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Stormwater Environmental Indicators Pilot Demonstration Project

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					                    Santa Clara Valley
                    Urban Runoff
                    Pollution Prevention Program




      Stormwater Environmental Indicators Pilot Demonstration Project
 INTERIM WORK PRODUCT
 Technical Memorandum: Indicators 18, 22 and 26
       Introduction _______________________________________________________________________ 2
          Background ____________________________________________________________________2
          Study Area _____________________________________________________________________5
          1992-1993 Pilot Project ___________________________________________________________5
          City of Santa Clara Stormwater Program ______________________________________________5
       Methods _________________________________________________________________________ 7
         Industrial/Commercial Pollution Prevention. ___________________________________________7
         BMPs Installed, Inspected and Maintained _____________________________________________8
         Industrial Site Compliance Monitoring ________________________________________________8
       Results __________________________________________________________________________ 9
          Industrial/Commercial Pollution Prevention ___________________________________________9
          BMPs Installed, Inspected and Maintained _____________________________________________9
          Industrial Site Compliance Monitoring _______________________________________________10
       Conclusions _______________________________________________________________________10
         Effectiveness of the City of Santa Clara’s Industrial Pollution Prevention Efforts______________10
         Usefulness of Stormwater Environmental Indicators____________________________________12
       Appendices
         City of Santa Clara Organizational Chart _____________________________________________ A
         NPS Inspection Violation Notice __________________________________________________ B
         Walsh Avenue Catchment Industrial Facility Types _____________________________________ C
         CWP Environmental Indicator Profile Sheets _________________________________________ D
         Survey for Industrial Businesses ___________________________________________________ E
         Survey Responses ______________________________________________________________ F
         Findings from Recent Surveys and Site Visits _________________________________________ G
         Recent Industrial Inspections of Existing Businesses ____________________________________ H
         Comparison of Industrial Inspections: 1993 and 1998 ___________________________________ I

                                                       Abstract
       Under a Water Environment Research Foundation grant, the Santa Clara Valley Urban Runoff Pollution
  Prevention Program (Program) is testing 20 of 26 stormwater environmental indicators proposed by the Center
  for Watershed Protection. Following up a 1993 pilot industrial inspection project, Program staff applied three
  indicators to a 28-acre industrial catchment in the City of Santa Clara. Working with City inspectors, staff sur-
  veyed pollution prevention efforts at 29 of 32 businesses, cataloged BMPs, and evaluated past and present
  compliance with stormwater pollution-prevention regulations.
       Businesses had substantially increased implementation of BMPs over six years, and more businesses were
  in compliance. Site managers associated “housekeeping” BMPs with efficient operation, but were generally
  unaware of Program objectives. Repeated violations and inconsistent compliance showed a need to target fol-
  low-up outreach and inspections. The interviews with site managers and compliance monitoring were useful
  indicator techniques. To use the number of BMPs implemented as an indicator of effectiveness, better inspec-
  tion records would be needed.                  F:\SC19\SC19-05\MEMO\walsh4.doc 7/20/99



Santa Clara Valley Urban Runoff Pollution Prevention Program
EOA, Inc. 1410 Jackson Street, Oakland, CA 94612 • 510-832-2852 • Fax 510-832-2856
    By Carolyn Chiu, Senior Engineer                                    will be collected from the entire Program area. See
    Santa Clara Valley Urban Runoff                                     Table 1.
    Pollution Prevention Program                                             This memorandum presents the results
                                                                        achieved by applying Indicators #18, #22 and #26
                       Introduction                                     to gauge the effectiveness of the Program’s storm-
          As part of the USEPA’s Environmental Indica-                  water pollution prevention efforts in the Walsh
    tors/Measures of Success Project, funded under                      Avenue Catchment.
    Clean Water Act Section 104(B)(3), the Center for
                                                                        Background
    Watershed Protection developed 26 “Environmental
    Indicators to Assess Stormwater Control Programs                          The City of Santa Clara is one of 13 Santa
    and Practices1.” The indicators were accompanied                    Clara Valley cities and towns named in a single
    by a suggested methodology for crafting an indica-                  NPDES stormwater permit issued by the California
    tor based monitoring program. Under a grant from                    Regional Water Quality Control Board for the San
    the Water Environment Research Foundation                           Francisco Bay Region (Regional Board). The County
    (WERF), the Santa Clara Valley Urban Runoff Pol-                    of Santa Clara and the Santa Clara Valley Water Dis-
    lution Prevention Program (Program) is testing 20                   trict are also Co-permittees under the permit.
    of the 26 environmental indicators. The main objec-                       The 15 Co-permittees jointly fund and manage
    tives of the Program’s Stormwater Environmental                     the Santa Clara Valley Urban Runoff Pollution Pre-
    Indicators Demonstration Project (SEIDP) are to                     vention Program (Program). The Program assists
    evaluate the usefulness, effectiveness, and applica-                the Co-permittees to meet their NPDES obligations
    bility of the Stormwater Indicator Methodology un-                  by implementing area-wide activities and by assist-
    der semi-arid conditions. This involves the selec-                  ing municipalities to implement their agency-specific
    tion, testing, and refining of protocols for                        stormwater pollution prevention programs.
    monitoring environmental indicators and the devel-                        Incorporated in 1852, the City of Santa Clara
    opment of guidance on selection and use of envi-                    lies at the south end of the San Francisco Bay. The
    ronmental indicators in the western states2.                        City is approximately 19.3 square miles and sustains
          The SEIDP will apply the Center for Water-                    a population of nearly 98,000.
    shed Protection’s stormwater indicator methodology
    at two distinct geographic scales: the 310-square-
    mile watershed of Coyote Creek (which includes the
    eastern portion of the City of San Jose) and a 28-
    acre industrial catchment along Walsh Avenue in
    the City of Santa Clara. See Figure 1.
          Data to analyze three of the social indicators


                                                                 Table 1
                                                  Indicators to Be Tested and Refined
     Coyote Creek Watershed                                              Walsh Avenue Catchment
     #5       Sediment Characteristics and Contamination                 #1        Water-Quality Constituent Monitoring
     #7       Stream Widening and Downcutting                            #2        Toxicity Testing
     #8       Physical Habitat Monitoring                                #3        Non-point Source Loadings
     #10      Increased Flooding Frequency                               #4        Exceedances of Water Quality Standards
     #11      Stream Temperature Monitoring                              #18       Industrial/Commercial Pollution Prevention
     #12      Fish Assemblage Analyses                                   #22       Number of BMPs Installed and Maintained
     #13      Macro-Invertebrate Assemblage                              #26       Industrial Site Compliance Monitoring
     #21      Illicit Discharges Identified/Corrected
     #23      Permitting and Compliance
     #24      Growth and Development
     Program Area
     #17      Public Attitude
     #19      Public Involvement and Monitoring
     #20      User Perception



2
                                                                                                                                    San Francisco Bay Region
        Figure 1: Study Area


                                                                            Santa Clara Basin                                                      Sa n
                                                                                                                                                Franci sc o
                                                                                                                                                   Ba y




                                                                                                                                                              Santa
                                                                                                                                                              Clara
                                                                                                                                                              Basin
                                                                                                        Alameda
                                                                                                         Coun ty
                                                    San Mateo                                                                            0 10 20 Miles
                                                     Cou nty


                                                                                      Milpita s                                  Santa Clara
                                                                                                                                   Co unty
                                                                                                             Count y



    Walsh                                                                                         San Jose



    Avenue
    Catchment                                                                                                   Coyote Creek
                                                                                                                 Watershed
              Lafayette Street




                                                                                                                       Mor gan
                                                                                                                        H ill




                                               ue
                                                      Storm Dr ain     #
                                                                       0
                                                                   Inle t
                                                                                                                                                                            N
                                 W alsh Aven


                                                                                                                                                                       W        E
                                                                                                                          0          5     10 Mile s
                                                                                                                                                                            S

    0                                                 0.25 Miles                                                                                                      Revised 3/31/99
                                                                                                                                                                      SCVURPPP




