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City of Stockton - 2 - 13 December 2000 Pretreatment Compliance Audit STAFFING LEVELS In January of 1999 the Regional Board conducted a PCI which determined that pretreatment staffing resources were insufficient to conduct an effective program. Staff found that the City had reduced the Environmental Control Officer (ECO) staff by another position in April 1998, the third staff to leave in 5 years. This left only two staff ECGs, a 60% reduction from the 5 ECO positions funded in 1993. Concurrently, the number of SNs had increased from 24 to 37, minor industrial users increased from 10 to 57, the population of Stockton increased from 196,000 to 239,500, and 43% of SNs were not in consistent compliance with pretreatment regulations. Also, the municipal stormwater program required periodic support by the ECGs diverting their time away from pretreatment activities. Since the January 1999 PCI, the number of SNs has increased from 37 to 40 while program resources have decreased further. Review of the 1998 and 1999 Annual Pretreatment Reports indicate that the total number of ECO staff hours was reduced from 4,680 hours in 1998 to 4,160 hours in 1999. Additionally, clerical staffing was reduced from 2184 hours in 1998 to 1144 hours in 1999. The Budget for the Pretreatment Program was reduced from$459,087 in 1998 to $403,708 in 1999. The additional reductions were not noticed to the Regional Board in accordance with 40 CFR 403.18 (d). And, as stated in the 1999 PCI,when these reductions are considered together, the overall affect to the pretreatment program is substantial. This Audit report documents various components of the Pretreatment Program that are in violation of the Order 94-324 and are indicative of inadequate staffing resources. These include: failure to update the list of industrial users through an adequate Industrial Waste Survey; failure to adequately monitor Special Use Permits; failure to follow up on enforcement actions; lack of resources to conduct compliance monitoring of hauled wastes; and, lack of adequate file maintenance. Each of these specific program components are discussed in greater detail within this Audit Report. The City is in violation of Order No. 94-324, Provision F.12.d, which requires the City to provide requisite funding and personnel to implement the program. Requirement: Additional staffing resources are required to effectively operate the program. The City must achieve compliance with Provision F.12.d of Order 94-324 which requires the Discharger to provide requisite funding and personnel to implement the program as provided in 40 CFR 403.80(3). City management mast consider the growing industrial base, which depends on use of the server system, and adequately staff the Pretreatment Program to meet this need. INDUSTRIAL USER/WASTE SURVEYS During the Audit, an initial interview with the Technical Service Supervisor, Senior ECO, and Regional Board and State Board staff(State inspectors) was conducted. The issue of how the City reviews and