................................ 49
1 1.0 INTRODUCTION
1.1 Introduction
The Permittees’ Receiving Waters Monitoring Program under Order No R8-2002-0010, NPDES Permit No. CAS618030, consists of seven main elements:
Long-term mass emissions monitoring
Estuary / wetlands monitoring
Bacteriological / pathogen monitoring
Urban stream bioassessment monitoring
Dry weather reconnaissance
Land use correlations
Nutrient TMDL monitoring.
Each of these addresses a different aspect of characterizing urban stormwater runoff and its impact on the environment. The dry weather reconnaissance, long-term mass loading, estuary / wetlands, and nutrient TMDL monitoring elements build on previous efforts in the First and Second Term Permit periods, while the urban stream bioassessment, bacteriological / pathogen, and land use correlations element are relatively new efforts. The following sections describe the Permittees’ overall approach to implementing these elements, relate them to the permit objectives, and describe their measurement and data analysis designs.
It is important to recognize that the Permittees’ overall Stormwater Management Program includes a wide range of elements that involve activities such as public education, inspections, and a variety of best management practices (BMPs). The Receiving Waters Monitoring Program described in this section will provide important feedback on the ultimate effects of such actions on receiving water quality. Combined with special studies and focused BMP evaluations, the Receiving Waters Monitoring Program will enhance the Program’s ability to continually adapt its management approach as knowledge improves.
1.2 Report Overview
This report describes the Orange County Stormwater Program’s overall approach to the design and implementation of receiving water monitoring (Section 2.1) and then explicitly states the Program’s objectives (Section 2.2). Section 3 and its subsections detail each of the monitoring program’s components in turn. For each component, the report states the underlying objective and then describes its core monitoring, regional monitoring, and special studies elements.
1.3 Permit and Monitoring Background
1.3.1 Permit history
In response to the First Term Permits (1990-1995), the Permittees developed and implemented a water quality monitoring program to aid in the detection and control of
2 illicit connections and illegal discharges to the municipal storm drain systems and to meet other program performance objectives. The monitoring program estimated pollutant loads in urban stormwater runoff, tracked compliance with water quality objectives, searched for sources of pollutants, and addressed impacts on areas of special concern.
In response to the Second Term Permits (1996-2002), the Permittees conducted a twoyear re-evaluation and revision of the water quality monitoring program. The purpose of this review was to (1) re-focus the efforts to determine the role, if any, of urban stormwater discharges to the impairment of beneficial uses and (2) to provide technical information to support an effective urban stormwater management program to reduce the beneficial use impairments associated with urban stormwater.
The Pemittees also initiated several water quality planning efforts, conducted additional water quality evaluations in response to technical requests from the Regional Boards, and participated in various regional research and monitoring programs. The combination of these efforts will aid the Permittees in determining the extent and degree of the relationship between urban stormwater runoff and impairment of beneficial uses within the aquatic resources of Orange County.
With the Third Term Permits (2002-2006), this evolution has continued with the thirdterm permit monitoring program described below. It expands further on previous efforts to identify pollutant sources, measure impacts, and gauge effectiveness of stormwater control efforts.
1.3.2 Past monitoring programs and findings
Past monitoring programs have helped to characterize spatial and temporal patterns of contamination in creeks, channels, and coastal bays and estuaries, as well as laying the groundwork for long-term tracking of trends. In addition, monitoring data have helped to increase understanding of the dynamics and patterns of stormwater pollution, thereby contributing to improved monitoring and management strategies. Specific representative findings include the following:
The first flush of a storm typically has higher concentrations of trace metals and greater organic-based turbidity than any other part of a storm. The first flush of the first storm of the season typically has the highest levels of the year. The concentration of total and dissolved metals is greater in storm runoff than in dry weather runoff.
Water hardness appears to be the dominant factor in the assessment of compliance with CTR standards for dissolved metals. Stormwater in a concrete-lined channel is more likely to have a lower hardness than in an earthen channel. Stormwater in a concrete-lined channel will therefore exceed CTR standards for dissolved metals more often than stormwater in an earthern channel, assuming similar land uses in the respective watersheds.
The Program is currently meeting the nutrient TMDL targets for San Diego Creek.
3 The nutrient load to Upper Newport Bay is seasonal, with the largest dry-weather load occurring during April and May.
The spring peak in nutrient load is correlated with peak algae blooms in Peters Canyon Wash and San Diego Creek.
Groundwater seepage into the stormdrain system appears to be a significant source of nitrate in the San Diego Creek watershed.
Benthic sediments collected from the harbors and bays typically have higher concentrations of trace metals than sediments collected from channels. Harbor and bay sediments also tend to have greater concentrations of silts and clays. Reconnaissance monitoring of the Construction Circle Drain in Irvine showed that many businesses in that drainage area were violating the County’s water pollution ordinance.
2.0 PROGRAM OVERVIEW
2.1 Approach to Monitoring Design and Implementation
The Permittees’ approach to the development of the Receiving Waters Monitoring Program is based on several widely recognized and fundamental principles of monitoring design. Monitoring should be:
Focused on specific, answerable questions that are relevant to management concerns Based on the most current scientific and technological understanding Cost effective and statistically efficient
Designed with adaptive feedback mechanisms that allow for appropriate adjustments to the program.
Continually assessing the seven main monitoring program elements against these principles ensures that the program, and the information it produces, remain relevant and effective. In order to help accomplish this, the Permittees have considered each program element in terms of three kinds of monitoring activities, each with different implications for implementation and for the analysis and evaluation of resulting data:
Core monitoring – routine, ongoing measurements, analyzed with well-defined methods, that address clearly defined questions related to small-scale or site-specific problems and processes
Regional monitoring – periodic, collaborative, and larger-scale surveys, e.g., the Bight Study carried out through SCCWRP, that use standardized sampling methods to collect a wide range of data across the entire region in both impacted and reference areas. Regional data can be analyzed with a variety of descriptive, hypothesis testing, and pattern analysis methods, as well as with indices designed to place sites on regional pollution or disturbance gradients. Special studies – tightly focused and relatively short-term studies, e.g., those carried out through the Stormwater Monitoring Coalition (SMC), often using exploratory data analysis methods, to investigate new measurement methods, improve basic
4 understanding, characterize problems, or provide one-time measurements of important parameters or processes.
These basic principles, along with the three-part framework, have been accepted by the Stormwater Monitoring Coalition (SMC) as a template for the design of a regional model stormwater monitoring program. They will help ensure that the various aspects of each program element utilize appropriate methods for sampling, data analysis, standardization, and flexibility. It will do by helping to adapt the design of specific monitoring studies (e.g., whether a long-term trend monitoring or a shorter-term experimental approach is used, the selection of parameters, the number and location of sites) to the particular questions being asked and/or problems being addressed. Table 2-1 illustrates how these three monitoring categories were used in organizing more detailed designs for each program element.
Figure 2-1 provides an overall depiction of the role of monitoring information in the Program’s decision making. A key aspect of this framework is the set of feedbacks that use information developed during the design and implementation of the monitoring program to refine not only technical study strategies but also more fundamental management expectations and goals.
These feedbacks occur in large part through the Program’s existing reporting process and management structure, including the Public Education component. These provide ample opportunities to disseminate information about patterns of pollution and discuss their implications for the Program’s objectives.
2.2 Objectives and Program Overview
The objectives of the Receiving Waters Monitoring Program, as stated in the Third Term Permit, are to:
1. Develop and support an effective municipal urban runoff and non-point source control program
2. Define water quality status, trends, and pollutants of concern associated with urban storm water and non-storm water discharges and their impact on the beneficial uses of the receiving waters
3. Characterize pollutants associated with urban storm water and non-storm water discharges and to assess the influence of urban land uses on water quality and the beneficial uses of receiving waters
4. Identify significant water quality problems related to urban storm water and nonstorm water discharges
5. Identify other sources of pollutants in storm water and non-storm water runoff to the maximum extent possible (e.g., atmospheric deposition, contaminated sediments, other non-point sources, etc.)
6. Identify and prohibit illicit discharges
5 7. Identify those waters, which without additional action to control pollution from urban storm water discharges, cannot reasonably be expected to attain or maintain applicable water quality standards required to sustain the beneficial uses in the Basin Plan (TMDL monitoring)
8. Evaluate the effectiveness of existing municipal storm water quality management programs, including an estimate of pollutant reductions achieved by the structural and nonstructural BMPs implemented by the permittees
9. Evaluate costs and benefits of proposed municipal storm water quality control programs to the stakeholders, including the public.
The monitoring program described in the following section (see Table 2-2 for summary overview) meets these objectives (with the proviso that evaluating the overall effectiveness and cost-benefit relationships of municipal stormwater programs, including specific BMPs, requires further effort beyond the scope of the water quality monitoring program outlined in the Permit and detailed in the following section). Table 2-3 illustrates the direct relationship between the specific permit objectives and the seven monitoring program elements.
The Receiving Waters Monitoring Program continues and expands the previous monitoring program’s emphasis on assessing impacts on aquatic resources, documenting long-term trends in water quality, targeting problematic discharge sites for more focused investigations, and adding additional monitoring elements. Table 2-3 briefly summarizes the specific objectives of the four program elements in terms of management goals, monitoring strategies, and other aspects of monitoring program design currently being used as a design framework in the SMC’s Model Stormwater Monitoring project. Table 2-4 results in the following more detailed objectives for each program element:
Long-term mass emissions
monitoring:
Using measurements of key pollutants, loads, as well as exceedances of relevant standards, shall decline over a time frame of years to decades, as compared with past
and present levels.
Estuary / wetlands
monitoring:
Using measurements of key pollutants, loads, and
biological community parameters, describe impacts on
estuarine and wetlands ecosystems and the relationship
of any impacts to runoff, based on theoretical and
empirical expectations about the structure and function of healthy communities.
Bacteriological / pathogen
monitoring:
Using measurements of a suite of bacterial indicators,
identify spatial and temporal patterns of elevated level in order to prioritize problem areas.
Urban stream
bioassessment monitoring:
Using a “triad” of indicators (bioassessment, chemistry, toxicity), describe impacts on stream communities and
the relationship of any impacts to runoff, based on
6 comparisons with reference locations and a regional IBI on a year-to-year timeframe.