3
    Figure 2




4
    The City of Santa Clara is 95% developed. The                  1992-1993 Pilot Project
    proportions of land area devoted to various land
                                                                         The primary objective of the 1992-1993 Walsh
    uses are:
                                                                   Avenue Pilot Inspection Program4 was to reduce
            −    Residential ..............................36%     loads of zinc, copper, lead and other pollutants in
            −    Industrial .................................21%   the stormwater discharged from the catchment
            −    Roadways.................................18%      through a comprehensive inspection program de-
            −    Institutional Facilities ..............8%         signed to identify pollutant sources and to provide
                                                                   assistance to facility owner/operators of source con-
            −    Commercial...............................7%
                                                                   trol measures and BMPs. The secondary objective
            −    Parks/Open Space...................6%
                                                                   was to develop generic industrial inspection guide-
            −    Vacant/Agricultural.................4%            lines that could be applied by other Program partici-
                                                                   pants to locate and control important industrial
        Most industrial activity is high-technology                sources of storm water pollution within their juris-
    manufacturing and research.                                    dictions. These inspection guidelines included
    Study Area                                                     hands-on training for inspectors, the development
                                                                   of written procedures and forms, and the prioritiza-
          The Walsh Avenue Catchment is a 28-acre in-              tion of facilities for inspection. Over the course of
    dustrial area located on the north and south sides of          this pilot study, 23 facilities were inspected. 11 of
    Walsh Avenue between the Southern Pacific Rail-                these 23 facilities warranted a reinspection due to
    road lines and Lafayette Street in the eastern portion         problems that were identified to likely contribute
    of the City of Santa Clara. See Figure 2.                      pollutants to stormwater.
          Currently, 32 industrial and commercial busi-                  Eighteen of these current businesses also par-
    nesses operate in the catchment area. Activities in-           ticipated in the 1993 pilot study.
    clude metal plating, high-tech equipment assembly,
    parts distribution, and warehouse storage. Two                 City of Santa Clara Stormwater Program
    businesses have submitted a Notice of Intent to the                  The City of Santa Clara’s local Urban Runoff
    California State Water Resources Control Board                 Pollution Prevention Program is funded through
    under California’s General Industrial Stormwater               contributions from the City’s general fund, sewer
    Permit.3 (See Figure 2.) These two businesses also             utility fee and an established non-point source storm
    maintain pretreatment permits for industrial sewage            water fee. The stormwater program is coordinated
    discharge to the San Jose/Santa Clara Water Pollu-             through the Street Department staff under the direc-
    tion Control Plant. At three other locations, busi-            tion of the Deputy Director of Public Works/Street
    nesses formerly covered under the statewide permit             Superintendent. The program has been divided by
    have terminated coverage, either because they                  the various component elements and incorporated
    ceased specific operations covered under the permit            into the existing operations of City Departments.
    or because they have closed the business location all          An Organizational Chart is contained in Appendix
    together. Appendix C compares the types of indus-              A. The Street Department/Storm Drain Mainte-
    trial facilities in the Walsh Avenue Catchment in              nance Division manages the activities associated
    1993 and 1999.                                                 with Illicit Connection & Illegal Dumping Elimina-
          All surface drainage from the area flows to a            tion, Public Information and Participation and Pub-
    manhole located on the east side of the railroad               lic Agency Activities. The Planning Department
    tracks at the end of Walsh Avenue. The storm drain             oversees the New Development Construction com-
    system in this area discharges to the lower reaches            ponent. The Fire Department is responsible for
    of Guadalupe River. (A discussion of potential ef-             Industrial and Commercial Discharges Control. Be-
    fects of the discharge to the Guadalulpe River is              cause of the large concentration of high-tech manu-
    included in SEIDP Technical Memorandum #1.) A                  facturing, research and development, the City of
    stormwater monitoring stations in this manhole was             Santa Clara places high priority on this program
    used to collect samples from storms during 1989-               element on the IND Program Element.
    1996, and again in 1998-1999. An analysis of cur-                    The involved City staff meet bimonthly to co-
    rent and historical water quality data will be pre-            ordinate the Program.
    sented in a separate technical memorandum.                           The City of Santa Clara adopted the Program’s
                                                                   model Performance Standard for Indus-
5
    trial/Commercial Discharger Control (IND), but               hazardous materials management. The six elements
    made minor modifications to tailor the model to the          of the Unified Program are:
    specific types of business within the City.                  ⇒ Hazardous waste generators and onsite treat-
          The model Performance Standard and support-              ment of hazardous wastes
    ing documents provide for:
    ⇒ Inspections of industries which have filed a               ⇒ Spill prevention control and counter measure
      Notice of Intent (NOI) to be covered under                   plans for above-ground storage tanks
      the SWRCB statewide NPDES permit for                       ⇒ Underground storage tanks
      stormwater discharges associated with indus-
      trial activities;                                          ⇒ Hazardous material release response plans and
                                                                   inventory
    ⇒ Investigation of other facilities that are identi-
      fied within selected Standard Industrial Classi-           ⇒ Risk management and prevention
      fication (SIC) codes;
                                                                 ⇒ Uniform Fire Code Hazardous Materials Man-
    ⇒ Inspections of selected commercial facilities;                    agement Plans and Inventories
                                                                        A CUPA is the single local agency designated
    ⇒ Distribution of information on indus-
                                                                 by the Secretary as being responsible for the ele-
      trial/commercial Best Management Practices;
                                                                 ments of the Unified Program within its jurisdiction.
    ⇒ Action, under local authority, on all violations           Counties, cities or local agencies may become certi-
      of local municipal ordinances; and                         fied as Participating Agencies (PA) to implement
                                                                 one or more of the six program elements within the
    ⇒ Referral to the Regional Board of any signifi-             PA’s jurisdiction. The City of Santa Clara’s Fire
          cant problems which cannot be addressed                Department is a PA.
          promptly and fully under local authority.                     The Fire Department’s Hazardous Materials
          The Co-permittees have flexibility in imple-           Division responds to all chemical spills.
    menting the Performance Standard as long as Pro-                    The Fire Department conducts annual inspec-
    gram and regulatory objectives are met, and effec-           tions of industries and commercial establishments
    tive coordination with related components is                 throughout the City. At a minimum, facilities that
    apparent. Typically, cities/agencies tailor the or-          have filed an NOI are to be inspected at least every
    ganization and implementation of their industrial            3 years. Table 2 shows a schedule for implementing
    inspection program based on the number of facili-            facility inspections.
    ties to be inspected (i.e., the size of the city), funding          Inspections are documented using the NPS In-
    resources, and available staff.                              spection Violation Notice form (see Appendix B). The
          For example, the City of San Jose (a much lar-         City reported that documentation of violations is
    ger municipality adjacent to Santa Clara) employs            kept on file at the Fire Department (in some cases,
    staff dedicated to the urban runoff program and              also at the Street Department/Storm Drain Mainte-
    inspection activities. The City of Sunnyvale (also           nance Division). According to the City of Santa
    adjacent to Santa Clara) operates its own sewage             Clara annual reports to the Regional Board from
    treatment plant, and has combined stormwater and             fiscal years 1991/1992 to 1997/1998, the City’s
    wastewater pretreatment inspections into a single            Public Information and Participation (PIP) activities
    unit for consistent implementation of discharge              consisted of media advertisements, distribution of
    regulations and communication with industrial busi-          Program-developed education materials and guid-
    nesses.                                                      ance manuals, development of BMPs, and participa-
          Santa Clara, as with many cities, has incorpo-         tion in community workshops. These PIP efforts
    rated industrial inspections into their Fire Depart-         were typically targeted at the general public citywide
    ment’s routine inspections for various fire and safety       (i.e., not specifically to businesses in the Walsh
    codes. The City also coordinates a Unified Program           Avenue catchment).
    for inspections under California’s Certified Unified
    Program Agency (CUPA) law.                                                        Methods
          The Unified Program is an State and local ef-               The Center for Watershed Protection’s Envi-
    fort to consolidate, coordinate and make consistent          ronmental Indicator Profile Sheets for the three in-
    six existing program regulating hazardous waste and          dicators are included in Appendix D.
6
                                                                 Table 2
                                              Facility Inspection Implementation Schedule

  This timetable for implementing the Industrial/Commercial Discharger Control Program performance standard is based on facility
  type. Reproduced from City of Santa Clara Urban Runoff Management Plan (September 1997).

                                                                  Inspection            Percent of the total number of inspection to be
                                                                  Frequency                            conducted yearly

                                                                                   Year 1      Year 2      Year 3      Year 4
  A. NOTICE OF INTENT (NOI) FILERS
  NOI Filers and NPDES-Permitted Facilities 1                   within 1 year      100%        ---         ---         ---
  New NOI Filers                                                within 1 year      100%        100%        100%        100%
  ---                                                           annually           ---         100%        100%        100%
  Non-Significant Facilities 3                                  every 3 years                  P           P           P
  B. NON-FILER INVESTIGATIONS
  Automobile Dismantlers (SIC-5015)                             within 1 year      100%        AD          AD          AD
  Other Recycling Industries (SIC-5093)                         within 1 year      100%        AD          AD          AD
  Stone Clay and Concrete Products Industry                     within 1 year      100%        AD          AD          AD
  (SIC-3200 series)
  Trucking Facilities (SIC-4100 & 4200 series                   within 1 year      100%        AD          AD          AD
  C.         COMMERCIAL FACILITIES
  Facilities with Pretreatment Permits                          every 2 years      P           P           P           P
  Pretreatment Facilities Permitted for Zero Discharge          every 2 years      P           P           P           P
  Vehicle Service Facilities                                    every 2 years      P           P           P           P
  Food Service Facilities                                       every 3 years      P           P           P           P


   1 NOI facilities are re-classified as Significant or Non-significant after the first annual cycle of inspections.
   2 Significant Facilities are facilities determined to be potentially significant contributors to storm water pollution based on the best
   professional judgement of the assigned inspector
   3 Non-significant Facilities are facilities determined to be non-significant contributors to storm water pollution based on the best

   professional judgement of the assigned inspector.
      AD – Inspected at the agency’s discretion
      P – Pro-rated to correspond with inspection frequency




Industrial/Commercial Pollution Prevention.                                 ⇒ Can be used to assemble and compare imple-
                                                                              mentation costs between different industries
      The Center for Watershed Protection describes                           and different geographic locations.
Indicator #18 as follows:
       “Surveys of pollution prevention efforts for                         ⇒ Can be a component of an industry stormwater
industrial sites are conducted to assemble data re-                           educational program which incorporates results
garding the costs and benefits associated with                                into future pollution prevention programs.
NPDES stormwater permit compliance. Site manag-                             ⇒ Can foster partnerships with industry and help
ers are surveyed to obtain information regarding                              managers identify site conditions of which they
permit implementation costs (e.g. BMP construction                            may be unaware.
costs, spill prevention training costs), technical is-
sues regarding implementation of structural and                             BMPs Installed, Inspected and Maintained
nonstructural BMPs, and potential benefits gained.”
      According to the Center for Watershed Protec-                                The Center for Watershed Protection describes
tion, Indicator #18:
⇒ Can be used to assess industry perception of
                                                                                                   Santa Clara Valley
  effectiveness of stormwater BMPs and meth-                                                       Urban Runoff
  ods for improvement.                                                                             Pollution Prevention Program


                                                                                                                                              7
    Indicator #22 as follows:                                    This indicator may provide additional assess-
          “By tracking the number of BMPs that are in-       ment to help
    stalled, inspected, and maintained in a given area,      ⇒ Evaluate the performance of structural and
    stormwater practicioners may be able to measure the        non-structural stormwater BMPs;
    progress and effectiveness of municipal programs.
    As more BMPs are installed, one may assume with          ⇒ Determine the industry’s contribution to over-
    reasonable confiedence that progress in the storm-         all water quality degradation or improvement;
    water arena is being made. Regular inpsection and
                                                             ⇒ Induce public education, support and activism
    maintenance of BMPs will insure that existing
    stormwater management resources are fully utilized,      ⇒ Solicit political pressure and support for plan-
    will help identify facilities which require retrofits,     ning issues;
    and will identify areas requiring additional manage-
    ment resources.”                                         ⇒ Determine industrial stormwater management
          Indicator #22 uses the on site as measurements       needs, water quality trends and target restora-
    of stormwater pollution prevention efforts, and the        tion efforts;
    Program’s influence and effectiveness. According to      ⇒ Identify areas where technical support or re-
    the Center for Watershed Protection, this indicator             search are needed to help address problems.
    may also:
                                                                    The three indicators were applied by reviewing
    ⇒ Expose weaknesses in BMP design, reveal                the City of Santa Clara’s inspection records, by ask-
      maintenance needs and determine needs for              ing business owners to respond to a questionnaire,
      enforcement actions;                                   and by conducting on-site visits at 29 of the 32
    ⇒ Determine if existing BMPs are sufficient in           (91%) businesses within the study area.
      scope and size;                                               Surveys were sent to all the site managers of
                                                             the businesses in the Walsh Avenue Catchment. The
    ⇒ Propose improvements to the design criteria            survey requested general information regarding the
      for future BMPs;                                       business, their prior knowledge of the Program,
                                                             previous inspections, implemented BMPs and asso-
    ⇒ Provide useful data when conducting stormwa-
                                                             ciated costs. The survey is shown in Appendix E.
      ter retrofit inventories.
                                                                    A few weeks after sending the surveys, the site
                                                             managers were contacted to schedule meetings to
    Industrial Site Compliance Monitoring
                                                             collect the completed surveys in person and review
          The Center for Watershed Protection describes      them with the site managers. Of the 32 businesses
    Indicator #26 as follows:                                in the Walsh Avenue catchment, 29 businesses were
          “NPDES permitting now requires most indus-         visited and 27 completed surveys were collected.
    trial sites to develop and implement pollution pre-      The meetings with each individual site manager
    vention plans and implementation of on-site best         were followed by a 30-to-60-minute guided site
    management practices. Compliance monitoring is           visit.
    conducted by either industry representatives, regula-           The survey responses and the findings from
    tory officials or certified inspectors. Monitoring may   the surveys and site visits have been compiled in
    include pollutant constituent monitoring, as part of     Appendix F and Appendix G, respectively.
    a permit condition, or visual inspections to check
    compliance with the approved and adopted pollu-                                Results
    tion prevention plan.
          While pollutant constituent data and compli-       Industrial/Commercial Pollution Prevention
    ance with pollution prevention plans documenting              Some site managers said they had been intro-
    the success or failure of a program can be extremely     duced to the Program through previous inspections
    useful, water quality managers may consider other        or from brochures and flyers distributed during in-
    information in assessing management efforts. Ex-         spections. Thirteen of the 29 (45%) responded that
    amples include: number of staff hours devoted to         they had “never heard of” the Program prior to our
    monitoring, public outreach efforts, pollution pre-      contacting them. The City of Santa Clara had in-
    vention training for employees, and documentation        spected three of these 13 businesses during previous
    of pollution prevention teams.”
8
four months. This may mean that the site managers        BMPs Installed, Inspected and Maintained
associated the inspections with the Fire Department
                                                              Respondents were asked to “check all that ap-
uniforms worn by the inspectors, rather than spe-
                                                         ply” from a list of BMPs typically associated with
cifically with the stormwater program.
                                                         industrial sites. The most commonly implemented
      Conversations during subsequent site visit in-
                                                         BMPs included:
dicated that most site managers had only a cursory
knowledge of the Program. In general, these site         ⇒ Perform daily cleanup and sweeping of indoor
managers understood that stormwater can carry pol-         and outdoor work areas (21 responses);
lutants to nearby creeks and water bodies. However,      ⇒ Regularly remove trash and debris from out-
few respondents were familiar with the different           door areas (parking lots) (19 responses)
Program components or with the environmental and
legal consequences of stormwater violations. Few         ⇒ Properly dispose of process residues (sawdust,
were familiar with the term “best management prac-         metal scraps, fluids) (18 responses)
tices” (BMPs) — but most of the sites were imple-
menting BMPs.                                            ⇒ Properly store raw materials, products and by-
      Businesses’ costs for stormwater pollution pre-      products (15 responses)
vention include construction and maintenance of          ⇒ Minimize the use of wash water when cleaning
BMPs, training of staff and labor costs to implement       equipment and vehicles (14 responses
“operational” BMPs. According to the survey, 11
of the 27 respondents considered their implementa-       ⇒ Properly store paints, chemicals and solvents
tion costs minimal or zero. Another eight did not             (12 responses).
respond or checked “not applicable.” Follow-up                Appendix G presents a more detailed list of
discussions revealed that most site managers regard      BMPs applied and what should be applied based on
typical “BMPs,” such as proper material storage, dry     observations made during the site visit and discus-
sweeping or good housekeeping, as safety or “com-        sion of the survey with the site manager. Most of
mon sense” practices. Although the BMPs are im-          the sites in the catchment are indoor operations.
plemented, most managers are not consciously mo-         This minimizes the potential impact to storm water
tivated by the need to prevent stormwater pollution.     and the need for BMP implementation. However,
      Where site managers did identify costs related     some BMPs were applicable. Existing (and recom-
to stormwater pollution prevention, these tended to      mended) BMPs were related to general housekeep-
be one-time costs (for example, the cost to purchase     ing in the area surrounding the business and debris
a piece of equipment or to install a “structural”        bins, staff training and material storage.
BMP.) In general, the site managers did not perceive
or track the costs for operational BMPs or for main-     Industrial Site Compliance Monitoring
tenance of strucural BMPs.                                     The City of Santa Clara’s non-point source in-
      For most facilities in the Walsh Avenue catch-     spection visits are typically unannounced. The Non-
ment, staff training is informal, and is part of day-    Point Source (NPS) Inspector introduces himself
to-day interaction between supervisor and employee.      and the program and then proceeds with the as-
Two of the larger facilities reported that they con-     sessment. Comments and observation are docu-
duct routine “tailgate” meetings with staff. The time    mented on the City’s NPS Inspection Violation Notice
required to implement these BMPs and train staff         form. After each inspection, the NPS inspector and
varied from 10 minutes per day to 16 hours per           the site manager review questions, findings and po-
week with the majority of time in the categories of      tential areas of violation. The NPS Inspector usu-
“zero” or “No response/Not applicable.”                  ally recommends actions and BMPs that may rectify
      In general, the tendency of respondents to not     the violation and promote compliance with pollu-
associate specific training and operational activities   tion-prevention objectives. The City of Santa Clara
with stormwater pollution prevention seemed re-
lated to their general unfamiliarity with the City’s
pollution-prevention program.
                                                                          Santa Clara Valley
                                                                          Urban Runoff
                                                                          Pollution Prevention Program


