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\s 1.J <br /> City of Stockton and County of San Joaquin Page 70 <br /> NPDES Permit CAS0083470 <br /> Response to Comments <br /> shall include,but not be limited to, auto body shops, auto dealers, dry cleaners, equipment rentals, <br /> nurseries,kennels, restaurants and caterers, and RGOs." The Tentative Order requires the facilities <br /> identified here to be inspected by the Permittees. As for the definition of"significant," our <br /> definition is consistent with the one provided by Webster's Dictionary. <br /> 39. Comment: (DK Comment 5(i)) SWMP Industrial/Commercial Program I I(b)(i)(a): DeltaKeeper <br /> believes that the frequency of inspections of significant sources should be increased, at a minimum, <br /> to three times during the life of the Permit and that the first inspection should be required no later <br /> than 1 July 2004. It is certainly technically and economically feasible to conduct more frequent <br /> inspections of significant sources of storm water pollution. <br /> Response: As with the construction site inspection requirements in the Tentative Order, the <br /> commercial/industrial facility inspection requirements are intended to balance the Regional Board's <br /> enforcement of the MEP standard with the Permittees' desire to optimize their facility inspection <br /> resources. The designated inspection frequency accounts for additional inspection demands such as <br /> conducting follow-up inspections for non-compliant sites, and responding to illicit discharge <br /> complaints. For this reason, no changes will be made to the Tentative Order's <br /> commercial/industrial facility inspection requirements at this time. <br /> 40. Comment: (DK Comment 50)) SWMP Industrial/Commercial Program I l(b)(ii): Facilities <br /> Requiring Coverage Under the General Industrial Permit: This seems to suggest that facilities that <br /> have been inspected by the Regional Board, within the past six months, do not need to be inspected <br /> during the life of the Permit. Please clarify. Regional Board inspections may take the place of one <br /> Permittee inspection, they should not eliminate the other required inspections during the life of the <br /> Permit. <br /> Response: We concur that Provision D.I l(b)(ii)poorly communicated our intent; we therefore <br /> revised the first paragraph as follows: <br /> "The Permittees shall conduct compliance inspections as specified below. For the purpose of <br /> meeting this requirement, the Permittees may consider any facility inspections conducted by <br /> Regional Board staff as equivalent to a Permittee inspection. Also, at sites owned or operated <br /> by the Permittees, self-monitoring inspections conducted in compliance with the General <br /> Industrial Permit shall be deemed to satisfy the inspection requirements of this section." <br /> 41. Comment: (DK Comment 5(k)) SWMP Industrial/Commercial Program 11(b)(ii)(a): The inspection <br /> schedule for facilities subject to the General Industrial Storm water Permit is clearly inadequate and <br /> does not meet MEP. Federally mandated facilities and those industrial facilities with SIC codes that <br /> are required to obtain coverage under the state General Industrial Storm water Permit, regardless of <br /> exposure, should be required to be inspected annually. We do not believe less frequent inspections <br /> would constitute MEP. These facilities have been found to be serious sources of storm water <br /> pollution throughout the nation. They include, but are not limited to: recycling(i.e., scrap metal, <br /> auto dismantling, etc.), fabricated metal products, motor freight (where refueling, vehicle <br /> maintenance or washing activities are conducted), chemical/allied products,primary metals <br />