Dry weather
reconnaissance:
Using measurements of key pollutants, identify potential illegal discharges and illicit connections, based on
comparison with historical data and available estimates of background levels.
Land use correlations: Using an experimental, “before-after,” design, identify changes in runoff associated with the urbanization of
previously agricultural land.
Nutrient TMDL monitoring: Using measurements of nutrients, track progress of nutrient control measures over time, based on
comparison with TMDL targets.
The monitoring program will reflect the Program’s continued evolution toward watershed management and toward addressing a more complex set of questions that integrate multiple Program elements. For example, the inclusion of an adaptive toxicity testing component in the mass emissions program element provides the ability to more fully characterize toxicity and then track its upstream source(s) on a watershed scale. As another example, the reconnaissance program (focused on identifying illegal discharges and illicit connections) will make use of the growing databases of commercial and industrial facilities resulting from the cities’ ongoing inventories of such facilities.
Further, the inclusion of bioassessment and estuary/wetlands components enables the Program to investigate the relationship of important biological endpoints to chemical contamination and physical changes in habitat. Overall, the monitoring program described in the following sections has expanded its focus on identifying the sources of problems, while continuing important historical data collection on trends at key sites.
Finally, the receiving water quality monitoring program responds explicitly to Section
3.3.1, Item 2, of the DAMP, which states that water quality problems will be identified through a countywide monitoring program and other assessments.
3.0 RECEIVING WATERS MONITORING PROGRAM ELEMENTS
Table 2-2 summarizes the monitoring program elements that have been designed to address the objectives described above. Each element is then described in fuller detail in the following sections.
3.1 Long-Term Mass Emissions Monitoring
The goal of the long-term mass emissions component of the program is to:
Estimate the total mass emissions from the MS4
Assess trends in mass emissions over time
7 Determine if the MS4 is contributing to exceedances of water quality objectives or beneficial uses, by comparing results to the California Toxics Rule (CTR), Basin Plan, and/or other relevant standards.
These objectives will be addressed with a trend monitoring design that focuses on sites at or near the bottoms of key watersheds, and includes sampling in both wet and dry weather for toxicity as well as for a broad range of pollutants. The trend monitoring is supplemented by toxicity testing, and by special studies for TIEs (Toxicity Identification Evaluations) and upstream source identification, where called for.
In addition to meeting the basic permit objectives, these data will also be useful in helping to assess the effectiveness, in a general sense, of urban runoff management programs. More specifically, they will be helpful in measuring the performance of existing site-specific TMDLs (e.g, Newport Bay) and in generating the requirements for new TMDLs (e.g., Huntington Harbour). While the design described below makes every effort to achieve efficiencies by coordinating the TMDL and NPDES monitoring activities, there are differences in the underlying information needs for these two programs that sometimes limit the degree of coordination that can be achieved. Linkages between the NPDES and TMDL programs include:
Mass emissions stations in the Newport Bay watershed will act as “trigger” sites in an adaptive monitoring approach that may initiate further sampling at upstream Toxics TMDL stations
Mass emissions stations in the Newport Bay watershed are part of the sampling networks for the Toxics and Nutrient TMDLs, and data for multiple programs can often be gathered during the same sampling event
The needs of the Toxics TMDL require that the fathead minnow (Pimephales promelas) be added to the suite of freshwater toxicity test organisms as a screening test during the first year of the permit.
However, sampling frequencies differ across the NPDES and TMDL programs, which limits the degree to which sampling efficiencies can be achieved.
The inclusion of toxicity testing in this element will not only help identify where biological impacts may be occurring, but will also improve the ability to assess potential impacts on coastal receiving waters (in coordination with the Bight ’03 study). Where called for, toxicity tests at higher dilutions and TIEs, carried out as special studies, will provide additional information for further upstream source identification and / or source control efforts. With the agreement of the Board, this adaptive toxicity testing component will be substituted for the permit requirement for priority pollutant scans.
Figure 3-1 shows the flow of information, and the relationships, among the NPDES mass emissions and TMDL monitoring programs.
3.1.1 Core monitoring
8 The core monitoring aspects of this program element include chemical and toxicity monitoring, for both aqueous and sediment samples, collected in both wet and dry seasons. This element is based on a trends monitoring design. However, mass emissions data may also be used in combination with data from other program elements to improve understanding of patterns in urban runoff and their potential relationship to other aspects of the environment.
Mass emissions monitoring is targeted at important inputs to Huntington Harbor and Newport Bay, as well as at key coastal sites, and areas of north Orange County where surface flows have not yet been well characterized (Figure 3-2).
3.1.1.1 Monitored parameters
The parameters to be sampled will depend on the season (3 storm events, 3 dry weather samples per year) and on whether the sample is an aqueous or a sediment sample, as illustrated below:
Parameter Wet Season
Storms
Dry Season
Aqueous
Dry Season
Sediment
Nutrients
o nitrate plus nitrite X X
o total ammonia X X
o total Kjeldahl nitrogen (TKN) X X
o total phosphate X X
o orthophosphate X X
Dissolved organic carbon (DOC) X
Total organic carbon (TOC) X
Total suspended solids (TSS) X X
Volatile suspended solids X X
Turbidity X X
pH X X
Oil and grease X
Temperature X X
Dissolved oxygen X X
Electrical conductivity X X
Hardness X X
Particle size X
Total and dissolved heavy metals
o cadmium X X X
o chromium X X X
o copper X X X
o lead X X X
o silver X X X
o mercury1 X X X
o selenium1 X X X
o zinc X X X
Organophosphate pesticides
9 o diazinon X X
o chlorpyrifos X X
o malathion X X
o dimethoate X X
Bacterial indicators
o total coliform X X
o fecal coliform X X
o Enterococcus X X
Toxicity X2 X3
Herbicides4 (e.g. Roundup) X
Others5
1To be sampled only at the five stations that are also part of the Toxics TMDL program 2 During two storms per year with Ceriodaphnia, sea urchin fertilization, mysid survival and growth; fathead minnow to be used in addition during the first year at the five stations that are also part of the Toxics TMDL in the Newport Bay watershed 3 Two times during dry weather with freshwater test organisms; fathead minnow to used in addition to Ceriodaphnia, Selenastrum, and Hyallela azteca during the first year at the five stations that are also part of the Toxics TMDL in the Newport Bay watershed 4 To be determined
5 Constituents, determined on a case by case basis, known to have contributed to the impairment of local receiving waters
3.1..2 Monitoring sites and analyses
Monitoring will be conducted at the mass loading sites shown on Figure 3-2. Samples will be collected for three storm events per season, with three to four samples collected per storm event, and three times during the dry season. The sites target:
Coyote Creek (in north Orange County)
Fullerton Creek (in north Orange County)
Carbon Creek (in north Orange County)
Santa Ana Delhi Channel (Newport Bay watershed) *
Peters Canyon Wash (Newport Bay watershed) *
San Diego Creek at Campus (Newport Bay watershed) *
Central Irvine Channel (Newport Bay watershed)
San Diego Creek at Harvard (Newport Bay watershed) *
Costa Mesa Channel (Newport Bay watershed) *
Bolsa Chica Channel (Huntington Harbour) *
East Garden Grove-Wintersburg Channel (Bolsa Bay) *.
Sites in the above list followed by an asterisk (*) are ones for which the Program has historical data that will be useful in providing a context for tracking trends into the future.
Sampling on the three northern County creeks will be phased in over a three-year period, to reflect the somewhat lower priority given this area in Section 3 of the DAMP.
The sampling schedule will be:
10 Year 1: Time-weighted composite samples from three storm events per year and 24- hr composite samples from three dry-weather periods per year Year 2: Continue automatic sampling of three storms and three dry-weather periods; install streeam gauges and define the rating curves for each site Year 3: install automatic samplers and move to routing mass emissions monitoring on alternate years
Year 5: continue monitoring in alternate years.
Analytical methods will remain as in the current 99-04 plan. Sampling equipment and methods will be modified to enable determinations of aqueous concentrations of organic compounds (diazinon, chlorpyrifos, malathion, dimethoate, DOC) and aquatic toxicity.
Calculation of both loads and event mean concentrations will be performed as in the previous program.
Loads and event mean concentrations will be analyzed for historical patterns and trends, both at individual sites and across the north County region as a whole. These analyses will use statistical techniques such as plotting and regression analysis (for identifying trends), and cluster analysis (for identifying patterns among sites). In addition, composite samples, grab samples, and event mean concentrations will be compared to relevant standards, including:
California Toxics Rule (CTR) levels
Basin Plan objectives.
3.1.1.3 Toxicity tests
With the concurrence of staff at the Santa Ana Regional Water Quality Control Board, we have modified the toxicity testing approach in the permit. The approach in the permit specifies that toxicity testing be performed using one freshwater (Ceriodaphnia) and one marine (sea urchin fertilization) test organism to evaluate both stormwater and non-stormwater discharges from the channels. We are modifying this requirement as follows:
Stormwater
Ceriodaphnia
Sea urchin fertilization
Mysid survival and growth
Fathead minnow (Newport Bay watershed only)
Non-stormwater (i.e., dry weather)
Ceriodaphnia
Selanastrum
Hyalella azteca
Fathead minnow (Newport Bay watershed only).
This combination of test organisms was selected to provide adequate coverage of the major classes of pollutants known as sources of toxicity (e.g., metals, organophosphate
11 pesticides). This will provide more insight into the probable sources of toxicity, because it is well known that test organisms differ in their relative sensitivity to different pollutants. Two marine test organisms were included for stormwater testing because the major potential impact of these flows is on the estuarine and nearshore marine environment. In addition, using some of the same test organisms for both stormwater and receiving water (i.e., bays and estuaries) testing will allow for drawing tighter conclusions about the relative contribution of different inputs to the observed toxicity in the receiving waters.