                                                                                                                9
     does not track the number of BMPs already installed        1. An evaluation of the effectiveness of the City of
     and maintained on-site. However, City inspectors              Santa Clara’s industrial stormwater pollution
     may review the operation and effectiveness of exist-          prevention efforts, based on the results of the
     ing BMPs during site inspections. When applicable,            indicators.
     the NPS Inspector may also ask to view manage-
                                                                2. An evaluation of the usefulness of the three
     ment plans and regulatory documentation such as
                                                                   indicators.
     spill response plans, the Notice of Intent, or the fa-
     cility’s stormwater pollution prevention plan.
                                                                Effectiveness of the City of Santa Clara’s
            Inspections of 23 businesses in the catchment
                                                                Industrial Pollution Prevention Efforts
     area were conducted by the Fire Department’s NPS
     Inspector between September 1998 and March                       No significant potential or actual sources of
     1999. Sixteen of the 23 (70%) were in compliance           stormwater pollution were found during our site
     with all stormwater pollution-prevention require-          visits.
     ments. The remaining seven facilities had violations             In the time since the 1993 pilot project, busi-
     relating to general housekeeping, outside storage of       nesses in the Walsh Avenue catchment increased
     equipment or raw material storage and washwater            their implementation of pollution-prevention BMPs.
     disposal. Appendix H summarizes documentation              Substantially more businesses were in compliance
     of recent industrial inspections.                          with pollution-prevention requirements in 1999 than
            In follow-up reinspections, two previously          in 1993.
     non-complying businesses remained in non-                        For the most part, we were unable to directly
     compliance. New violations were found at two               attribute these improvements to the City of Santa
     businesses that had been in compliance during the          Clara’s stormwater pollution prevention efforts. This
     previous inspection.                                       is because:
            Of the 32 businesses currently in the Walsh         ⇒ The City’s inspection records lacked detail.
     Avenue Catchment, 18 participated in the previous
     1993 Pilot Study. A comparison of the inspection           ⇒ Most of the City’s industrial stormwater inspec-
     data for these sites for the two periods (Appendix I)           tions were incorporated into inspections for
     indicates a marked increase in the proportion of                compliance with the City’s Fire Code and with
     sites in compliance with the City’s stormwater regu-            other environmental regulations (i.e. CUPA).
     lations. In two cases, some have never achieved                 Since many BMPs also serve the objectives of
     compliance and demonstrated repeat violations in                these other regulations (and improve workplace
     the same areas.                                                 safety and efficiency) we were unable to distin-
            The two metal plating/finishing facilities in the        guish which BMPs were implemented as a re-
     catchment are subject to the State’s General Indus-             sult of efforts specifically related to stormwater
     trial Permit and must submit a Notice of Intent                 pollution prevention outreach.
     (NOI). As a part of the General Permit process, a               Here’s what each indicator told us about the
     copy of the NOI, an Annual Report, and a Storm-            effectiveness of the City’s program:
     water Pollution Prevention Plan should be available.
     One of the facilities maintained a 1998 NOI, but           Indicator 18 − Industrial/Commercial
     their Annual Report and SWPPP were from 1995-              Pollution Prevention
     1996. The other facility was able to provide Annual              Application of this indicator showed that cost,
     Reports for the previous two years.                        work effort and site manager attitudes were not sig-
            These two facilities operate industrial waste       nificant barriers to the implementation of runoff
     treatment systems on-site and maintain a permit            pollution control measures in the Walsh Avenue
     from the San Jose/Santa Clara Water Pollution Con-         industrial catchment. Site managers would likely
     trol Plant (WPCP) to discharge the treated effluent        respond positively to more frequent targeted out-
     into the sanitary system. Staff based at the WPCP          reach by the City’s pollution-prevention program.
     inspects the treatment equipment and requires                    Ownership of some businesses, and City in-
     monitoring of effluent quality discharges.                 spection staff, changed between 1993 and 1999.
                        Conclusions                             Many site managers could not recall having been
                                                                inspected. Others recalled fire inspections, but did
          Two evaluations follow:                               not associate these with stormwater pollution pre-
10
vention. Managers of recently inspected sites did not      regulations and with other (non-stormwater) envi-
retain a lasting impression of the City’s concerns         ronmental regulations.
regarding runoff pollution.
      Most managers of sites in the Walsh Avenue           Recommendations for
catchment were unaware of the City’s stormwater            Continuous Improvement
pollution-prevention program and the objectives of              Based on the results of the three indicators, the
its Industrial Discharger Control Element. They            City of Santa Clara’s Industrial Discharger Control
were, however, generally receptive to pollution-           Element (IND) could be improved by:
prevention concerns.                                       ⇒ Clearly informing businesses of the intent and
      Most of the site managers did not self-monitor         focus of stormwater pollution-prevention in-
for potential sources of stormwater pollutants. Many         spections and conducting follow-up re-
said that the size and the type of business did not          inspections timely.
warrant dedicating many staff hours specifically to
storm water pollution prevention. However, a ma-           ⇒ Consistently documenting inspections in an
jority of the site managers said they were willing to        efficient record-keeping system. A relational
implement BMPs.                                              database is suggested to systematically organize
                                                             documentation by site visit, potential pollut-
Indicator 22                                                 ants, and best management practices.
BMPs Installed, Inspected and Maintained
                                                           ⇒ Providing inspectors with routine refresher
      Many of the sites in the Walsh Avenue catch-
                                                             training. Inspectors should receive updates on
ment implement BMPs, but did not link this imple-
                                                             Program activities and on new or revised
mentation to the City’s outreach and inspections.
                                                             BMPs. The inspectors should also be trained to
For example, many managers of commercial and
                                                             effectively communicate this information to
light industrial sites cited organization and efficiency
                                                             site managers during inspections.
as the reason for storing materials properly. Simi-
larly, parking lots and entranceways were swept to
                                                           Usefulness of Stormwater Environmental
maintain a pleasing appearance. BMPs at the more
                                                           Indicators
industrial sites were implemented to comply with
other environmental regulations, safety codes and
local fire codes and not necessarily to protect storm      Indicator 18
drains.                                                    Industrial/Commercial Pollution Prevention
      Most BMPs implemented at Walsh Avenue                      We found Indicator #18 useful. We attribute
businesses (with the exception of the plating facili-      this usefulness to the on-site visits. The written sur-
ties) are non-structural BMPs. Most of the commer-         veys alone would not have been as effective in de-
cial and light industrial businesses were implement-       termining the Program’s impact and the industries’
ing some appropriate housekeeping and material             understanding of the Program. However, the sur-
and waste storage BMPs. Additional BMPs are rec-           veys followed by the on-site visit provided a general
ommended for many of the businesses. See Appen-            assessment of the attitudes and level of understand-
dix G.                                                     ing of the individual site managers with respect to
                                                           the storm water program. The one-on-one visits
Indicator 26                                               helped initiate a dialogue and partnership between
Industrial Site Compliance Monitoring                      the City and industry. Site managers seemed to be
      Most business in the catchment were in com-          more comfortable with verbal communication rather
pliance with the City’s stormwater pollution-              than written, and more willing to ask questions and
prevention requirements. The sites that were in vio-       to provide detailed answers. Technical issues, such
lation had typical “poor housekeeping” and wash-           as potential pollutants or BMPs, were better re-
water disposal problems.
      The results of this indicator reinforce our con-
clusions from applying Indicator 18: Businesses are
                                                                             Santa Clara Valley
implementing BMPs for reason of general hygeine
                                                                             Urban Runoff
and efficient organization, and to comply with safety                        Pollution Prevention Program


                                                                                                                     11
     ceived and comprehended by the site manager when         the need for additional outreach, in connection with
     presented directly and in a friendly, casual manner.     site inspections, to insure that site managers imple-
                                                              ment and maintain stormwater BMPs.
           Program and City staff also found the site vis-          Application of the indicator also revealed the
     its useful. Through the site visits, SEIDP and City      need for follow-up inspections. As shown in Ap-
     staff gained familiarity with the facility operation     pendices H and I, successive inspections showed
     and staff, and of the conditions under which poten-      that several of the businesses remained in non-
     tial pollutants may occur. This enabled City and         compliance while others were inconsistently in
     SEIDP staff to better interpret the survey responses     compliance. Most violations were in repeated prob-
     and their validity. The Program’s deficiencies and       lem areas. Better documentation of inspections
     strengths were seen from industry’s point of view.       would make it possible for stormwater programs to
           Being able to determine the information and        use the indicator to target outreach and document
     outreach gaps between the Program and the industry       progress.
     validates the usefulness of the indicator. Data were
     insufficient to thoroughly analyze costs and benefits
     of BMPs, but by applying the indicator, we started       References
     the process of improved outreach and education           1 Claytor, Richard A. and Brown, Whitney E. Environ-

     needed to develop this information over the longer         mental Indicators to Assess Stormwater Control Pro-
     term.                                                      grams and Practices, Final Report, Center for Water-
                                                                shed Protection, July, 1996.
                                                              2 See SEIDP Technical Memorandum #1: Preliminary
     Indicator 22
                                                                Review and Program Assessment, Santa Clara Valley
     BMPs Installed, Inspected and Maintained                   Urban Runoff Pollution Prevention Program.
           Indicator 22 was not particularly useful as ap-    3 For a detailed analysis of permitting and compliance,
     plied in the Walsh Avenue catchment. The indicator         see the Technical Memorandum for Indicator #23.
     could be potentially useful under other circum-          4 Woodward-Clyde Consultants (August 1993). Walsh
     stances.                                                   Avenue Pilot Inspection Program Draft Report. Prepared for
           The City’s NPS inspectors do not routinely           the Santa Clara Nonpoint Source Control Program.
     document BMPs being implemented at the site.
     Without this documentation, (and without much
     documentation of previous industrial inspections), it
     was not possible to determine the number of BMPs
     installed, inspected and maintained.
           For the indicator to be useful, it would be nec-
     essary to link implementation of additional BMPs to
     specific efforts by the City. (The number and type of
     BMPs did correspond to the general nature of the
     facilities and the corresponding needs for pollution
     prevention.) Better documentation of inspections
     and of BMPs implemented could make this possi-
     ble.

     Indicator 26
     Industrial Site Compliance Monitoring
           This indicator was useful in gauging the effec-
     tiveness of the City’s industrial stormwater inspec-
     tion efforts. Compliance monitoring identified po-
     tential sources of stormwater pollutants and ways to
     prevent those pollutants from reaching storm drains.
     It was also an effective way to begin outreach to site
     managers.
           The compliance monitoring conducted by the
     Santa Clara in connection with this study revealed

12
Appendix A:
Appendix B:
                                                                                                           Appendix C
                                                                                                    Walsh Avenue Catchment
                                                                                                   Types of Industrial Facilities



         SITE ADDRESS                                                 PRIOR TO 1999                                                                                    1999

                                                      Facility Name                            Type of Business                                        Facility Name                       Type of Business

  601 Walsh Ave                    New West Industries                     Futon manufacturing                                      New Color Image                    Production of souvenir T-shirt and sweatshirt
                                                                                                                                                                       (screenings)
  621 Walsh                        Unknown                                                                                          Kapa Auto Body Shop                Storage & distribution of auto parts

  623 Walsh Ave                    Unknown                                                                                          Strong Steel                       Steel fabrication & erection

  625 Walsh                        Strong Steel                            Steel fabrication & erection                             Charles Moving & Storage           Additional storage for company
                                                                                                                                                                       (see 705 Walsh)

  627 Walsh                        Unknown                                                                                          Phantom Furniture                  Office furniture assembly

  630 Walsh Ave                    Haros Anodizing                         Protective coating of aluminum                           Haros Anodizing                    Protective coating of aluminum
                                   Specialist, Inc. 1                                                                               Specialist, Inc. 1
  631 Walsh Ave                    Sunshine Leasing Company                Storage and rental of trucks.                            La-Z-Boy Furniture Galleries       Retail furniture storage and sales

                                   Rainbow Express                         Freight loading and storage

  660 Walsh Ave                    Diasonics Ultrasound                    Unknown                                                  Diasonics Ultrasound               Company's storage warehouse

  661 Walsh Ave                    Adventure Palace & Stadium              Recreational games facility (paintball)                  Facilities Logistic Services       Office & industrial moving and storage

                                   Woodstalk Face Mask                     Unknown

  664 Walsh Ave                    Phoenix Fasterners, Inc.                Distributor of screws, bolts, nuts                       GLR Fasteners, Inc                 Distributor of screws, bolts, nuts

  668 Walsh Ave                    Atlas Manufacturing & Supply Co.        Conveyor belt manufacturing and repair                   Calif. State AAA                   Tow service

  672 Walsh Ave                    A & B Painting West                     Commercial painting contractor                           A & B Painting West                Commercial painting contractor

  676 Walsh                        Tron Precision Machine, Inc.            Machine repair                                           Xontech Inc.                       Electronic assembly of radar equipment

  680 Walsh                        D.J. Ommert's Manufacturing             Welding shop

  684 Walsh Ave                    Sprinkler Irrigation Specialists        Sale & storage of piping and                             Townhouse Square Warehouse         Storage
                                                                           plumbing equipment
  688 Walsh Ave                    La-Z-Boy Furniture                      Retail furniture storage and sales                       ACI Auto Glass                     Storage & distribution of auto glass

                                   Martinez UPH                            Unknown

  691 Walsh Ave                    A-1 Broom and Supply                    Janitorial supply warehouse                              R.A. Enterprises                   Sell old & new equipment




SC19/SC19-05/Memo/Tableswalsh_bustypes                                                                            1 of 2
                                                                                                                     Appendix C
                                                                                                              Walsh Avenue Catchment
                                                                                                             Types of Industrial Facilities



         SITE ADDRESS                                                         PRIOR TO 1999                                                                                          1999

                                                       Facility Name                                     Type of Business                                      Facility Name                              Type of Business

  696 Walsh Ave                    Penhall, Inc. 1                                  Concrete sawcutting, core drilling                        Penhall, Inc.                          Concrete sawcutting, core drilling

  705 Walsh Ave                    Charles Moving & Storage                         Moving company and storage                                Charles Moving & Storage               Moving company and storage

  711 Walsh Ave                    Mission Door                                     Manufacture wooden doors                                  Mission Door                           Manufacture wooden doors

  750 Walsh Ave                    ACI Glass                                        Wholesale distributor of glass                            ACI Glass                              Wholesale distributor of glass

  785 Walsh Ave                    Western Way Landscape                            Landscape contractor                                      Western Way Landscape                  Landscape contractor
                                   (Hydro Tec)                                                                                                (Hydro Tec)
  810 Walsh Ave                    Curtis Manufacturing                             Wooden furniture production                               Curtis Manufacturing                   Wooden furniture production

  810 Walsh Ave                    Iberti Door Co.                                  Production of wooden doors                                Eaton Door                             Cut wood for construction

  850 Walsh Ave                    Western Surplus Liquidators                      Unknown                                                   Buy & Sell Used Furnitures             Refurbish office panel systems
                                                                                                                                              (same ownership; different business)
  860 Walsh                        Unknown                                          Warehouse?                                                Lyric Theater                          Fabricate theatrical sets

  870 Walsh Ave                    National Smelting Refining, Inc. 1               Precious metal reclamation                                Gold Technology                        Fabricate high tech chips

  880 Walsh Ave                    Dr. Daily Corporation                            Storage of electronic parts                               A-1 Plating 1                          Metal finishing/ zinc plating

  890 Walsh Ave                    Musson Theatrical                                Sell & rent theatrical lighting                           Musson Theatrical                      Sell & rent theatrical lighting

  2605 Lafayette Ave               T.L. Broderick                                   Unknown                                                   A-1 Plating 1                          Metal finishing/ zinc plating

  2655 Lafayette Ave                A-1 Plating 1                                   Metal finishing/ zinc plating                             A-1 Plating 1                          Metal finishing/ zinc plating

  2705 Lafayette Ave               Motion Industries                                Distributor of industrial parts                           Motion Industries                      Distributor of industrial parts

  2707 Lafayette Ave               GM Mini Truck 1                                  Automotive dismantling and storage                        Owned by Minton Lumber                 Warehouse storage lumber company

  2715 Lafayette Ave.              Turf & Industrial Equipt. Co.                    Repair & sell garden vehicles/eqpt                        Turf & Industrial Equipment Co.        Repair & sell garden vehicles/eqpt

  2725 Lafayette Ave               S.C. Windustrial Co.                             Sale & storage of piping and                              South Bay Truck Center                 Truck & equipment repair and sales
                                                                                    plumbing equipment
  2765 Lafayette Ave               ACI Glass                                        Glass fabrication and distribution                        ACI Glass                              Glass fabrication and distribution


                            Notes
                                1 Covered under State's Industrial General Permit (NOI)




SC19/SC19-05/Memo/Tableswalsh_bustypes                                                                                      2 of 2
Appendix D:
                                       APPENDIX E
                    Santa Clara Valley Urban Pollution Prevention Program
                                      City of Santa Clara

                                Survey for Industrial Businesses


To: Facility Manager

The main objective of the Santa Clara Valley Urban Pollution Prevention Program (previously
known as the Non-Point Source Pollution Control Program) is to prevent runoff pollutants from
entering the storm drain system. With industrial businesses like yours, common everyday
practices can generate pollutants (such as washdown water, equipment fluids, chemicals), that
can potentially enter nearby storm drains during both dry and wet weather. Keep in mind that
pollutants can be carried into distant storm drains by heavy rainfall.

The City of Santa Clara’s Industrial Inspection Program, implemented by the City’s Fire
Department, performs periodic inspections of industrial sites and provides educational outreach
to facility managers. Industrial inspectors (also known as Non-Point Source Inspectors) may
recommend best management practices, and assist the facility manager in implementing these
practices. Best Management Practices (BMPs) are practices that prevent or reduce water
pollution.

The City of Santa Clara is studying the effectiveness of its Industrial Inspection Program. Your
comments to this survey will help us improve our inspection program and provide better
assistance to you in complying with state and local regulations. Thank you for your time and
assistance.




                                                           Date

ABOUT YOUR BUSINESS

1. Name and Address of Company


2. Name and Title of Person Completing Survey


3. Name of Owner

4. Type of Business

5. How long has the business been at this location?
                                                  Name of Business


6. How long has the business been under its current ownership?

7. Has your business filed a Notice of Intent (NOI) under the State Industrial Activities Storm
   Water General Permit?        Yes             No            Not applicable

     If YES, is a Storm Water Pollution Prevention Plan (SWPPP) readily available on-site?
                                  Yes            No

     IF YES, please provide a copy of the most recent Annual Monitoring report.


STORMWATER POLLUTION PREVENTION PROGRAM

1. Have you ever heard of the Santa Clara Valley Urban Runoff Pollution Prevention Program,
   or Non-Point Source Program?
                               Yes            No

2. Have you ever received any brochures or flyers on stormwater pollution prevention such as
   the Best Management Practices for Industrial Storm Water Pollution Control booklet?
                               Yes            No

3. Where did you learn about the Santa Clara Valley Urban Pollution Prevention Program?
   (Check all that apply.)

            during my industrial inspection              from ads in the newspaper

            through flyers received in the mail          community events

            I never heard of the Program before          Other
            today.




4. Have you have ever attended or have been invited to attend a workshop or training
   session on: (Check all that apply.)

            Stormwater Pollution Prevention. When?

            Industrial Inspections. When?

            Industrial Permitting. When?

            I never received any notice of a workshop or training.




Survey for Industrial Businesses                                                      Page 2 of 4
F:\SC19\SC19-05\Surveys\sitesurvey.doc 2/8/99
                                                     Name of Business


INSPECTIONS

1. How many times has your business been inspected by a Non-Point Source (NPS) Inspector
   in the last seven years?

2. When was the last time your business was inspected?

3. Do you recall any violations found during your last inspection?




4. What BMPs were recommended by the Inspector?




5. Was the Inspector helpful in implementing these BMPs?                      Yes              No

6. Do you perform self-inspections of your site for potential stormwater violations?

                                      Yes       No            How often?


