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Foothill Landfill <br />Storm Water Pollution Prevention Plan <br /> <br /> <br /> <br />Page 55 <br />10.0 Annual Comprehensive Facility Compliance Evaluation (Annual <br />Evaluation) <br />Typically, during the month of May, an annual evaluation is performed at San Joaquin County <br />Foothill Landfill, in conjunction with preparation of the annual report. This comprehensive <br />evaluation consists of the following items: <br />10.1 Review of Observation and Inspection Records and Analytical Data <br />The storm water and non-storm water observation records, analytical data, and the annual <br />facility inspection record (conducted during the previous reporting year) are reviewed and <br />evaluated. The analytical data is evaluated by looking at historical trends. The current year’s <br />analytical data is compared to the NAL exceedance chart (General Permit, Table 2) and the <br />ELGs referenced on Table 7 in Section 7.1 to evaluate the effectiveness of the BMPs. The <br />analytical data is also compared with the observation records in an attempt to find clues and <br />identify possible causes for results that are out of the “benchmark levels” range. <br />10.2 Visual Inspection of Potential Pollutant Sources and the Drainage System <br />During the annual evaluation, a facility inspection is performed. All storm water drainage <br />systems and outfalls are inspected for non-storm water discharges and for signs of <br />contaminated discharge. Activities occurring in storm water drainage areas are inspected for <br />potential pollutant sources. The inspection also reviews all drainage areas previously identified <br />as having no exposure to industrial activities and materials. A record of the inspection findings <br />is prepared (Form 3), and any items needing attention are incorporated into the storm water <br />corrective action record for follow-up. <br />10.3 Review and Evaluation of the BMPs <br />During the facility inspection, the existing BMPs are inspected to ensure they are being <br />properly implemented and achieving their intended purpose. The BMPs are evaluated for <br />effectiveness based on the field inspection, discharge observation records, and analytical <br />results. Areas with no BMPs and areas with existing BMPs are reviewed and analyzed for the <br />need for initial or additional BMPs, respectively.