Stations in the Newport Bay watershed, that are also part of the Toxics TMDL, will include the fathead minnow in the freshwater tests. Since the fathead minnow is more sensitive to pyrethroid pesticides than are Ceriodaphnia and Hyallela azteca, this will address concerns about this pesticide in the Toxics TMDL. Fathead minnow will be used as a screening test during the first year of the permit. It will continue to be used only if it shows a toxic r esponse.
These test organisms correspond as closely as possible to those being used in the San Diego region on the County. Commonality of approach provides important benefits, including:
Enhancing the comparability of results among programs and between Regions A broader assessment of potential impacts on saline receiving waters, i.e., Bolsa Bay, Talbert Marsh, Huntington Harbour.
Decreasing the likelihood that sampling error will result in the wrong test being performed
Improving efficiency and reducing costs
Providing additional information on dry-weather freshwater toxicity in the Santa Ana Region with the addition of Selanastrum.
Providing feedback, as the result of the addition of Selanastrum (which is sensitive to nutrients), that can be used in the Nutrient TMDL program for San Diego Creek and Upper Newport Bay.
All wet weather toxicity tests will be performed at 100%, 50%, 25%, 12.5%, and 6.25% dilutions, and dry weather tests at 100% and 50% dilutions, based on past findings of much higher toxicity in wet weather. (All fathead minnow tests will be performed at 100% concentration only.) A finding of substantial toxicity at the 100% and 50% dilutions will trigger a set of adaptive special studies involving additional tests at higher dilutions and TIEs (see Figure 3-3 and Sections 3.1.3.1 and 3.1.3.2.
3.1.2 Regional monitoring
As described above, the mass emissions stations in the Newport Bay watershed are also an integral part of regional monitoring programs for the Nutrient and Toxics TMDLs. In addition, mass emissions stations on channels that drain into Huntington Harbour and Bolsa Chica Bay will provide information useful in developing future TMDLs in that area.
12 In addition, the Bight ’03 study will have an estuarine component that will measure chemical contamination in benthic sediments and in the water column, as well as in the tissue of benthic and pelagic fish. This component will also estimate pollutant loads to estuaries from surrounding watersheds. The mass emissions stations may provide useful information about pollutant loads, depending on which estuaries Bight ’03 samples (the Bight ’03 planning process is not yet complete).
3.1.3 Special studies
In addition to the core monitoring, there are four additional special studies aspects of this program element (see Tables 2-1 and 2-2):
Toxicity tests at higher dilutions
Toxicity identification evaluations (TIE)
Upstream source identification studies
Design of a model stormwater monitoring program.
Figure 3-3 shows the interrelationship of the first three of these special study components.
3.1.3.1 Toxicity tests at higher dilutions
If the core monitoring toxicity tests show substantial toxicity (defined as a 100% effect) at the 100% and 50% dilutions within the first hour, this will trigger additional toxicity tests at higher dilutions (up to seven dilutions for wet weather and five dilutions for dry weather) (see Figure 3-3). The purpose of these additional tests is to better characterize the degree of toxicity. This information, in turn, will be useful in designing any subsequent TIEs and/or upstream source ID studies.
3.1.3.2 Toxicity Identification Evaluation (TIE)
Where toxicity tests show persistent toxicity, the program will prioritize available resources to carry out toxicity identification evaluations (TIEs) to identify sources of toxicity and thereby provide information needed for more focused source identification and control. Because there are no widely accepted standards within stormwater monitoring for using toxicity test results to prompt toxicity identification evaluations (TIEs), we will use the following rules of thumb, developed in the ongoing SMC project to develop a model stormwater monitoring program for southern California. We interpret persistent to mean the occurrence of substantial toxicity in at least half the monitoring events conducted through a particular season. We will then rank instances of persistent toxicity in terms of their degree of toxic effect (as compared to controls) and allocate available TIE resources to these sites in rank order. The SMC model monitoring project is developing a quantitative metric that includes the persistence and magnitude of toxicity, as well as the percentage of the suite of organisms that shows a toxic response to any one sample. This metric will be adopted for use in the program as soon as it is developed and accepted by the SMC project. The relative ranking of sites on this metric will then be used to identify a set of monitoring sites for potential TIE studies in
13 the following year (as described in the following paragraph). Prioritizing sites for TIEs based on a year’s worth of data reflects the fact that toxicity in stormwater runoff is often sporadic and serve to focus TIEs on those instances where the likelihood of identifying the source(s) of toxicity is the highest.
In general, where there is persistent and substantial evidence of toxicity in Year A, TIE’s should be conducted in Year B (the following year). (However, the list of sites may be prioritized to fit within budget and logistical constraints.) In such cases, the Program will prepare to conduct both toxicity tests and toxicity identification evaluations (TIEs) in parallel in Year B. Toxicity tests will be started and, if their results confirm the Year A conclusions (i.e., 50% or greater effect at the highest concentration), toxicity identification evaluations (TIEs) will be run immediately, using water collected from the same storm. (Based on past monitoring results, the first storms in the wet season will be the most toxic.) Where the Year B toxicity tests do not confirm the Year A results, the water collected for the toxicity identification evaluations (TIEs) will simply be discarded.
This approach runs the risk of incurring extra costs in those cases where the toxicity identification evaluations (TIEs) are not run. However, it may be possible to balance such extra costs by focusing the toxicity tests on the specific organisms that demonstrated toxicity in Year A. Depending on the results of the toxicity identification evaluations (TIEs), a variety of management actions, from further source identification to specific best management practices (BMPs) and source control actions, could be implemented. Again, because there are no commonly accepted standards for using toxicity identification evaluation (TIE) results to trigger management actions, the Program will work with SCCWRP and the Stormwater Monitoring Coalition’s model monitoring program project during Year 1 of the Program to further the development of such standards.
3.1.3.3 Upstream source identification studies
Upstream source identification studies will be an integral part of this and other Program components.
The design of any upstream source identification studies will depend on the nature of the clues provided by the higher dilution toxicity tests and the TIEs. If the results of these are specific enough to “fingerprinting” a particular kind of activity/source, then upstream clusters of these could be identified either through map-based Yellow Page searches or with the results of municipal inventories of commercial and industrial facilities. This information could be combined with historical reports of spills or other violations to narrow the search to a smaller number of likely sources.
An alternative approach is to work upstream from the monitoring site at which the toxicity was originally found, testing both for toxicity and the presence of the identified toxic compounds at major branch points and/or inputs. While this approach is straightforward in its design, it may be difficult to implement because of the often sporadic nature of stormwater flows. Thus, identifying the source(s) of toxicity will most likely require a combination of both approaches and the source identification studies may of necessity extend over more than one monitoring year.
14 3.1.3.4 Model stormwater monitoring design
The Orange County Stormwater Program is participating in the Stormwater Monitoring Coalition project to develop a model stormwater monitoring design for the southern California region. The model design is being developed by a technical committee with representatives of the three Regional Boards (Los Angeles, Santa Ana, and San Diego) and the major municipal stormwater programs in southern California. It will involve developing regionally consistent higher-level management questions, detailed objectives, and monitoring approaches. While not intended to be overly rigid, the model program is meant to provide a common framework or starting point for fleshing out the details of individual monitoring programs. Thus, the model monitoring project will result in specific guidance for the design of the mass emissions program element (and for a range of other program elements), as well as the criteria for prompting TIEs discussed in the preceding paragraph.
3.2 Estuary / Wetlands Monitoring
The goal of the estuary / wetlands component of the program is to determine the effects of stormwater and non-stormwater runoff associated with the increased urbanization in the watersheds of these systems. This objective will be addressed with an assessment monitoring approach that identifies relationships between runoff inputs, levels of key pollutants, and measurements of the integrity of biological communities.
These data will be useful in assessing the effectiveness of urban runoff management programs. More specifically, they will improve understanding of the ecological health of, and stresses on, these important coastal zone ecosystems. This understanding will be helpful in developing, adjusting, and tracking the performance of site-specific TMDLs and other management strategies. Coordination of the design and implementation of this element with the Bight ’03 study will help place the northern Orange County monitoring results in a broader regional context by comparing conditions in the County to conditions elsewhere in southern California. Where called for, toxicity identification evaluations (TIEs) carried out as special studies will provide additional information for further source identification and / or source control efforts.
3.2.1 Core monitoring
The core monitoring aspects of this program element include chemical and toxicity monitoring, in both aqueous and sediment samples, from key estuaries / wetlands as well as the channels that input to them. This element is based on an assessment monitoring design that searches for relationships among important biological and chemical endpoints and a range of inputs and processes.
3.2.1.1 Monitored parameters
The parameters to be sampled in the input channels will be the same as those sampled in the mass emissions component of the Program (see section 3.1.1.1). The parameters to be
15 sampled in the estuaries / wetlands themselves will depend on the season, on whether the sample is an aqueous or a sediment sample, and on the location of the monitoring site, as illustrated below:
Parameter Wet Season
Storms
Dry Season
Aqueous
Dry Season
Sediment1
Nutrients
o nitrate plus nitrite X X
o total ammonia X X
o total Kjeldahl nitrogen (TKN) X X
o total phosphate X X
o orthophosphate X X
Dissolved organic carbon (DOC) X
Total organic carbon (TOC) X
Total suspended solids (TSS) X X
Volatile suspended solids X X
Turbidity X X
pH X X
Oil and grease X X
Temperature X X
Dissolved oxygen X X
Electrical conductivity X X
Hardness X X
Particle size X
Total and dissolved heavy metals
o cadmium X X X
o chromium X X X
o copper X X X
o lead X X X
o zinc X X X
Organophosphate pesticides
o Diazinon X X
o chlorpyrifos X X
o malathion
o dimethoate
Bacterial indicators
o total coliform X X
o fecal coliform X X
o Enterococcus X X
Toxicity X2 X3 X
Benthic infauna 4 X
1 In estuaries
2 Aqueous, during two storms per year with the standard marine test organisms sea urchin fertilization, sea urchin embryo development, mysid survival and growth, at 5 dilutions 3 Aqueous, once during dry weather with the standard marine test organisms, at 2 dilutions 4 Once per year
16 The Program will combine its own monitoring data (e.g., benthic infauna) with data being collected by other parties in order to assess a broader suite of biological indicators.
Table 3-1 summarizes the key ongoing monitoring efforts in the four water bodies to be monitored.