BEST MANAGEMENT PRACTICES

1. Can you and your employees identify the locations of all storm drains and catch basins in or
   near your business?                Yes             No

2. How does your business currently protect nearby catch basins and storm drains? Indicate
   the types of structural and non-structural BMPs present at the site 1. (Check all that apply)

             Perform daily cleanup and sweeping of             Develop a spill response plan.
             indoor and outdoor work areas.
            Properly store paints, chemicals and               Properly store raw materials, products
            solvents (double containment).                     and by-products.
            Properly dispose process residues (saw              Minimize the use of wash water when
            dust, metal scraps, fluids).                        cleaning equipment and vehicles.
            Ensure indoor floor drains and sinks                Divert all generated flows into the
             are hooked up to the sanitary sewer.               sanitary sewer.
            Train employees on stormwater                      Regularly remove trash and debris
            pollution and BMPs.                                from outdoor areas (parking lots).
            Place covers on storm drains and                   Install inlet filters in the storm drain
            catch basins.
            Other




Survey for Industrial Businesses                                                               Page 3 of 4
F:\SC19\SC19-05\Surveys\sitesurvey.doc 2/8/99
                                                Name of Business



3. How much did it cost to implement the BMPs at your site? (include permit fees, construction
   costs and training)?

4. How much time is spent by you and your employees in implementing BMPs for stormwater
   pollution prevention?

5. Do you feel that BMPs are effective in preventing pollutants from entering the storm drain?

                Yes                   No


COMMENTS AND SUGGESTIONS




1
  The BMPs listed in this survey represent the common BMPs typically associated with industrial
sites. Best Management Practices are numerous and are dependent on specific site conditions,
the presence of potential pollutants and the vicinity of the storm drain system and other
sensitive areas.




Survey for Industrial Businesses                                                    Page 4 of 4
F:\SC19\SC19-05\Surveys\sitesurvey.doc 2/8/99
                                                                                        Appendix F
                                                                          Walsh Avenue Catchment Survey Responses

                           Survey Items                                        No. of                                    Survey Items                             No. of
                                                                              Responses                                                                          Responses

No. of Businesses in Catchment                                                    32            Cost of Implementing BMPs
                                                                                                                                                            $0      11
                                                                                                                                                         $1000       1
No. of Surveys Completed                                                          27                                                                     $5000       1
                                                                                                                                                       $10,000       1
No. of Businesses under State Industrial General Permit                           2                                                      $100 - $400 per month       1
                                                                                                                                                      Unknown        3
Knowledge of SCVURPPP from:                                                                                                                          As needed       1
                                              Industrial inspections              12                                                No response/Not applicable       8
                                                Flyers or brochures                8
                                          Newspaper advertisements                 2            Time Required to Implement BMPs
                                                 Community events                  0                                                                         0      7
                                      City workshop/training events                0                                                           10 minutes/day       1
                                              None (before survey)                12                                                                1 hour/day      3
                                                                                                                                                 5 hours/week       1
Recollection of No. of Inspections                                                                                                              16 hours/week       1
Received in the Last 7 years                                                                                                                    1 hour/ month       3
                                                               None               12                                                                 As needed      1
                                                                  1                7                                                                 Unknown        2
                                                                  2                6                                                No response/Not applicable      8
                                                            Unknown                2
                                                                                                Do you perform self-inspections of your site?
BMPs Implemented                                                                                                                                          Yes       16
                        Locate nearby storm drains & catch basins                 10                                                                       No        7
                          Routinely clean and sweep of work areas                 21                                                No response/Not applicable       4
                     Properly store paints, chemicals, solvents, etc.             12
                              Properly dispose of process residues                18            Are BMPs effective in preventing contaminants from entering
      Ensure sinks and floor drains are plumbed to sanitary system                 6            the storm drain?
                      Divert all generated flows to sanitary system                6                                                                     Yes        18
                       Train staff stormwater pollution and BMPs                   9                                                                      No         0
                                                                                                                                   No response/Not applicable        9
                                        Develop spill response plan                5
            Properly store raw materials, products and by-product                 15
                                       Minimize use of wash water                 14
           Routinely remove trash and debris from outdoor areas                   19
                                   Install inlet filters in storm drain            1
                                 Place covers on storm drain inlets                1
                                                                 Other             2




F:\SC19\SC19-05\MEMO\Tables\surveyresults_formatted.doc                                                                         8/16/99
                                                                                                               Appendix G
                                                                                                         Walsh Avenue Catchment
                                                                                                Findings From Recent Surveys and Site Visits


     SITE ADDRESS                        FACILITY NAME           TYPE OF BUSINESS                                      POTENTIAL POLLUTANS                        BMPs APPLIED            BMPs SHOULD BE APPLIED             COMMENTS

601 Walsh Ave                 New Color Image                    Production of T-shirts, sweatshirts      plastisol (decals);        chemicals;              indoor operation             housekeeping;
                                                                 (screenings)                             cardboard;                 used rags;                                           train employees;
                                                                                                                                                                                          chemical storage
621 Walsh                     Kapa Auto Body Shop                Storage & distribution of auto parts     parking lot debris;        garbage bin;            indoor operation             dry sweep lot;
                                                                                                          empty boxes;                                                                    housekeeping;
                                                                                                                                                                                          cover garbage bin;
623 Walsh Ave                 Strong Steel                       Steel fabrication & erection             paint;                     metal byproducts        chemcial storage;
                                                                                                          laquer thinner             vehicle fluids          train employees;
                                                                                                                                                             housekeeping
625 Walsh Ave                 Charles Moving & Storage           Additional storage for company           debris;                    trash                                                equipment storage; train
                                                                 (see 705 Walsh)                          metal products                                                                  employees; housekeeping
627 Walsh                     Phantom (Furniture)                Office furniture manufacturing           sawdust                    surface cleaner         housekeeping;                train employees
                                                                                                                                                             indoor operation

630 Walsh Ave                 Haros Anodizing Specialist, Inc.   Protective coating of aluminum           treatment sludge;          industrial WWTP on-site housekeeping;                train employees; need updated   NOI
                                                                                                          chemicals;                                         dry sweep lot                SWPPP; spill response plan

631 Walsh Ave                 La-Z-Boy Furniture Galleries       Furniture retail (store/distribute)      parking lot debris;        old furniture           indoor operation             dry sweep lot
                                                                                                          empty boxes;
660 Walsh Ave                 Diasonics Ultrasound               Warehouse storage for firm                                                                                                                               Not inspected
661 Walsh Ave                 Facilities Logistic Services       Office & industrial moving and           none
                                                                 storage
664 Walsh Ave                 GLR Fasteners, Inc                 Distributor of screws, bolts, nuts, etc. none

668 Walsh Ave                 Calif. State AAA                   Tow service                              windshield wiper fluid                             train employees
                                                                                                          (no maintenance on site)
672 Walsh Ave                 A & B Painting                     Painting contractor                      paint ;                    empty paint cans;       spill response plan;
                                                                                                          laquer thinner;            paint waste;            spill kit available; storm
                                                                                                                                                             drains labeled;
                                                                                                                                                             housekeeping
676 & 680 Walsh               Xontech Inc.                       Electronic assembly - radar eqpt.        transformer oil                                    indoor operation;            train employees
                                                                                                                                                             oil containment
684 Walsh Ave                 Townhouse Square Warehouse         Storage                                                                                                                                                  Not inspected
688 Walsh Ave                 ACI Auto Glass                     Storage & distribution of auto glass     Packing material; Parking                          Indoor operation;
                                                                                                          lot debris                                         daily housekeeping
691 Walsh Ave                 R.A. Enterprises                   Sell old & new equipment                 Vehicle fluids;           Debris from dumpster                                  Housekeeping;
                                                                                                          Outdoor storage of eqpt;                                                        train employees:
                                                                                                                                                                                          Sweep near dumpster;
                                                                                                                                                                                          Proper material storage
696 Walsh Ave                 Penhall, Inc.                      Concrete sawcutting, core drilling       Brake fluids (maint. on    washwater ;             fluid containment;         Train employees; need spill
                                                                                                          site);                     vehicle storage         wash pad to sanitary sewer response plan; housekeeping
                                                                                                          oil petroleum;
                                                                                                          concrete debris;
705 Walsh Ave                 Charles Moving & Storage           Moving company and storage               washwater ;                parking lot debris;                                  Housekeeping; train employees
                                                                                                          outside storage;




  SC19\19-05\Memo\table\walsh_survey
                                                                                                             Appendix G
                                                                                                       Walsh Avenue Catchment
                                                                                              Findings From Recent Surveys and Site Visits


      SITE ADDRESS                     FACILITY NAME              TYPE OF BUSINESS                                   POTENTIAL POLLUTANS                          BMPs APPLIED          BMPs SHOULD BE APPLIED                   COMMENTS

