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City of Stockton 8 - 13 December 2000 Pretreatment Compliance Audit Enforcement/Compliance Issues Quarterly and annual pretreatment reports demonstrate the City is carrying out enforcement of its users; however, State inspectors were unable to verify and follow the extent of compliance, violations, enforcement, and return to compliance from the file review. The lack of adequate documentation and inconsistent filing made it very difficult for State inspectors to review the City's ability to track user compliance. The lack of adequate documentation allows non-compliance issues to lapse without appropriate follow-up enforcement. An example of this lapse was found in the file for Viktron. Correspondence from the industrial user dated 24 May 2000 acknowledged a compliance schedule for submittal of a revised Slug Discharge Control Plan within 60 days. State inspectors could not identify correspondence from the City requiring the user to submit such a plan through a compliance schedule. The ECO responsible for this case could not locate the correspondence or a submitted plan either. There was no Notice of Violation or other correspondence by the City to the user indicating the plan had not been submitted. At the date of the PCA file review, the lack of plan submittal places the industrial user into significant non-compliance as defined by the City's own ERP. Requirement: The City must implement programmatic functions (40 CFR 403.8 (f) (2)) which includes enforcement action against Viktron for failure to submit a'Slug Discharge Plan by required due date. Recommendation: Consistent filing and enforcement tracking are essential to allow the City to more accurately track user compliance. As with the previous recommendation, documentation by the Pretreatment Program staff is crucial in tracking compliance of users to enforcement requirements. Careful evaluation by Pretreatment Program staff of an industrial user's response(or lack of response) to its violations is needed to determine if significant non-compliance is occurring. Pretreatment Program staff should periodically review the enforcement proceedings listed within the ERP, which describe how violations and noncompliance are to be dealt with. Documentation of Inspections and Compliance Monitorine Documentation and reporting of City inspections and compliance monitoring is inconsistent. State inspectors observed that the detail of the inspection reports varied from one ECO to another and there did not appear to be a consistent format for reporting the inspections. Annual inspection reports were found for each of the files reviewed, with exception of the Viktron facility. The Viktron folders labeled "Site Inspection, 1999 and 2000" did not contain an inspection report. Neither State Inspectors nor the responsible ECO could initially locate the annual inspection report for the Viktron facility. Discussion with the ECO determined that the inspection report was misdated as 1998 for the 1999 report and was located in the "Enforcement" folder.