3.2.1.2 Monitoring sites and analyses
Monitoring will be conducted at the sites shown on Figure 3-4. These include a combination of channel and estuary / wetland sites, with both types of sites sampled during both wet and dry weather.
There will be six channel stations, including:
Talbert Channel
San Diego Creek at Campus Drive
Santa Ana Delhi Channel
Costa Mesa Channel
East Garden Grove-Wintersburg Channel
Bolsa Chica Channel.
Samples will be collected at the channel stations for three storm events per season, with three to four samples collected at two-day intervals per storm event, and three times during the dry season.
All the channel sites, with the exception of Talbert Channel, are also mass emissions sites. The availability of mass emissions data for these channels will assist in identifying potential relationships between patterns and trends in the estuaries/wetlands and the inputs of key pollutants.
There will be 12 estuary / wetland sites, including:
UNBJAM (Upper Newport Bay-Unit Basin 1) (Toxics & Nutrient TMDLs) UNBSDC (Upper Newport Bay-Unit Basin 2) (Toxics & Nutrient TMDLs) UNBCHB (Upper Newport Bay-PCH Bridge) (Toxics & Nutrient TMDLs) UNBNSB (Upper Newport Bay-North Star Beach) (Toxics & Nutrient TMDLs) LNBHIR (Lower Newport Bay-Harbor Island Reach) (Toxics & Nutrient TMDLs) LNBRIN (Lower Newport Bay-Rhine Channel) (Toxics TMDL) HUNBCC (Huntington Harbour-near Bolsa Chica Channel mouth) HUNWAR (Huntington Harbour-Warner Avenue Bridge)
HUNCRB (Huntington Harbour-Christiana Bay)
TGDC05 (Bolsa Bay-d/s E. Garden Grove Wintersburg Channel tidegates) BBOLR (Bolsa Bay-off observation pier)
Talbert Marsh.
Some sites are situated near the mouths of channels that represent major inputs of runoff, and there is a minimum of one site in each estuary that is free of direct runoff
17 influences from the channels (Figure 3-4). Comparisons between these two types of sites will help identify runoff impacts. The estuary / wetland sites in Huntington Harbour, Bolsa Bay, and Talbert Marsh will be sampled during two storm events per season, with three samples collected per storm event, and twice during the dry season, once prior to the beginning of the storm season (October) and once after the end (May). Sites in Upper Newport Bay have a somewhat different sampling regime because of nutrient TMDL Regional Monitoring Program (RMP) requirments. These four sites will be monitored monthly throughout the year, in addition to the two storms. However, toxicity tests in Upper Newport Bay will be conducted at only two of the four sites (UNBJAM and UNBSDC). See Section 3.1.2 for a description of chemical sampling and laboratory analytical methods.
The data analysis approaches used in the program element will reflect the basic conceptual model used to develop the monitoring design (Figure 3-5). This model is a generic source – transport – fate/effects model that assumes that pollutants enter the estuary / wetland from channels, move through the system with the flow of water and sediment, and potentially cause impacts on sensitive habitats and/or species. While we understand that certain pollutants can accumulate in the sediment, precise knowledge about residence times, chemical transformations, and biological uptake in this and other ecosystem compartments is not available. The data analysis approach will therefore be based primarily on two related approaches:
A search for evidence of impacts in endpoints such as chemical concentrations in sediment, benthic infaunal community parameters, and sediment toxicity A search for patterns of relationship between these endpoints and measures of the input of pollutants from channels.
Evidence of impacts can be derived from comparison of current data with historical data (where available), with similar sites in other areas of southern California, or with commonly accepted reference standards (e.g., for toxicity and benthic infauna). Patterns of relationship between endpoints and measures of pollutant input can be derived from correlation analyses and multivariate pattern analyses. Where long-term historical data are available (e.g., Upper Newport Bay, Bolsa Bay Ecological Reserve) trend analyses, along with information about land use changes, may provide additional insight.
3.2.1.4 Toxicity testing
See the discussion of toxicity in the mass emissions section (section 3.1.1.4).
3.2.2 Regional monitoring
The availability of a southern California Benthic Response Index (BRI) for enclosed bays and estuaries will make it possible to place benthic infauna monitoring results in a broader regional context. Combined with information on sediment chemistry and channel inputs, this will assist in drawing more reliable conclusions from the Orange County monitoring results.
18 In addition, the Bight ’03 study contains an estuaries component, targeted at locations on the mainland that are saline in the summer, have soft-sediment bottoms, contain subtidal habitat, and have minimal vessel traffic. Upper Newport Bay and Bolsa Bay meet these criteria, but the set of sampling locations has not yet been finalized. This component will measure chemical contamination in sediments and in the water column, as well as in the tissue of benthic and pelagic fish. In addition, this component will estimate pollutant loads to estuaries from surrounding watersheds. While there is overlap between the Bight ’03 and the Program’s parameter list (particularly for sediment and water column measurements), the two efforts will complement each other in useful ways. Bight ‘03’s measures of tissue contamination will provide an additional indicator for documenting the effects of pollutant inputs. Comparisons between patterns of benthic infauna (County’s Program) and tissue contamination in fish (Bight ’03) may provide insight into the fate and effects of pollutants and the processes that control them.
3.2.3 Special studies
Where toxicity tests show substantial toxicity, the program will carry out toxicity testing at higher dilutions, followed by toxicity identification evaluations (TIEs) to identify sources of toxicity (see discussion in the mass emissions section (Sections 3.1.3.1 and
3.1.3.2) for more detail). In addition, upstream source identification studies may be implemented where monitoring data indicate that impacts may be caused by inputs of one or more particular pollutants from a specific channel (see Section 3.1.3.3 for more detail). Finally, further special studies (yet to be defined) may be required to investigate specific patterns or relationships suggested by the monitoring data, for example, between sediment chemistry and observed changes in the benthic infauna community.
There is some concern that pollutants in stormwater may enter wetland upland areas through two mechanisms. First, pollutants with a specific gravity less than 1.0 float on the surface of the water and may collect along the land / water interface. Second, periodic flooding during storm events may bring stormwater-borne contaminants to upland areas. We will address this concern with a scoping study of upland sediment contamination. A transect of four stations, beginning just below the low tide line and traversing inland, will be sampled during dry weather on Shellmaker Island in Upper Newport Bay, and in Bolsa Bay. These sites will be chosen to minimize other sources of human impact and thus help isolate any contamination signal from stormwater. The suite of parameters to be measured will be determined in consultation with Regional Board staff. The results of this study may then provide a basis for additional special studies and/or monitoring.
3.3 Bacteriological / Pathogen Monitoring
The goal of the bacteriological / pathogen component of the program is to determine the impacts of stormwater and non-stormwater runoff on the loss of beneficial uses to receiving waters. This objective will be addressed with a design that:
19 Compares ambient indicator levels to relevant standards at sites along the coastline and on a number of inland channels during dry weather
Evaluates the impacts of coastal stormdrains on the surfzone.
The design of the coastal stormdrain portion of this program component is based on an adaptive approach. In this approach, the basic coastal stormdrain design described below will be carried out in Years 1 and 2 of the permit. Beginning in Year 3, additional drains will be evaluated with shorter-term studies. The design of these shorter-term studies will be based on results obtained in Years 1 and 2. In addition, persistently high levels of indicator bacteria in the drains themselves will trigger upstream source identification studies to be carried out by the relevant city. Over time, these monitoring data will help to establish correlations between indicator levels in the surfzone, indicator levels in the stormdrains themselves, and upstream sources, and to identify and resolve upstream sources of elevated levels.
3.3.1 Core monitoring
Core monitoring will include coastal stormdrains in representative areas along the Orange County coastline.
3.3.1.1 Monitored parameters
Monitoring will focus on total coliforms, fecal coliforms, and Enterococcus. The County Health Care Agency Public Health Laboratory will perform the necessary laboratory work, using the membrane filtration method and negotiations are currently underway between the Program and the Health Care Agency Environmental Health Division to establish a cooperative approach to performing the field sampling, especially for the coastal sites.
3.3.1.2 Monitoring sites and analyses
Designation of the set of coastal sites will require a more formal reconnaissance and siteselection process conducted in coordination with HCA and the County Sanitation Districts of Orange County (CSDOC), which both currently monitor a number of sites at bathing beaches. The reconnaissance will be necessary because the sites currently being monitored were not necessarily selected with reference to the locations of coastal storm drains and because not all coastal drains have been identified and mapped. Therefore, the available drains, identified through a reconnaissance effort, will be subset according to a hierarchy of criteria and different monitoring approaches applied to each (Figure 3- 7).
The rationale for each of the sorting criteria in Figure 3-7 is as follows:
Drains with equivalent diameters larger than 39 inches and/or whose dry-weather flow is greater than 100,000 gallons per day are more likely to be a source of significant contamination problems and this was the size threshold used in the
20 recent Aliso Creek Directive studies and the Coastal Stormdrain Outfall Monitoring for the Permit in San Diego Region.
Drains posted by the Health Care Agency are more likely to discharge to areas of public access where there may be a potential for human health risk Drains that outlet to the coast but whose flow does not reach the surfzone, even at high tide, are not likely to be affecting indicator levels in the surfzone and will not be monitored during the dry season (May-September); however, increased flows characteristic of the wet season have the potential for sometimes reaching the surfzone and warrant monitoring during this season
Drains that are larger than 39 inches or have dry-weather flows of greater than 100,000 gallons per day, are posted by the Health Care Agency, and whose flow reaches the surfzone are high priorities for monitoring and will be monitored weekly throughout the year, in the drain itself and in the surfzone 25 yards upcoast and downcoast of the drain/surfzone interface.
The set of drains meeting the criteria described above will be identified through a field reconnaissance to be carried out in cooperation with the County Health Care Agency (HCA) and the County Sanitation Districts of Orange County (CSDOC).
