2004 AGN JAN 20 I17 - Laserfiche WebLink

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• Inadequate inspection documentation. The existing inspection form only provided a checklist for non-compliance and lacked sufficient detail to understand industrial activities, processes, and potential for non-compliance; • Local Limits not having been re-evaluated despite a treatment plant upgrade to the tertiary facility (RIX) and an overall decrease in permitted industries; • Inadequate communication between the City of Grand Terrace and the City of Colton regarding the Pretreatment Program implementation and reporting required under the existing Interjurisdictional Agreement; and • No Policy and Procedures Manual to provide guidance and ensure consistent application of regulatory program elements (i.e. inspection protocol, enforcement response, standard forms, scope of program, etc.). Despite the lack of adequate implementation of various program elements, the City of Colton's Water Reclamation Facility remains in compliance with the effluent limitations in their current permit. However, the chronic non-compliance to oil & grease limitations by some industrial users is impacting sewer collection line maintenance and increases the potential for a sanitary sewer overflow. G&G has indicated that the deficiencies identified can be corrected fairly quickly. Program development (i.e. developing a Standard Operating Procedures Manual, evaluating local limits, establishing a sound database for tracking program activities, and establishing vital links between other City Departments) will require additional time. The poor condition of the program was not revealed until G&G completed the audit. As such, the actual cost of mitigation and program development could not be estimated. Staff intends to develop and solicit a formal RFP for program development and administration in the coming months. However, several pending permit and compliance issues remain and must be addressed. Based on G&G's current familiarization with the status of the program, qualifications and ability to meet the CUA's operational and technical needs, it is recommended that G&G Environmental be selected to continue program development and implementation for the remainder of the fiscal year. FINANCIAL IMPACT Staff recommends amending the existing current not -to -exceed $25,000 contract with G&G Environmental Compliance, Inc. for an additional $45,000. The aggregate not -to exceed amount for the contract will be $70,000 for the current fiscal year. Retained cash will need to be transferred to Professional Services Account No. 522-8200-8200-2350 in the amount of $45,000 during FY03/04 to fund the contract. ENVIRONMENTAL IMPACT Failure to administer the program in accordance with State and Federal laws could result in illegal discharges to the Santa Ana River or other wastewater treatment violations. CONFLICT OF INTEREST—Gift Disclosure Requirements G&G Environmental Compliance, Inc. President: Gary Ethridge Contact: (Same) Staff recommends that the Colton Utility Authority authorize the City Manager to amend the existing contract with G&G Environmental Services, Inc. to an amount not -to -exceed $70,000. Report prepared by: Eric Fraser, Director of Water and Wastewater REVIEW T NL City Attorney: Finance Director: City Manager: HER: