2004 AGN JAN 20 I17 - Laserfiche WebLink

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CITY OF COLTON AGENDA REPORT For the Colton Utility Authority Meeting of January 20, 2004 TO: HONORABLE CHAIRPERSON AND UTILITY AUTHORITY MEMBERS FROM: ERIC R. FRASER, DIRECTOR OF WATER & WASTEWATER OPERATIONS Item #17 SUBJECT: APPROVAL OF AMENDMENT TO THE CONTRACT FOR INDUSTRIAL PRETREATMENT INSPECTION AND ADMINISTRATION SERVICES TO G&G ENVIRONMENTAL COMPLIANCE, INC., IN AN AMOUNT NOT -TO -EXCEED $50,000 DATE: January 12, 2004 BACKGROUND The City of Colton's Pretreatment Program (Program) is required under existing federal pretreatment program regulations (40CFR403) and NPDES Permit No. CA 0105236. California Regional Water Quality Control Board, Santa Ana Region adopted Order No. 00-009 on May 19, 2000, which issued the NPDES Permit. The essential program elements required under this permit include inspection, monitoring, permitting, and enforcement. DISCUSSION/ANALYSIS G&G Environmental Compliance, Inc. (G&G) was retained earlier this year by the CUA to evaluate the current program and provide pretreatment inspection services. The City's program was audited by the EPA and Regional California Regional Water Quality Control Board, Santa Ana Region in February 2003. The follow-up audit by G&G was needed to assess program areas that had become deficient. G&G was hired to identify and correct a wide range of deficiencies that included reissuing expired permits; follow-up on enforcement actions; reviewing local limits; filing delinquent regulatory reports; performing required inspections; and preparing a plan and budget for implementation of the program on an annual basis. The previous program included one full-time employee. Records indicated that the one-man program was managed and implemented by a Grade I (CWEA) certified Environmental Compliance Inspector at an annual cost of —$75,000 including benefits. This level of certification is more suitable for entry-level inspectors. Programs are generally managed by Grade III or IV Certified Environmental Compliance Inspectors. Key features of the City's program were designed by Krieger & Stewart over ten years ago in response to the City being in violation of several pretreatment regulations. The program design includes local limits development, legal authority development (ordinance), Enforcement Response Plan (ERP) development, and establishing interjurisdictional agreements as needed for conditioning wastewater received by contributing agencies. These documents are the basis for the legal authority to conduct inspections, monitor compliance, and take progressive enforcement actions against those industries who fail to comply with permit and/or ordinance provisions. The preliminary assessment of the program revealed deficiencies in the implementation of several key program areas. These deficiencies include: • Existing Enforcement Response Plan (ERP) is not being followed; • Inaccurate and Expired Permits (i.e. incorrect discharge limits, wrong addresses, inconsistent requirements, delinquent reporting, etc.); • Lack of a program Industrial User Listing or Database; • Multiple instances of delinquent Program Reporting (Quarterly, Stormwater, etc.); • Lack of an adequate compliance tracking mechanism (i.e. database, wipe board, or some mechanism to ensure initial compliance orders are followed and reported on time);