Analyses of these surfzone data for core monitoring purposes will focus primarily on calculating the weekly levels of indicator bacteria and direct comparison of monitored levels to the Ocean Water Contact Standard (AB411 standard -see Section 3.3.3.1 for more detail). Exceedances will be reported to the County Health Care Agency, which posts bacterial indicator monitoring data on the Agency’s website and emails a data spreadsheet to all local jurisdictions. The Health Care Agency also routinely reviews these data and notifies cities when problems occur. Analyses of the inland data for core monitoring purposes will focus primarily on direct comparison to the Basin Plan’s REC1 and REC- 2 standards.
3.3.2 Regional monitoring
The regional monitoring aspect of this program element involves participation in the Bight ’03 stormwater plume tracking and monitoring study, which will use a combination of remote sensing and in situ measurements to characterize wet season stormwater plumes from the Santa Ana, San Gabriel, and Los Angeles Rivers. In addition to offshore plume measurements, additional bacteriology samples will be collected in the surfzone and at the beach, inshore of the plumes, in order to determine if such plumes have an effect on indicator levels along the shoreline.
3.3.3 Special studies
In addition to the core monitoring, there are four additional special studies aspects of this program element (see Tables 2-1 and 2-2):
Inland channels and/ or creeks
Reprioritization and source identification
Correlations between stormdrain and surfzone indicator levels
21 Assessment and/or application of improved indicators.
3.3.3.1 Inland channels and/or creeks
The permit specifies that six inland channels and/or creeks that are currently impaired for pathogens shall be monitored. The following sites have been selected, based on consultation with the County Health Care Agency (HCA) (Figure 3-6):
Buck Gully
Los Trancos Creek
San Diego Creek at Campus Drive
Waterfall Creek
El Moro Creek
Santa Ana Delhi Channel.
The creeks were selected based on their contamination and their likelihood of containing flowing water. Monitoring at these locations will be coordinated with the monitoring currently being conducted by HCA, in order to increase the frequency of monitoring data and thus possibly provide a more accurate picture of contamination patterns at these locations. Data from this effort will be evaluated with statistical power analysis to determine whether the increased frequency does indeed improve the ability to resolve patterns and differences among drains. The design of this element of the program will then be reevaluated in consultation with the Board.
3.3.3.2 Reprioritization and source identification
Special studies aspects of this program element include analyses needed to prioritize the drains for further study, based on the first two years of monitoring data. These analyses will include both the patterns of indicator levels (e.g., loads, frequency of exceedance, average amount of exceedance), receiving water characteristics (e.g., well flushed open coast, poorly flushed, semi-enclosed), and measures of body contact recreational water use to develop a qualitative site-specific risk measure. Prioritization criteria will be developed in collaboration with SCCWRP and the Stormwater Monitoring Coalition and will be useful in providing a meaningful context for the raw data on levels, loads, and exceedances.
Prioritization criteria will then be used to identify the worst drains for additional IC/ID (Illegal Connections and Illicit Discharge) monitoring and for reconnaissance source identification studies to be carried out by the Permittees (see Section 3.1.3.3 for more detail on source identification methods). The results of such monitoring and source identification in turn could lead to further source identification efforts and/or management actions such as best management practice (BMP) implementation. In addition, the prioritization process could lead to reductions in monitoring effort on drains that are shown not to be a problem. The SMC model stormwater monitoring project is currently developing a quantitative trigger for initiating source identification work based on the results of monitoring of discharges to coastal and inland receiving waters. This trigger will be applied when it has been approved by the SMC model monitoring committee.
22 The Program will also identify a priority list of additional drains for assessment and monitoring activities in Years 3 – 5 of the permit period.
3.3.3.3 Correlations between stormdrain and surfzone indicator levels Another goal of the special studies analyses is to improve our understanding of the correlations between levels of indicator bacteria in the surfzone and levels in the stormdrains themselves. This will be accomplished through correlational analyses of data from the stormdrains and data collected in the surfzone. These analyses will also include data from the Bight ’03 water plume tracking study that may provide insight into the relationship between indicator levels in offshore stormwater plumes and in the surfzone and at the beach (see Section 3.3.2).
3.3.3.4 Improved indicators
In addition, the Program will participate, through the Stormwater Monitoring Coalition, in developing rapid bacteriological indicators that will provide managers with near-realtime measures of human health risk and microbiological source identification methods that will narrow the source(s) of contamination to specific human and non-human categories.
Although they are widely used, there are well-known shortcomings that limit the effectiveness of current bacteriological indicators, both for measuring human health risk and for identifying the sources of pathogen contamination. Two projects being managed by SCCWRP are currently underway that begin to address these shortcomings. The first, development of rapid bacteriological indicators, is focused on producing easily used field tests that would provide a reliable measure of bacteriological contamination within a few hours at most. The second, validation and comparison of alternative methods to identify the upstream sources of bacteriological contamination, will select those methods (primarily genetics-based) that provide the most dependable means of identifying and distinguishing among such sources. The Orange County Stormwater Program will participate in these and related projects as needed and appropriate. For example, the Bight ’03 study may include a bacterial source tracking component utilizing one or more genetic methods.
3.4 Urban Stream Bioassessment Monitoring
The goal of the urban stream bioassessment element of the program is to describe impacts on stream communities due to stormwater runoff and to track trends in such impacts over time. The combination of core monitoring aspects described below provides the urban bioassessment program element with the ability to use a “triad” approach to assessment that includes routinely collected biological and physical data, along with direct measures of toxicity. In addition, special studies aspects provide the ability to identify pollutant and disturbance sources more accurately, improving the knowledge base for implementing best management practices (BMPs).
23 This is illustrated in Figure 3-8 that shows how bioassessment, chemical monitoring, and toxicity testing combine to create an overall assessment of condition. In addition, each portion of the “triad” can lead, as appropriate, to targeted source identification studies that, in turn, can suggest specific best management practices (BMPs). The effectiveness of these best management practices (BMPs) can then be evaluated, in part, through future monitoring efforts conducted by each portion of the “triad.” However, establishing a causal linkage between best management practices (BMPs) and receiving water conditions also requires information from focused studies of the effectiveness of individual best management practices (BMPs), such as those currently being conducted by the County.
3.4.1 Core monitoring
Core monitoring aspects of this program element include bioassessment, chemical monitoring, and toxicity testing at all sites (see Table 2-2 for more detail). This will permit assessment of conditions based on a “triad” of complementary indicator groups that provide different kinds of insight into the action of runoff-related stressors. The inclusion of toxicity testing as an aspect of core monitoring exceeds the specific permit requirements. However, it is included because of its potential to enhance information from the other two legs of the “triad” (Figure 3-8) and provide additional guidance to source identification studies.
3.4.1.1 Monitored parameters
In addition to the habitat and biological community parameters typical of bioassessment approaches, this element will include routine monitoring of:
Nutrients
o nitrate plus nitrite
o total ammonia
o total Kjeldahl nitrogen (TKN)
o total phosphate
o orthophosphate
Total suspended solids (TSS)
Volatile suspended solids
Turbidity
pH
Oil and grease (if sheen is present)
Temperature
Dissolved oxygen
Electrical conductivity
Hardness
Total and dissolved heavy metals
o cadmium
o chromium
o copper
o lead
24 o silver
o zinc
Organophosphate pesticides
o diazinon
o chlorpyrifos
o malathion
o dimethoate
Toxicity testing with the standard freshwater test organisms Selenastrum, Hyallela azteca, and Ceriodaphnia (with the addition of fathead minnow in the Newport Bay watershed).
3.4.1.2 Monitoring sites and analyses
The bioassessment program will include up to 12 monitoring stations, determined in coordination with the Regional Board and SCCWRP (Figure 3-9). While explicit siteselection criteria have not yet been established, it is likely they will include some or all of the following:
Be located within a range of watersheds throughout the north County Be representative of urban stream conditions within these watersheds (e.g., Santa Ana River, Santiago Creek, San Diego Creek, Peters Canyon Wash) Be listed in the Basin Plan as containing freshwater aquatic habitat Meet the physical criteria of the California Stream Bioassessment Procedure Be coincident with, or in close proximity to, a long-term mass loading monitoring site.
To the extent feasible, as many as possible of the monitoring sites will be in channels that contain mass loading sites (see Section 3.1.2). Although the bioassessment sites will most probably be upstream of the mass loading sites (which are situated as close to the mouths of their respective watersheds as possible) the availability of loadings data may help in interpreting bioassessment results from these watersheds. Sampling at the 12 sites will be conducted twice annually, in May and October, to coincide with the end and the beginning of the rainy season. Sites will be selected to ensure that adequate flow is present at these times of years in all but drought conditions.
Data from each site will be used to establish a basis for longer-term trend monitoring of site-specific conditions. In addition, correlation and other appropriate statistical analyses will be used to search for site-specific relationships between chemical measurements, toxicity results, and bioassessment results. These site-specific relationships will be compared across sites in order to gain an understanding of the differences between reference and more urbanized sites, as well as of any gradient of changes that might be associated with various degrees of pollution and/or habitat disturbance. On a regional basis, data from each site will be compared to an appropriate Index of Biological Integrity (IBI) when this becomes available (see Section 3.4.3.3).
There are no formal and widely accepted frameworks for interpreting data from the Triad approach in the context of stormwater management. We will utilize the
25 framework developed by the San Diego County Stormwater Program (Table 3-2), which provides a decision framework for implementing specific follow-up analyses depending on particular combinations of Triad results.
3.4.2 Regional monitoring
The two aspects of this component that are relevant to regional monitoring, the development of a model stormwater monitoring program and the development of a regional Index of Biotic Integrity (IBI) are discussed in the following section on special studies.
3.4.3 Special studies
In addition to the core monitoring, there are five additional special studies aspects of this program element (see Table 2-1):
Toxicity tests at higher dilutions
Toxicity identification evaluations (TIE)
Upstream source identification
Design of a model stormwater monitoring program
Development of an urban stream Index of Biotic Integrity (IBI).
Two of these, toxicity testing and toxicity identification evaluations (TIEs), will characterize impacts in more depth, while the index of biotic integrity (IBI) will provide a more standardized framework for interpreting bioassessment monitoring results.
3.4.2.1 Toxicity tests at higher dilutions
See Section 3.1.3.1 above for a discussion of how additional tests will be implemented.