711 Walsh Ave                 Mission Door                        Manufacture wooden doors              sawdust;                    parking lot debris                                  Daily housekeeping; dry sweep
                                                                                                                                                                                        lot; control outside litter
750 Walsh Ave                 ACI Glass                           Wholesale distributor of glass        packing material ;          broken glass;             Good housekeeping                                               GW remediation for
                                                                                                                                                                                                                              outdoor fuel tanks
785 Walsh Ave                 Hydro Tec (Western Way Landscape)   Landscape contractor                  fuel refuse;                fertilzer; pesticides     covered chemical storage; Cover manure/dirt stored in
                                                                                                        equipment fluids;                                     indoor repair shop;       stables;
                                                                                                                                                              paints stored indoors     Minimize washwater; clean out
                                                                                                                                                                                        storm drains; Housekeeping

810 Walsh Ave                 Curtis Manufacturing                Wooden furniture maker                sawdus; paints; thinners;   used rags;                                          Dry sweep shop; Train
                                                                                                                                     lacquers                                           employees; Develop
                                                                                                                                                                                        spill/hazwaste plan
810 Walsh Ave                 Eaton Door                          Cut wood for construction             sawdust;                    litter in lot;                                      Daily housekeeping; dry sweep
                                                                                                        drum storage;               equipment fluid                                     lot; control outside litter; remove
                                                                                                                                                                                        chemical drums
850 Walsh Ave                 Buy & Sell Used Furnitures          Refurbish office panel systems        fabric glue;                some paint                indoor operation;
                                                                                                        cleaning products;                                    housekeeping; proper
                                                                                                                                                              storage
860 Walsh                     Lyric Theater                       Fabricate theatrical sets             none                                                  indoor operation
870 Walsh Ave                 Gold Technology                     Fabricate high tech chips             machine coolant                                       indoor operation
880 Walsh Ave                 A-1 Plating                         Metal finishing/ zinc plating         industrial waste;           hazardous chemicals;      Good housekeeping; train Need updated SWPPP and spill NOI
                                                                                                         metal sludge               industrial WWTP           employees                response plan
890 Walsh Ave                 Musson Theatrical                   Sell & rent theatrical lighting       None
2605 Lafayette Ave            A-1 Plating                         see 880 Walsh
2655 Lafayette Ave            A-1 Plating                         see 880 Walsh
2705 Lafayette Ave            Motion Industries                   Distributor of industrial parts       parking lot debris;                                   Minimize washwater;
                                                                                                        washwater                                             sweep lot
2707 Lafayette Ave            Owned by Mitton Lumber              Warehouse storage lumber company
2715 Lafayette Ave.           Turf & Industrial Equipment Co.     Repair & sell garden vehicles/eqpt    battery acid;               washwater; vehicle        Washwater into sewer;     Inspect vehicles parked outside
                                                                                                        fuel;                       storage; old batteries    storage of oils indoors
                                                                                                        oil;
2725 Lafayette Ave            South Bay Truck Center              Truck & Equipment repair and sales    battery acid fuel, oil,     washwater; vehicle        Indoor operation; proper Drip pans for vehicles;
                                                                                                                                    storage; old batteries;   storage of oils          train employees
2765 Lafayette Ave            ACI Glass                           Glass fabrication and distribution    packing material; broken    parking lot debris                                 Housekeeping; sweep lots daily
                                                                                                        glass




  SC19\19-05\Memo\table\walsh_survey
                                                                                                 Appendix H
                                                                                         Walsh Avenue Catchment
                                                                             Recent Industrial Inspections of Existing Businesses


                       ADDRESS                    FACILITY NAME                                                         INDUSTRIAL INSPECTIONS

                                                                             Date          Compliance            Violations/Problems (a)                       Comments                          BMPs (b)
                                                                                                                                                                                                  Given

            601 Walsh Ave                New Color Image                  24-Sep-98            Yes                                         All work done indoors. Provide training to              b1
                                                                                                                                           employees.
            621 Walsh                    Kapa Auto Body Shop               8-Mar-99            No                  a9                                                                              b1

            623 Walsh                    Strong Steel                      6-Dec-96                                                        Illegal discharge (paint & metal waste). Cease &        b1
                                                                                                                                           desist letter to owner
                                                                          17-Nov-98            No                  a2               a11    Reinspection necessary                                  b1
                                                                                                                   a6               a12
            625 Walsh Ave                Charles Moving & Storage         10-Mar-99            No                  a7                      warehouse storage for business
                                                                                                                   a9
            627 Walsh                    Phantom (Furniture)              17-Nov-98            No                  a8                      Reinspection necessary.                                 b1
                                                                                                                   a9                      Need BMPs in other languages.
            630 Walsh Ave                Haros Anodizing                  4-Nov-98             Yes                                                                                                 b1
                                         Specialist, Inc.
            631 Walsh Ave                La-Z-Boy Showcase                5-Nov-98             Yes

            660 Walsh Ave                Diasonics, Ultrasound, Inc.    No inspection

            661 Walsh Ave                Facilities Logistic Services   No inspection

            664 Walsh Ave                GLR Fasteners, Inc               4-Nov-98             Yes                                                                                                 b1

            668 Walsh Ave                California AAA                 No inspection                                                                                                              b1

            672 Walsh Ave                A & B Painting                   20-Mar-96                                                        Illegal discharge (paint). Cease & desist letter to
                                                                                                                                           owner.
                                                                           2-Dec-98            Yes                                                                                                 b1

            676 Walsh Ave                Xontech, Inc.                    20-Nov-98            Yes
            680 Walsh Ave
            684 Walsh Ave                Townhouse Square Warehouse     No inspection
            688 Walsh Ave                ACI Auto Glass                   2-Dec-98             Yes                                                                                                 b1

            691 Walsh Ave                R.A. Enterprises                 5-Nov-98             Yes                                         Wholesale computer warehouse

            696 Walsh Ave                Penhall, Inc.                    12-Sep-97                                                        Sawcut slurry discharge. Penhall provided
                                                                                                                                           corrective action and training to staff.
                                                                           2-Dec-98            Yes                                         Recommended use dry methods for cleaning                b1
                                                                                                                                           spills
                                                                           1-Mar-99            No                  a5
                                                                                                                  a13




SC19/SC19-05/Memo/Tables/inspections99                                                               1 of 3                                                                                                 2/22/2000
                                                                                                Appendix H
                                                                                        Walsh Avenue Catchment
                                                                            Recent Industrial Inspections of Existing Businesses


                       ADDRESS                   FACILITY NAME                                                           INDUSTRIAL INSPECTIONS

                                                                            Date            Compliance            Violations/Problems (a)                       Comments                       BMPs (b)
                                                                                                                                                                                                Given
            705 Walsh Ave                Charles Moving & Storage         2-Dec-98                 Yes                                      Recommend controlling litter near dock area.

                                                                          8-Mar-99                 No               a2              a4                                                           b1
                                                                                                                    a3
            711 Walsh Ave                Mission Door                     2-Dec-98                 Yes                                      Recommend sweep sawdust daily.
                                                                                                                                            Control litter outside dock area.
            750 Walsh Ave                ACI Glass                       5-Nov-98                  Yes

            785 Walsh Ave                Western Way Landscape           5-Nov-98                  No               a4                      Reinspection necessary
                                         (Hydro Tec)
                                                                          2-Mar-99                 No               a2               a9     Reinspection necessary
                                                                                                                    a4              a13
                                                                                                                    a8
            810 Walsh Ave                Curtis Manufacturing             2-Dec-98                 Yes                                                                                           b1

            810 Walsh Ave                Eaton Door                       2-Dec-98                 No               a2              a7      Reinspection necessary                               b1
                                                                                                                    a5
                                                                         10-Mar-99                 No               a2                      Reinspection necessary
                                                                                                                    a5
            850 Walsh Ave                Buy & Sell Used Furnitures    No inspection

            870 Walsh                    Gold Technology               No inspection

            890 Walsh Ave                Musson Theatrical                3-Dec-98                 Yes                                                                                           b1

            880 Walsh Ave                A-1 Plating                   see 2605 & 2655 Lafayette

            2605 Lafayette Ave           A-1 Plating                     26-Nov-95                                                          Illegal discharge into parking lot

            2655 Lafayette Ave           A-1 Plating                     24-Mar-98                 No               a9                      Need to provide last year's sampling results and
                                                                                                                                            inspection report. Provide training to
                                                                                                                                            employees.
            2705 Lafayette Ave           Motion Industries             No inspection

            2707 Lafayette Ave           Warehouse for Mitton Lumber   No inspection
            2715 Lafayette Ave.          Turf & Industrial              20-Nov-98                  Yes                                      No inspection
                                         Equipment Co.
            2725 Lafayette Ave           South Bay Truck Center          20-Nov-98                 Yes

            2765 Lafayette Ave           ACI Glass                     No inspection                                                                                                             b1




SC19/SC19-05/Memo/Tables/inspections99                                                                   2 of 3                                                                                           2/22/2000
                                                                                                                   Appendix H
                                                                                                           Walsh Avenue Catchment
                                                                                               Recent Industrial Inspections of Existing Businesses


                       ADDRESS                          FACILITY NAME                                                                    INDUSTRIAL INSPECTIONS

                                                                                               Date               Compliance       Violations/Problems (a)                          Comments             BMPs (b)
                                                                                                                                                                                                          Given
            NOTES
            (a). Problem Areas (Violations)
                                               Outdoor Activities                                                                              Indoor Activities
                                         a1.   Vehicle and equipment fueling (tank farm)                                                  a10. Equipment cleaning wastewater improperly disposed
                                         a2.   Vehicle and equipment washing                                                              a11. Manufactured residues, spills, leaks improperly cleaned
                                         a3.   Vehicle and equipment maintenance and repair
                                         a4.   Storage and handling of raw materials, prducts and by-products                                    Equipment
                                         a5.   Waste staorage, handling and disposal (Hazardous materials)                                a12.   Air Compressors
                                         a6.   Pavement cleaning or power washing (steam)                                                 a13.   Catch basin/Drop inlet condition
                                         a7.   Scrap yards/Equipment/Vehicle storage                                                      a14.   Floor sinks/drains
                                         a8.   Process residues                                                                           a15.   Roof (vent/other roof equipment)
                                         a9.   General housekeeping

            (b) BMPs
                                         b1.   Best Management Practices for Industrial Storm Water Pollution Control
                                         b2.   Your Shop Can Make a Difference (Automotive BMPs)
                                         b3.   Blueprint for a Clean Bay (Construction BMPs)
                                         b4.   The Bay Begins At Your Front Door




SC19/SC19-05/Memo/Tables/inspections99                                                                                    3 of 3                                                                                    2/22/2000
                                                                                                        Appendix I
                                                                                                 Walsh Avenue Catchment
                                                                                      Comparison of Industrial Inspections 1993 and 1998



                             ADDRESS                      FACILITY NAME                                                    CITY'S INDUSTRIAL INSPECTIONS

                                                                                     Date          Compliance            Violations/Problems (a)                       Comments                          BMPs (b)
                                                                                                                                                                                                          Given

                  623 Walsh                       Strong Steel                     6-Dec-96                                                        Illegal discharge (paint & metal waste). Cease &        b1
                                                                                                                                                   desist letter to owner
                                                                                  17-Nov-98            No                  a2              a11     Reinspection necessary                                  b1
                                                                                                                           a6              a12
                  630 Walsh Ave                   Haros Anodizing                  6-Aug-92            No                  a3              a14                                                             b1
                                                  Specialist, Inc.                                                         a9
                                                                                   2-Mar-93            No                  a3              a4      Reinspection necessary                                  b1
                                                                                                                           a9
                                                                                  4-Nov-98             Yes                                                                                                 b1

                  688 Walsh Ave                   La-Z-Boy Showcase               12-Feb-93                                                        Inspection notice letter sent to owner

                  631 Walsh Ave                                                    3-Mar-93            Yes                                         No reinspection required.
                  new location
                                                                                  5-Nov-98             Yes

                  660 Walsh Ave                   Diasonics, Ultrasound, Inc.   No inspection

                  664 Walsh Ave                   Phoenix Fasteners, Inc.          5-Aug-92            Yes                                         No reinspection required.                               b1

                                                  GLR Fasteners, Inc              4-Nov-98             Yes                                                                                                 b1
                                                  (changed ownership)
                  672 Walsh Ave                   A & B Painting                   6-Aug-92            No                  a5                      Reinspection necessary                                 b1, b3
                                                                                                                          a12
                                                                                   8-Feb-93            No                  a5                      Inspected storage area. Requested development
                                                                                                                                                   of spill response plan
                                                                                   2-Mar-93            No                  a5              a9      Reinspection necessary
                                                                                                                          a12
                                                                                   4-Mar-93                                                        Response letter from owner.

                                                                                  17-Mar-93                                                        Reinspection. Requirements satisfied.

                                                                                  20-Mar-96                                                        Illegal discharge (paint). Cease & desist letter to
                                                                                                                                                   owner.
                                                                                   2-Dec-98            Yes                                                                                                 b1




SC19\SC19-05\Memo\table\inspections92-99\Sheet1                                                              1 of 3                                                                                                 2/22/2000
                                                                                                      Appendix I
                                                                                               Walsh Avenue Catchment
                                                                                    Comparison of Industrial Inspections 1993 and 1998



                             ADDRESS                       FACILITY NAME                                                 CITY'S INDUSTRIAL INSPECTIONS

                                                                                  Date            Compliance           Violations/Problems (a)                     Comments                        BMPs (b)
                                                                                                                                                                                                    Given
                  696 Walsh Ave                   Penhall, Inc.                 6-Aug-92              No                 a2              a4      Reinspection necessary
                                                                                                                         a3              a6
                                                                               25-Feb-93              No                 a2              a9
                                                                                                                                         a4      Reinspection necessary
                                                                                                                         a3              a9
                                                                                1-Mar-99              No                 a5
                                                                                                                        a13
                  705 Walsh Ave                   Charles Moving & Storage   No previous inspection

                                                                                2-Dec-98              Yes                                        Recommend controlling litter near dock area.

                                                                                8-Mar-99              No                 a2              a4                                                          b1
                                                                                                                         a3
                  711 Walsh Ave                   Mission Door               No previous inspection

                                                                                2-Dec-98              Yes                                        Recommend sweep sawdust daily.
                                                                                                                                                 Control litter outside dock area.
                  750 Walsh Ave                   ACI Glass                    12-Aug-92              No                 a1              a12     No reinspection required.                           b1
                                                                                                                         a5
                                                                                3-Mar-93              No                 a1                      No reinspection required.

                                                                               15-Nov-93                                                         Request for approval of new sewer connection to
                                                                                                                                                 storm drain (allowed under NPDES Permit 91-
                                                                                                                                                 056).
                                                                                5-Nov-98              Yes

                  785 Walsh Ave                   Western Way Landscape        12-Aug-92              No                 a4              a10     Reinspection necessary                              b1
                                                  (Hydro Tec)                                                            a5              a12
                                                                               25-Feb-93              No                 a5              a12     Reinspection necessary
                                                                                                                         a9
                                                                                5-Nov-98              No                 a4                      Reinspection necessary

                                                                                2-Mar-99              No                 a2               a9     Reinspection necessary
                                                                                                                         a4              a13
                  810 Walsh Ave                   Curtis Manufacturing         12-Aug-92              No                 a8
                                                                                                                         a9              a12     Reinspection necessary
                                                                                                                         a8
                                                                                2-Dec-98              Yes                                                                                            b1

                  890 Walsh Ave                   Musson Theatrical            19-Aug-92              No                 a9                      Reinspection recommended.
                                                                                                                        a11
                                                                                3-Dec-98              Yes                                                                                            b1




SC19\SC19-05\Memo\table\inspections92-99\Sheet1                                                             2 of 3                                                                                            2/22/2000
                                                                                                                             Appendix I
                                                                                                                      Walsh Avenue Catchment
                                                                                                           Comparison of Industrial Inspections 1993 and 1998



                             ADDRESS                              FACILITY NAME                                                                   CITY'S INDUSTRIAL INSPECTIONS

                                                                                                         Date                Compliance         Violations/Problems (a)                          Comments                        BMPs (b)
                                                                                                                                                                                                                                  Given
                  880 Walsh                             A-1 Plating                                   10-Aug-92                  No               a4               a15       Reinspection necessary                                b1
                  2605 Lafayette                        (single business occupying                                                                a5
                  2655 Lafayette Ave                    several parcels)                                                                          a9                         As per 3/4/93 inspection, no NOI or SWPPP
                                                                                                                                                                             has been completed.
                                                                                                       4-Mar-93                  No               a4                         Reinspection necessary
                                                                                                                                                 a15
                                                                                                      26-Nov-95                                                              Illegal discharge into parking lot

                                                                                                      24-Mar-98                  No               a9                         Need to provide last year's sampling results and
                                                                                                                                                                             inspection report. Provide training to employees.

                  2705 Lafayette Ave                    Motion Industries                          No inspection

                  2715 Lafayette Ave.                   Turf & Industrial                              3-Mar-93                  No               a2                a8       Reinspection necessary
                                                        Equipment Co.                                                                             a4                a9
                                                                                                                                                  a5
                                                                                                      20-Nov-98                  Yes                                         No inspection

                  2765 Lafayette Ave                    ACI Glass                                      3-Mar-93                  No               a9                         No reinspection required.                             b1
                                                                                                                                                 a12
                                                                                                   No recent inspection                                                                                                            b1



                  NOTES
                  (a). Problem Areas (Violations)
                                                        Outdoor Activities                                                                                  Indoor Activities
                                                  a1.   Vehicle and equipment fueling (tank farm)                                                      a10. Equipment cleaning wastewater improperly disposed
                                                  a2.   Vehicle and equipment washing                                                                  a11. Manufactured residues, spills, leaks improperly cleaned
                                                  a3.   Vehicle and equipment maintenance and repair
                                                  a4.   Storage and handling of raw materials, prducts and by-products                                        Equipment
                                                  a5.   Waste staorage, handling and disposal (Hazardous materials)                                    a12.   Air Compressors
                                                  a6.   Pavement cleaning or power washing (steam)                                                     a13.   Catch basin/Drop inlet condition
                                                  a7.   Scrap yards/Equipment/Vehicle storage                                                          a14.   Floor drain/sink
                                                  a8.   Process residues                                                                               a15.   Roof (vent/other roof equipment)
                                                  a9.   General housekeeping

                  (b) BMPs
                                                  b1.   Best Management Practices for Industrial Storm Water Pollution Control
                                                  b2.   Your Shop Can Make a Difference (Automotive BMPs)
                                                  b3.   Blueprint for a Clean Bay (Construction BMPs)
                                                  b4.   The Bay Begins At Your Front Door




SC19\SC19-05\Memo\table\inspections92-99\Sheet1                                                                                        3 of 3                                                                                               2/22/2000

				
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