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City of Stockton - 3 - 13 December 2000 Pretreatment Compliance Audit identifies potential new users was discussed. Presently, Pretreatment Program staff relies on the Municipal Utility Division, Permitting Center(where all building and Special Use Permits are issued) to identify new sources. The City's web page also provides information and application information for pretreatment permitting to potential users. These processes place the burden of determining if pretreatment regulations apply on the industrial user. As cited in Stockton's own Enforcement Response Plan (ERP), "...the Department lacks staff resources needed to mount a vigorous pursuit ofgeneral survey techniques for identifying new sources such as phone book review, newspapers, mailers, and drive-by-surveys." City staff essentially repeated this statement during the interview. Part 40 CFR 403.12(i)(1) requires the Control Authority to update its Industrial Waste Survey and report its findings annually. Review of the San Joaquin County Yellow Pages by Board staff prior to the PCA identified several categorical-type businesses, which were not identified in the annual Pretreatment Report. These businesses include: Cal-Tech Metal Finishers, Valley Plating, Gillis Plating and Custom Metal Finishing, all are metal plating companies; Valimet Inc., a metal powder company; G.B Industrial Spray and Stanley-Adams Machine Company, both metal spraying companies; and, Contech Paints and Velvacon-Pittsburgh Paints, both paint manufactures. Specifically, State inspectors inquired about Gillis Plating during the interview. The City stated that this company was small with limited and infrequent discharge and was not permitted through the program. The City indicated that regulating such a small facility would most likely put the owner out of business. It should be noted that this type of business is a CIU and as such must be included in the pretreatment program regardless of its size or quantity discharged. Issuance of permits is part of the implementation of a pretreatment program. Failure to issue enforceable permits is a violation of 40 CFR 403.8(f)(1)(iii). Board staff attempted to inspect this facility on 30 August 2000 and 13 September 2000; however, on both dates the facility was closed. Requirements: The City must develop and implement procedures that enable it to locate and process all existing and new IUs which might be subject to the Pretreatment Program according to 40 CFR403.8 09(2)(1). This requirement is achieved through an industrial user survey. The City must provide documentation of industrial user survey activities in its annual report as specified by Federal Requirements under 40 CFR 403.12(1)(1) and 403.12(1)(2). The City shall take appropriate actions to ensure that Gillis Plating and any other CIUs that discharge to the sewer be inspected and permitted as required. The City shall review and report the status of the other identified facilities listed above. SPECIAL USE PERMITS On 3 August 2000, of the Regional Board received an Office of Emergency Services (OES) Hazardous Material Spill Report regarding the discharge of a chlorine product, which had been dumped into a storm