3.4.3.2 Toxicity identification Evaluations (TIEs)
See Section 3.1.3.2 above for a discussion of the Program’s approach to TIEs.
3.4.3.3 Upstream source identification
See Section 3.1.3.3 above for a discussion of the Program’s approach to upstream source identification.
3.4.3.4 Model stormwater monitoring design
See Section 3.1.3.4 above for a description of the program’s participation in the SMC’s model stormwater monitoring design project. This project may result in regionally consistent approaches to bioassessment monitoring, the use of the “triad” approach, and the application of TIEs.
26 3.4.3.5 Urban stream Index of Biotic Integrity
The Stormwater Program will also participate in the SMC’s planned effort, in cooperation with the California Department of Fish and Game to develop an urban stream Index of Biotic Integrity (IBI) that is consistent across the entire southern California region. This may result in a single IBI or a set of related IBIs that are appropriate for various subsets of the southern California region.
3.5 Reconnaissance Monitoring
The goal of the reconnaissance component of the program is to identify and eliminate illegal discharges and illicit connections (ID/ICs). This will be accomplished through a monitoring design that targets specific, individual sites for which there is some prior evidence (e.g., history of spills or contamination events, surrounding landuses) that suggests the presence of IC/IDs.
3.5.1 Core Monitoring
Core monitoring aspects of this program element will consist primarily of monitoring at 30 or more targeted sites selected for their potential to provide information about IC/IDs. In addition, ten randomly selected sites will be monitored during the first year.
The data from these random sites will be used to determine if monitoring data from the San Diego region of the County can provide a basis of comparison for determining which targeted sites warrant further source identification studies to be carried out by the relevant city.
3.5.1.1 Monitored parameters
Monitored parameters will include:
Ammonia (f)
nitrate (f)
soluble phosphorus (f)
Total suspended solids (TSS)
pH (f)
Oil and grease (if sheen is present) or total petroleum hydrocarbons Temperature (f)
Dissolved oxygen (f)
Electrical conductivity (f)
Hardness (f)
Dissolved heavy metals
o cadmium
o hexavalent chromium (f)
o total chromium
o copper (f&)
o lead
o nickel
27 o zinc
Organophosphate pesticides
o diazinon
o chlorpyrifos
o malathion
o dimethoate
Bacterial indicators
o total coliform
o fecal coliform
o Enterococcus
MBAS (f)
Phenols (f).
(f) field determination
(f&) field determination and laboratory analysis
3.5.1.2 Monitoring sites and analyses
The locations of the sites recommended by the individual cities are listed in Table 3-3 and shown on Figure 3-10. These sites were all chosen based on their elevated potential to contain pollution from IC/IDs. This potential was subjectively evaluated on the basis of past history of spills, local land uses, the configuration of the drainage network, and the proximity of concentrations of specific types of commercial and/or industrial activities. Sampling and analytical methods will be the similar to those used in the San Diego region of the County (see Appendix 1, Section 3.2.1.2).
An important issue in this design is establishing the criteria to be used to trigger followup source identification studies by individual cities. In principle, only those sites that contain significantly higher than average levels of pollutants, or that exhibit unusual increases of pollutant levels over time, should be targeted, so that resources can be prioritized to deal with the worst problems first.
The County’s reconnaissance program in the San Diego region of the County accomplishes this by comparing monitoring data from all reconnaissance sites to the average regional background, established with data from a set of 30 randomly selected sites (see Appendix 1, Section 3.2.1.1). Statistical methods (i.e., tolerance intervals, control charts) are then used to determine which sites contain pollutant levels that are well above the average background (see Appendix 2).
If the description of the average regional background from the San Diego portion of the County could be applied to the Santa Ana portion of the County, this would improve consistency across the County and achieve potential cost savings. However, the Santa Ana portion of the County has larger concentrations of commercial and industrial activity, and thus the background calculated from sites in the southern portion of the County might not be applicable to the northern County. We will assess the applicability of the south County background with ten randomly selected sites (Table 4-4, Figure 3- 10) in the north County (selected from the list of major County drains that discharge to
28 open channels). If statistical tests show that the data from the north County are equivalent to the background data from the south County (Figure 3-11), then we will use the south County background estimates, and the procedures described in Appendix 1, Section 3.3 to select the subset of reconnaissance sites for follow-up source identification studies.
If statistical tests show that data from the ten randomly selected north County sites are not equivalent to those from the south County, then we will use a combination of three approaches to select monitoring sites for follow-up source identification efforts (see Appendix 1, Section 3.3 for additional detail). These are intended primarily to help provide the basis for determining which sites are candidates for follow-up source identification studies to be carried out by the Permittees. These include:
Comparison of each site’s data values with relevant guidance levels, which will help answer the question: What are the characteristics of urban dry weather runoff at specific locations that may present higher risk?
Calculation of a site-specific control chart for each individual targeted site (see Appendix 2 for more detail), which will help answer the question: Which sites exhibit substantial changes in their characteristics over time that could be indicative of worsening or improving conditions?
The application of professional judgment to assess the results of the preceding two statistical analyses.
When the County has identified a site that meets the criteria for follow-up studies, it will notify the appropriate City representative that follow-up IC/ID efforts should be initiated. However, if the monitoring program finds extreme conditions that represent a clear and immediate risk to human health or receiving water quality, or that provide unambiguous evidence of a substantial upstream problem, then this routine procedure will be bypassed and the relevant inspector for that City notified immediately. In both kinds of instances, if the monitored site is near a jurisdictional boundary and the upstream drainage network for the site extends into a neighboring jurisdiction, both the jurisdiction containing the site as well as the jurisdiction containing the upstream portion of the drainage network will be notified.
The County plans to deliver monitoring data to the cities as soon as it is received from the contract laboratory and processed through a set of quality control checks. In most cases, this will be accomplished within 45 days of the sampling data. In addition, the County will carry out the procedure described in Appendix 1, Section 3.3 after each sampling event and notify the relevant city of any sites that require follow-up IC/ID investigations within 21 days of receipt of the data from the laboratory.
Each year’s monitoring results will be used to assess the need for continued monitoring at each targeted site. The list of targeted sites will be reevaluated to determine whether an individual site requires further monitoring by the County or whether monitoring can
29 be shifted to another targeted site that has yet to be monitored. Monitoring will be discontinued at a particular site when:
Multiple sampling events find no evidence of elevated values compared to the regional tolerance interval
An IC/ID effort, led by the relevant Permittee, is underway and does not require further County monitoring data from the targeted site
An IC/ID effort has found the source of elevated values.
In such cases, the Program will identify additional priority sites and shift monitoring effort to those.
3.5.2 Regional monitoring
See Section 3.1.3.4 above for a description of the program’s participation in the SMC’s model stormwater monitoring design project. This project may result in regionally consistent approaches to reconnaissance monitoring and to the development of consistent criteria for triggering follow-up IC/ID investigations.
3.5.3 Special studies
Follow-up IC/ID source investigation studies may be triggered in specific instances by the core reconnaissance monitoring data. However, with the exception of Seal Beach, which is unincorporated County land, these will be conducted by the individual Permittees. In the case of Seal Beach, any needed studies will follow the approach described above in Section 3.1.3.3.
3.6 Land Use Correlations
The goal of the land use correlations component of the program is to determine the effects of changes in land use on the quality of receiving waters, in particular, the impacts of increasing development and the conversion of agricultural land on the sediment loading of Upper Newport Bay.
This goal will be addressed with an experimental design that uses a series of comparisons to help isolate the impacts of specific kinds of land use changes.
3.6.1 Core monitoring
Core monitoring aspects of this program element will consist primarily of the implementation of an experimental design that will measure several key parameters in runoff both before and after conversion of agricultural land to urban land uses. The monitoring design is intended to answer the question:
30 What is the reduction in sediment load (and associated pollutants) in runoff associated with the conversion of agricultural land to urban land uses? The monitoring design will include flat farmland at a minimum and may also include hillside agricultural sites if appropriate and representative ones can be found. Two replicate sites will be monitored in each condition (i.e., flat, hillside) and monitoring will take place both before and after land conversion has occurred. Replicate sites within each condition are required in order to estimate the variability in converted sites of a similar type. Repeated monitoring events in both before and after conditions are required in order to estimate the background temporal variability against which changes due to land use conversion will be compared (Figure 3-12).
The ability to implement this design will depend on the timing of land use conversions in these two areas and the speed at which they progress. Specific decisions about the size and location of monitoring sites will depend on development plans, as will the number and timing of monitoring events in the before and after conditions. [Note:
reconnaissance of potential sites will be taking place at the end of June.]
3.6.1.1 Monitored parameters
Monitored parameters will be the same as those monitored in the mass emissions element of the program (Section 3.1.1.1).
3.6.1.2 Monitoring sites and analyses
The locations of study areas and monitoring sites within these will be determined in consultation with the Regional Board and relevant developers, depending on the schedule of planned land conversions. Potential study areas include the old Tustin helicopter base, a planned development north of Brea, and a planned development in Villa Park.
Data analyses will involve standard ANOVA (analysis of variance) approaches to assessing differences between land use type and between before and after conditions.
3.6.2 Regional monitoring
If possible, study areas will be chosen to complement other monitoring being carried out for (or planned for) the Sediment, Nutrient, and Toxics TMDLs.
3.6.3 Special studies
The monitoring results may suggest additional questions that may warrant special studies to investigate patterns of pollution during certain conditions, the relationship between soil and runoff characteristics, the different effects of alternative development scenarios, and the application of different sets of BMPs.
31 3.7 Nutrient TMDL Monitoring
The permit specifies that the Permittees shall continue to participate in the Regional Monitoring Program for the San Diego Creek Nutrient TMDL. This monitoring program is most recently described in the Regional Board’s staff report, “A Regional Nutrient Monitoring Program for the Newport Bay Watershed – RWQCB Staff Report.” This is included as Appendix A in Appendix T of the County Stormwater Program’s 2001 Annual Status Report.
In addition, the permit states that strategies must be revised and/or developed to evaluate the impacts of stormwater or non-stormwater runoff on all impairments with the Newport Bay watershed and other 303(d) listed waterbodies. The components of the receiving water program described in the preceding sections meet this objective. 303(d) listing is dynamic, as the permit recognizes, as is the state of our knowledge about the patterns and sources of impacts due to urban runoff. The receiving water program explicitly recognizes this dynamism by including adaptive elements and special studies throughout the program.
3.8 Relationship to the Bight ’03 Study
There are several instances in which the Program’s participation in the Bight ’03 study will complement the NPDES permit monitoring. For example, the Bight ’03 stormwater plume tracking and characterization study will provide a broader context for interpreting data from the coastal stormdrain monitoring element, and the Bight ’03 coastal ecology monitoring will do likewise for the Program’s wetlands and estuaries monitoring element. In addition, the Program is cooperating with UCI researchers on a project in the Santa Ana River to improve our understanding of the ecology of bacterial indicators.
The Program is making a direct financial contribution to both these efforts and therefore proposes to offset these costs during the first year of the permit by foregoing the monitoring of one storm event in the Huntington Harbour / Bolsa Bay estuary. The cost offset from not sampling the two channel stations and the five estuary sites in this estuary would be $56,100. This one-time cost offset will help ensure that the Program’s overall monitoring effort, including its participation in Bight ’03 and the Santa Ana River study, remains cost neutral.
4.0 SUMMARY
This report fulfills the requirements of the Monitoring and Reporting Program defined in Permit CAS618030, Order No. R8-2002-0010, from the Santa Ana Regional Water Quality Control Board to the Orange County Stormwater Program Permittees. It describes the design of the new Third Term Permit monitoring plan to be implemented beginning July 2003. There are three distinct aspects of the Program that deserve emphasis.
32 4.1 Program Philosophy
In terms of the overall philosophy underlying the monitoring program, the program will continue to improve its ability to assess compliance, document impacts, identify the sources of these impacts, and evaluate the effectiveness of best management practices (BMPs) and other management actions taken by the Permittees to reduce impacts (Figure 4-1). This means the Program should continue to improve its ability to:
Assess compliance
Describe the ultimate impact of stormwater runoff on ecosystems (e.g., by including bioassessment in routine monitoring)
Target additional kinds of impact (e.g., on estuarine and wetland ecosystems) Work with the Permittees to identify and evaluate effective methods for reducing pollutants and other stormwater-related sources of impact.
This will require the continued development of new monitoring tools and approaches.
4.2 Program Structure
In terms of the basic structure of the monitoring program, the program will formally adopt the three-part structure being considered by the Stormwater Monitoring Coalition – core monitoring, regional monitoring, and special studies. As Table 2-1 shows, this is an effective way to organize the range of monitoring activities needed to fully address the objectives described in Table 2-4.
It also provides a means of avoiding the constraints on spatial pattern and temporal trend analyses stemming from shifts in methods, management and monitoring questions, and sampling designs. By providing mechanisms to address several different types of questions, it allows for core monitoring stations, spread throughout the northern region of the County, to be sampled with consistent methods over a period of many years. Such stable core monitoring elements reduce variance from extraneous sources, thereby enhancing the Program’s ability to perform trend analyses and spatially extensive analyses without hampering the capacity to conduct a full range of shorterterm special studies.
This three-part structure also highlights the Program’s growing involvement in regional monitoring and its opportunity to cost effectively develop new monitoring techniques, standardize approaches, and carry out monitoring efforts that are beyond the Program’s capacity when acting alone.
4.3 Specific Program Elements
In terms of the specific elements of the monitoring program, the program will adopt the elements summarized in Section 3.0 for the ensuing five-year permit period, including:
Long-term mass emissions monitoring
Estuary / wetlands monitoring
33 Bacteriological / pathogen monitoring
Urban stream bioassessment monitoring
Dry weather reconnaissance
Land use correlations
Nutrient TMDL monitoring.
This new program is notable for the addition of routine bioassessment and toxicity testing, the provision for toxicity identification evaluations (TIEs), as well as for expanded estuary and wetlands assessment. In addition, these elements involve several interactions with the Stormwater Monitoring Coalition’s efforts to improve and standardize methods. They also include two specific interactions with the upcoming regional Bight ’03 study:
Participation in the assessment of conditions in estuaries, which will provide a regional background for the evaluation of local conditions in Newport Bay, Talbert Marsh, Huntington Harbour, and Bolsa Bay
Participation in the coastal plumes study, which will provide data to complement the Program’s studies of bacterial contamination in coastal storm drains.
34 APPENDIX 1: SAN DIEGO REGION DRY WEATHER RECONNAISSANCE The following material is taken from the description of the dry weather reconnaissance program developed for the San Diego region of the County. Section numbers correspond to those in the original report. However, only those tables relevant to the data analysis procedures are included (e.g., tables and figures describing site locations are not included).
3.0 Future Dry Weather Monitoring
The Permittees’ Dry Weather Monitoring Program under the San Diego Regional Water Quality Control Board’s Order No. R9-2002-0001 consists of three main elements:
A set of randomly located stations intended to characterize the average area-wide conditions in urban runoff
A set of rotating targeted stations intended to provide additional information about specific sites thought to have a high potential for contaminated runoff and to provide coverage of the entire MS4 system over the period of the permit term A set of criteria that will trigger focused IC/ID (illegal connection and illicit discharge) studies by the Permittees when the monitoring data indicate the presence of a problem.
It is important to recognize that the Permittees’ overall Stormwater Management Program includes a wide range of elements that involve activities such as public education, inspections, and a variety of best management practices (BMPs). The Dry Weather Monitoring Program described in this section will provide important feedback on the ultimate effects of such actions on stormdrain water quality. Combined with special studies and focused BMP evaluations, the Dry Weather Monitoring Program will enhance the Program’s ability to continually adapt its management approach as knowledge improves.
3.1 Objectives and Program Overview
The objectives of the Dry Weather Monitoring Program, as stated in the permit, are to:
Assess compliance with Order No. R9-2002-0001
Detect and eliminate illicit discharges and illegal connections to the MS4 system (by identifying sites that will be the subject of follow-up source identification investigations conducted by the Permittees)
Characterize urban runoff within the MS4 system with respect to water quality constituents that may cause or contribute to exceedances of receiving water quality objectives when discharged to receiving waters.
35 These objectives translate into six fundamental questions that form the basis for specific design elements of the Dry Weather Monitoring Program:
1. What are the average background characteristics of urban dry weather runoff in the region?
2. What are the trends in these background characteristics over time?
3. What are the characteristics of urban dry weather runoff at specific locations that may present higher risk?
4. What are the trends in runoff characteristics at these locations?
5. Which sites exceed the overall regional average by a substantial amount in one or more constituents?
6. Which sites exhibit substantial changes in their characteristics over time that could be indicative of worsening or improving conditions?
The randomly located sites will address Questions 1 and 2. The targeted sites will address Questions 3 and 4. Data from all sites will be used to address Questions 5 and 6, using the criteria established to trigger follow-up IC/ID studies by the Permittees. The goal of these studies will be to seek out reasons for exceedances and, if feasible, correct the problems. Data from the IC/ID studies can be combined with monitoring data to help link particular land uses to specific patterns of contamination. Figures 3-1 and 3-2 present maps of the random and targeted station locations, respectively. Figures 3-1 and 3-2 also demonstrate that each Permittee has at least one site in each major drainage area in its jurisdiction (major drainage areas are defined as the major watersheds listed in Table 3-1), in accordance with permit section E.4.b.2.
Three aspects of the dry weather program deserve to be emphasized:
First, the initial year of monitoring will have a stronger emphasis on characterizing average background conditions through the use of the random sites. As the estimates of background conditions stabilize, some of this monitoring effort may be shifted to targeted sampling focused on specific potential problems. Second, the list of targeted sites will be updated each year as potential problems are identified and/or resolved. This will enable the Permittees to meet the permit requirement to “provide adequate coverage of the entire MS4 system” (E.4.b.3) over the course of the full permit term.
Third, monitoring data will be evaluated from a variety of perspectives (see Section
3.3) and decisions about whether to initiate follow-up investigations will be based on professional judgment. Thus, there are no automatic triggers built into the program.
3.2 Dry Weather Monitoring Program Elements
36 The dry weather monitoring program will address the six questions listed above with a two-part sampling design. The first part consists of 30 randomly selected sites intended to address questions about regional background conditions (Questions 1 and 2). The second part consists of 24 non-random, targeted sites intended to address questions about specific locations (Questions 3 and 4). Data from both sets of sites will be used to address questions about which sites should be evaluated more extensively by the Permittees because they exhibit higher values of pollutants or substantial changes in such values over time (Questions 5 and 6). The set of targeted sites will be updated each year to ensure that monitoring results in the coverage of the entire MS4 system over the course of the permit period.
The Dry Weather Monitoring Program will sample each of the 30 random sites three times and each of the 24 targeted sites five times during the five-month dry season.
Laboratory analyses for metals, coliforms, pesticides, and oil and grease will be carried out for all samples, in addition to the on-site analyses conducted at each site. While this level of sampling and laboratory analysis exceeds the permit requirements, we believe it is warranted for three reasons:
First, past experience has shown that problematic discharges can be intermittent in nature and there is a much greater likelihood of identifying such discharges if sampling occurs at a greater frequency
Second, not all potential problems can be identified by the set of on-site analyses; thus, performing laboratory analyses at each site at each sampling event will maximize the program’s ability to detect potential problems Third, interpreting monitoring results, putting them into context, and assessing their relative severity can be more effectively accomplished with this more intensive sampling and analysis approach.
Thus, the monitoring design described below reflects the fundamental philosophy that the program will produce more usable information by concentrating monitoring resources on a given set of sites, and sampling and analyzing them more intensively, than would be achieved by monitoring a larger number of sites less intensively. We also emphasize that the cumulative number of sites monitored will increase each year as effort is shifted from random to targeted sites and as monitoring rotates to new sets of targeted sites each year.
3.2.1 Random Site Sampling
The goal of the random sampling element is to characterize concentrations and trends in the average conditions of urban runoff. A related goal is to help identify those sites that are candidates for follow-up source identification efforts. This section describes the site selection protocol, identifies the sites chosen for random sampling, and describes field sampling and laboratory analysis.
37 3.2.1.1 Random Site Selection
Figure 3-3 outlines the steps involved in selecting sites for the random sampling element of the Program.
There are two primary considerations in selecting sites for the random element of the program. The first is defining the pool of potential sites to be drawn from and the second is ensuring that the random selection is not overly weighted toward one geographic area at the expense of others. These two issues are discussed more fully in the following paragraphs.
The primary goal of the Dry Weather Monitoring Program is to provide focus and support to an illicit connection and illegal discharge (IC/ID) effort, which means that the program should concentrate on urban runoff to the greatest extent possible. This can best be achieved by attempting to remove extraneous influences by including only enclosed pipes in the pool of potential sites. Open channels run the risk of including fecal contamination from birds and other wildlife, while enclosed pipes are more likely to reflect the influence of urban runoff. In addition, including only pipes that collect runoff from predominantly urbanized land uses (as opposed to open space areas) will also help ensure that monitoring focuses on the impacts of urban runoff. However, in order to achieve the most efficient “coverage” with the least number of tests, it may be necessary to occasionally collect some samples from open channels.
The County’s database of facilities contains 148 major named drains in the south County that are designated as enclosed pipes draining urbanized land uses. Of these, 64 pipes discharge either to an open channel or to the ocean where sampling is more feasible.
However, it is known that not all stormwater pipes are included in the County’s database. This does not represent a problem for the random site selection if the undocumented pipes are spread throughout the study area and are not significantly different in character from the documented pipes. We have no reason to believe that the undocumented pipes fail these two criteria.
The other major consideration in selecting sites is to avoid a geographic overweighting of random sites in a small portion of the study area. This was achieved by creating geographic strata based on watersheds (Figure 3-1) and allocating random sites to each stratum based on their relative proportions of urbanized land. Urbanized land uses included:
Commercial
Education and religion
Industrial
Recreational
Residential
Transportation, communication, utility.
More specifically, strata were defined based on watershed boundaries (see Table 3-1 for a list of watersheds and Figure 3-1 for their locations). The area of total urbanized land
38 uses in each watershed was then calculated based on GIS maps produced by the County’s Geomatics Division. The relative proportion of the total urbanized land uses appearing in each stratum was then used to divide the total pool of 30 random sites among the strata (see Table 3-1 for the number of random sites per watershed). For example, if a stratum contained 10% of the study area’s total area of urbanized land uses, it would be allocated 10%, or 3, of the sites. Once the proportional allocation was determined, the specified number of random sites per stratum was selected from the pool of potential sites. One additional site was selected per watershed as an alternate site to be used when a primary site is found to be dry, with the exception of watersheds H (Los Trancos) and I (Laguna Canyon), which had only one suitable pipe apiece. Table 3-2 lists the random sites and Figure 3-1 illustrates their distribution throughout the study area.
One adjustment was made to this randomization scheme. The number of sites in the Salt Creek watershed (K) was increased from two to four, and the number of sites in the San Juan Creek watershed (L) was reduced from 15 to 13. This adjusment was made to ensure a more complete geographic coverage of the study area.
3.2.1.2 Random Sampling and Laboratory Analysis
Monitoring will be conducted three times during the dry season (May through September) at each site. Monitoring will begin in May and subsequent monitoring carried out in July and September, depending on logistical constraints that may shift the monitoring time somewhat. Monitoring at each site will consist of:
Field observations
Field screening analyses
Analytical laboratory analyses.
If flow or ponded runoff is observed at a site and there have been at least seventy-two (72) hours of dry weather, field observations will include general information such as time since last rain, quantity of last rain, site descriptions (i.e., conveyance type, dominant watershed land uses), temperature (air and water), and visual observations (e.g., odor, color, clarity, floatables, deposits/stains, vegetation condition, structural condition, and biology). Flow estimates will be made at each site where there is flowing water, based on the width of the water surface, the approximate depth of water, and the approximate flow velocity. The flow measurements may contribute to pollutant mass loading estimates and to identifying substantial changes in discharge that bear further investigation. Digital photographs may be taken to document unusual conditions that may have a bearing on the interpretation of the other monitoring data.
If flow or ponded runoff is observed at a site and there have been at least seventy-two (72) hours of dry weather, a grab sample will collected for an on-site analysis (field screening) of the parameters specified in permit Section E.4.d.1.d:
Turbidity
pH, specific conductance, dissolved oxygen, water temperature
39 Reactive Phosphorous
Nitrate Nitrogen
Ammonia Nitrogen
Phenol
Surfactants (MBAS)
Total hardness (from Section e.4.d.1.e).
If flow or ponded runoff is observed at a site and there have been at least seventy-two (72) hours of dry weather, a grab sample will be collected for laboratory analysis of the parameters specified in permit Section E.4.d.1.e:
Oil and grease
Diazinon and chlorpyrifos
Cadmium (dissolved)
Copper (dissolved)
Lead (dissolved)
Zinc (dissolved)
Fecal coliform bacteria
Enterococcus bacteria
Total coliform bacteria
Total suspended solids (TSS)
Total chlorine (not specified in permit).
If a designated site is dry (i.e., no flowing water or ponded runoff), then all applicable observations will be recorded and sampling will be attempted at the alternate site for that watershed. Table 3-3 lists the analytical methods that will be used for each parameter.
In accordance with permit Section E.4.d.6, monitoring staff will use a global positioning system (GPS) unit to record the coordinates of each site on the first sampling event.
These coordinates will then be compared to those in the County’s GIS system to verify the accuracy of the database and update it if necessary.
3.2.1.3. Random Data Analysis
There are three components to the analysis of data from the random sites. These are intended to help provide the basis for determining which sites are candidates for followup source identification studies to be carried out by the Permittees (see Section 3.3).
These include:
Calculation of a regional tolerance interval based on data from all 30 random sites, which will help answer Question 5: Which sites exceed the overall regional average by a substantial amount in one or more constituents?
Comparison of each site’s data values with relevant guidance levels (Table 3-4), which will help answer Question 3: What are the characteristics of urban dry weather runoff at specific locations that may present higher risk?
40 Calculation of a site-specific control chart for each individual random site, which will help answer Question 6: Which sites exhibit substantial changes in their characteristics over time that could be indicative of worsening or improving conditions?
Tolerance intervals are a quantitative, rigorous method for incorporating and addressing the presence of variability in background conditions when a monitoring program searches for data values that are significantly different from background (see Appendix 2 for technical detail). A tolerance interval bound is simply the upper or lower confidence-interval bound of a quantile of the background data distribution (see Figure 3-4). Tolerance intervals will be calculated as described in the technical appendix and applied as described in Section 3.3 to help identify candidate sites for further follow-up investigations by the Permittees. The tolerance interval will be derived after the first sampling period and will then be recalculated each time the random sites are sampled throughout the duration of the program, in order to ensure that decisions are being made with the best data possible. As additional data lead to better estimates of variance, the tolerance interval will continue to become more precise over time. We investigated the possibility of accelerating this process by developing a regional tolerance interval with existing data, but found this was not feasible because existing data were not collected with a random sampling design.
Where guidelines and/or standards are available, data will be compared to these (Table 3-4), although it should be noted that any standards in Table 3-4 have been developed for receiving waters and not for the storm drain system. Information about the degree and persistence of exceedances will be used to help identify which sites are candidates for follow-up source identification efforts (see Section 3.3).
Control charts provide a means of tracking data at each individual site and identifying when new data values deviate substantially (either upward or downward) from previous experience (see Appendix 2 for technical detail). A control chart can be used to establish a bound or threshold, based on previous monitoring data, as illustrated in Figure 3-5. Control charts will be calculated as described in Appendix 2 and applied as described in Section 3.3 to help identify candidate sites for further follow-up investigations by the Permittees. The site-by-site control charts will be recalculated each time the random sites are sampled throughout the duration of the program in order to ensure that decisions are being made with the best data possible. As additional data lead to better estimates of variance, the control charts will continue to become more reliable over time. We investigated the possibility of accelerating this process by developing sitespecific control charts with existing data, but found this was not feasible because appropriate grab sampling data were not available from these sites.
The results of these three analyses will be combined with professional judgment to identify those sites that are candidates for further source identification efforts by the Permittees (see Section 3.3 for more detail).
3.2.2 Targeted Site Sampling
41 The primary goals of the targeted sampling element are to, first, characterize concentrations and trends at particular sites that are thought to have a high potential for polluted runoff and receiving water impacts, and, second, help provide coverage of the entire MS4 system. A related goal is to help identify those sites that are candidates for follow-up IC/ID efforts. This section describes the site selection protocol, identifies the sites chosen for targeted sampling, and describes field sampling and laboratory analysis.
3.2.2.1 Targeted Site Selection
Sites for the targeted, or non-random, portion of the Dry Weather Monitoring Program were selected by combining information from two primary sources:
County staff’s knowledge about the sorts of locations and land uses with a high potential for polluted runoff
Input from the Permittees.
County staff have noted that concrete companies, chemical supply houses, waste transfer stations, food warehouses where transfer operations take place, and concentrations of automobile repair facilities are sometimes correlated with elevated pollutant levels. We used an Internet search engine to identify locations where concentrations of such industrial/commercial activities occurred, and then discussed these potential sites with knowledgeable City staff. In addition, the Permittees provided suggestions about sites they felt were areas of particular concern, based on inspections, spills, land use type, and other past experience.
Table 3-5 presents the final list of the targeted sites and Figure 3-2 illustrates their distribution throughout the study area.
As discussed in more detail below (Section 3.2.3), the list of targeted sites will be updated each year, with the twin goals of addressing high-priority potential problems first and achieving coverage of the entire MS4 system over the course of the full permit term.
3.2.2.2 Targeted Sampling and Laboratory Analysis
Sampling and laboratory analysis will be conducted as described for the random sites (see Section 3.2.1.2).
3.2.2.3 Targeted Data Analysis
There are three components to the analysis of data from the targeted sites. As with the random sites, these are intended primarily to help provide the basis for determining which sites are candidates for follow-up source identification studies to be carried out by the Permittees (see Section 3.3). These include: