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HomeMy WebLinkAboutAGENDA REPORT 1996 0807 CC REG ITEM 10FTO: FROM: DATE: AGENDA REPORT CITY OF MOORPARK The Honorable City Council T =M 10F J Baldemar Troche, Public Works Management Analyst �5 June 7, 1996 (CC Meeting of 6- 19 -96) /s- SUBJECT: Consider Approval of Contracting with the Ventura County Flood Control District to perform Automobile Business Inspections The Federal Clean Water Act was amended in 1987 to require the Federal Environmental Protection Agency (EPA) to develop certain regulations -- which have become known as the National Pollution Discharge Elimination System (NPDES) -- designed to reduce the amount of pollution reaching the rivers and the ocean. As part of said program, all ten (10 ) cities within the County of Ventura, the County of Ventura and the Ventura County Flood Control District (VCFCD) obtained a single stormwater discharge permit which sets forth a number of programs designed to mitigate stormwater and related water discharges through public awareness of the problem. DISCUSSION 1. Clean Business Program One of the programs identified in the permit requires all of the above mentioned agencies to implement an educational outreach effort, instead of a regulatory approach with fines and permits, to the business community. The automotive service businesses have been selected for this program. The approach document which discusses this approach, including the inspections forms to be utilized and a listing of automotive businesses to be inspected, has been provided to City Council under separate cover. The objective of said document it to provide a free inspection in order to inform businesses of how stormwater pollution can be prevented by utilizing appropriate Best Management Practices (BMP's). No sanctions or fines will be imposed on businesses. To be in compliance with NPDES requirements, a total of 34 automotive businesses must be inspected within the City. If the educational outreach programs are not effective in controlling stormwater pollution in the manner Federal and State officials expect, staff anticipates the NPDES regulations may be amended and !Become more stringent (e.g. issuing of citations and fines for those businesses found to be in non - compliance). 000220 NPDES - Automotive Inspections Page 2 DISCUSSION (continued 2. Inspection A program is being established whereby VCFCD will contract with Ventura County Environmental Health Department (EHS), on an annual basis, to have inspectors perform the automobile business inspections. EHS inspectors are trained in the field of environmental health and as such, are experts in identifying problem areas. The clean business inspection checklist forms will be added to their normal work routine. VCFCD will administer said contract with EHS. Currently, five (5) cities (Camarillo, Fillmore, Ojai, Santa Paula, and Ventura) have agreed to take advantage of this opportunity. The cost for said service for these cities will be deducted from the municipal assessment levied by each city. Since the City of Moorpark has no such assessment, a purchase order in the estimated amount of $1,904 (34 x $56 per inspection) is required. An option to the above described contract would be to perform the inspections in- house. Since the areas to be inspected are located on private property, it is anticipated that the Code Enforcement Officer and /or Building Inspector could be assigned to perform the inspections. Unlike EHS inspectors, the City staff (including the contract Building Inspectors) are not currently knowledgeable in identifying problem areas addressed by the NPDES program. It would be necessary, therefore, to have this staff undergo training by an outside agency already accustomed to performing business inspections. As of the date of this report, staff is unaware if EHS will allow staff to ride -along and observe how these inspections should be performed. The costs anticipated to train staff, plus the time required to perform the inspections while performing ongoing regular duties, far exceeds the cost of contracting with VCFCD to have EHS inspect the automotive businesses. t�(�221 NPDES - Automotive Inspections Page 3 DISCUSSION (continued) 3. Evaluation The Regional Quality Control Board has been critical of the County permit and has requested that evaluation procedures be implemented to measure the effectiveness of educational outreach programs. Co- permittee's are currently discussing the methods to be utilized in the evaluation procedure and the type of programs that will be evaluated. Since the automotive service businesses will be inspected on an annual basis, measuring the effectiveness of this program will be relatively uncomplicated. The inspection reports will be compared each year to determine the quantity and type of stormwater pollution measures undertaken by each business. 4. Enforcement of NPDES Regulations To be in compliance with NPDES regulations, each city must have stringent regulations in -place that enforce compliance with NPDES requirements. Co- permittee's are currently drafting a boiler plate ordinance that will address these requirements. Staff anticipates that all the co- permittee's, including the City of Moorpark, will adopt this ordinance or develop a similar ordinance that addresses the specific needs of each agency. 5. Municipal Assessment Fee As you are aware, a number of co- permittee's fund their NPDES programs through the municipal assessment levied by each city. It is staff's intent to investigate and identify different revenue mechanisms that can be utilized to fund NPDES programs. The recommended revenue sources will be presented to City Council in conjunction with the adoption of a stormwater pollution prevention ordinance as discussed above. x+®222 NPDES - Automotive Inspections Page 4 DISCUSSION (continued) 6. Fiscal Impact Staff recommends funding for the inspections be charged to the stormwater management program (01.145.642). A summary of said program is shown below. *This amount was originally proposed as a contingency to retain a consultant to assist the Planning Department in amending and /or developing planning documents (e.g. general plan, zoning code, etc.) required in order to be in compliance with NPDES regulations. If a consultant is retained and the anticipated total cost exceeds $1,000, staff will prepare a budget amendment for City Council consideration. RECOMMENDATION Staff recommends that the City Council take the following actions: 1. Authorize the City Manager to sign documents necessary to retain the Ventura County Flood Control District to perform automobile business inspections through the County Environmental Health Department, required by the City's NPDES stormwater discharge permit; and 2. Authorize staff to issue a purchase order for said inspection services to be charged to the City's Stormwater Management Program expenses budgeted for FY 1996/97 (01.145.642). \npdes \bus_insp.rpt VWZ23 Draft Account Account Budget Proposed Description Number FY 1995 -96 Change FY 1996 -97 Professional 01.145.641 $5,000* ($2,000) $ 3,000 services Contract 01.145.642 $0 $2,000 2,000 Services Total $5,000 $ 0 $ 5,000 *This amount was originally proposed as a contingency to retain a consultant to assist the Planning Department in amending and /or developing planning documents (e.g. general plan, zoning code, etc.) required in order to be in compliance with NPDES regulations. If a consultant is retained and the anticipated total cost exceeds $1,000, staff will prepare a budget amendment for City Council consideration. RECOMMENDATION Staff recommends that the City Council take the following actions: 1. Authorize the City Manager to sign documents necessary to retain the Ventura County Flood Control District to perform automobile business inspections through the County Environmental Health Department, required by the City's NPDES stormwater discharge permit; and 2. Authorize staff to issue a purchase order for said inspection services to be charged to the City's Stormwater Management Program expenses budgeted for FY 1996/97 (01.145.642). \npdes \bus_insp.rpt VWZ23 MEMORANDUM TO: The Honorable City Council FROM: Baldemar Troche, Public Works Management Analyst DATE: June 14, 1996 SUBJECT: CC Meeting of 6 -19 -96 : Item #10I : Automobile Business Inspection At the subject meeting, City Council will be considering the approval of contracting with the Ventura County Flood Control District for inspection services through the Ventura County Environmental Health Department to perform automobile business inspections. The agenda report makes reference to the Clean Business Program. A description of that program is attached as Exhibit 'A'. The inspection forms are attached as Exhibit 'B', and a list of automotive businesses to be inspected is attached as Exhibit 'C'. If you have any questions or concerns, please contact me at extension 253. cc: City Manager Public Works Director EXHIBIT A Specific Business Outreach Programs Program Element Clean Business Program for Automotive Service Businesses Program Goal The Specific Business Outreach Programs allow business owners and municipalities to work together to define appropriate, acceptable, [practicable] stormwater pollution controls. They have the following long -term objectives: • Identify types of businesses with potential to discharge stormwater with higher than typical pollutant concentrations. • Identify appropriate BMPs that can be implemented countywide. • Encourage businesses to implement BMPs. • Institute a local public recognition /awards program for businesses that volun- tarily implement BMPs. • Identify limitations in voluntary compliance programs for businesses. Background I Why Implement This Program? Under the Ventura countywide permit, the co- permittees must develop programs to reduce stormwater pollutants from businesses. These programs should target business types that individually may have relatively low volume discharges but, taken as a group, may contribute relatively large amounts of pollutants. The co- permittees decided that the first such program would be directed toward automotive service businesses because other municipal stormwater programs have included these businesses in their respective programs and because the Regional Boards have found that there is a higher probability of stormwater pollution from these facilities. Because these are retail businesses, the countywide program evolved as a Clean Busi- ness Program: a program that promotes environmentally responsible businesses to the public. In future years this approach may be modified as additional types of business that respond to different incentives are added to the program. Specific activities of concern are shown in Table 1. These activities are likely to be sources of pollutants such as metals (copper, zinc, lead), total petroleum hydrocarbons (TPH), oil and grease, and solvents. Ventura Countywide Stormwater Quality Management Program or.rt March 20•'998 _ �, Programs for Industrial /Commercial Businesses Countywide Program Approach Specific Business Outreach Programs Clean Business Program for Automotive Service Business The approach seeks to minimize or even eliminate stormwater pollution from automo- tive service facilities through proper education of business owners and their employees. This program is designed to be non - regulatory with an approach of encouraging businesses to voluntarily implement BMPs by providing education and incentives such as public recognition for their efforts. The approach draws from programs developed by other communities such as the City of Palo Alto and the City of Santa Rosa and from the pilot Clean Business Program conducted by Thousand Oaks and Simi Valley. An overview of this approach appears next, followed by a detailed discussion of each step of the approach. This approach involves six steps: Identify and Evaluate Existing Conditions. To prepare for the Clean Business Program, co- permittees will review current public agency programs and regula- tions impacting automotive service businesses, obtain specific information about businesses of concern in the service area and characterize the general business community. 2. Select Target Businesses. Co- permittees will target businesses for the Clean Business Program based on the type of activities at the business' facility or known presence of pollutant discharges at the site. 3. Select Control Measures /BMPs. Co- permittees will select control measures that can be implemented by the targeted businesses to meet the Clean Business criteria. 4. Contact Target Businesses. Co- permittee staff will contact each targeted busi- ness to inform them about stormwater concerns, inspect them for stormwater pollution, and determine their stormwater pollution control status. Offi. V entura Countywide Stormwater Quality Management Program Draft February 12,1386 Programs for Industrial /Commercial Businesses 2 Table 1= Activities of Concern at Automotive Service Businesses • Vehicle leaks and spills ■ Pavement cleaning • Steam cleaning ■ Fueling • Radiator flushing ■ Fluid changing • Car washing ■ "Boneyard" area • Bodywork ■ Battery storage • Painting ■ Metal grinding /finishing • Waste drum storage ■ Parts cleaning • Floor cleaning ■ Waste storage The approach seeks to minimize or even eliminate stormwater pollution from automo- tive service facilities through proper education of business owners and their employees. This program is designed to be non - regulatory with an approach of encouraging businesses to voluntarily implement BMPs by providing education and incentives such as public recognition for their efforts. The approach draws from programs developed by other communities such as the City of Palo Alto and the City of Santa Rosa and from the pilot Clean Business Program conducted by Thousand Oaks and Simi Valley. An overview of this approach appears next, followed by a detailed discussion of each step of the approach. This approach involves six steps: Identify and Evaluate Existing Conditions. To prepare for the Clean Business Program, co- permittees will review current public agency programs and regula- tions impacting automotive service businesses, obtain specific information about businesses of concern in the service area and characterize the general business community. 2. Select Target Businesses. Co- permittees will target businesses for the Clean Business Program based on the type of activities at the business' facility or known presence of pollutant discharges at the site. 3. Select Control Measures /BMPs. Co- permittees will select control measures that can be implemented by the targeted businesses to meet the Clean Business criteria. 4. Contact Target Businesses. Co- permittee staff will contact each targeted busi- ness to inform them about stormwater concerns, inspect them for stormwater pollution, and determine their stormwater pollution control status. Offi. V entura Countywide Stormwater Quality Management Program Draft February 12,1386 Programs for Industrial /Commercial Businesses 2 Specific Business Outreach Programs Clean Business Program for Automotive Service Business 5. A►vard Clean Businesses. Businesses practicing proper stormwater pollution control will be designated Clean Businesses, provided incentive rewards, and recognized as such to the general public. 6. Evaluate Program Effectiveness. Co- permittees will use results from the Clean Business program in combination with other stormwater program results to track program effectiveness and determine future program directions. Identify and Evaluate Existing Conditions The first step in developing a Clean Business Program is to identify and coordinate with existing public agency programs dealing with the automotive service businesses, identify specific automotive service businesses in the community, and meet with repre- sentatives of these businesses on issues of concern. Coordinate with Other Public Agencies Automotive service businesses in Ventura County are usually inspected by several public agencies, each with its own set of requirements and regulations. Attachment 1 lists the public agencies with jurisdiction over automotive service businesses within each co- permittee's boundaries. Before developing its Clean Business Program, each co- permittee should contact the agencies within its jurisdiction and discuss oppor- tunities for coordination of inspections, business recognition or other program elements. Ideally, the development of a Clean Business Program would involve a joint - recognition program with all public agency environmental programs. Opportunities for such a program should be explored. At a minimum, a Clean Business award should only be given to a business if all other agencies agree that there are no outstanding environmental issues for that business. The co- permittee should confirm that the agency contact is the appropriate person to review a list of Clean Business Program candidates and identify any businesses that may have compliance issues with the agency's program. Some questions that can be used to obtain the desired information are: • Does your agency inspect automotive service businesses? • Do you provide other public agencies with a list of businesses you inspect? ■ How often are they inspected? ■ What is covered during an inspection? ■ Who is the contact in your agency that deals with these businesses? • Does this contact have the authority to review businesses with respect to their compliance status with your agency's programs. • Is there an existing outreach program and, if so, what does it consist of (e.g., brochures, workshops, technical assistance, etc.)? 000228 Ventura Countywide Stormwater Quality Management Program Draft February 12, 1996 Programs for Industrial /Commercial Businesses 3 Specific Business Outreach Programs Clean Business Program for Automotive Service Business ■ Is there an existing awards or recognition program? ■ Which businesses have received the award? The answers to these questions will enable each co- permittee to effectively coordinate their program with other agencies in their jurisdiction. Identify Automotive Service Businesses The next step is to identify the specific businesses to be included in the Clean Business Program. Resources for identifying automotive service facilities include the Environmental Health Department's and Fire Department's hazardous materials inventory; Industrial Pretreatment Program industrial user surveys, city business license records, Dun & Bradstreet database, and the yellow pages. Information from these sources should include business names, owners, locations and some description of business operations. SIC codes can be used to identify businesses that are included in the program. The SIC codes corresponding to automotive service businesses are listed in Table 2. Table 2 Automotive Service Related SIC Codes S/C S/C Code Description Code Description 5511 Motor Vehicle Dealers 5521 Motor Vehicle Dealers (Used Only) 5531 Auto/ Home Supply 5541 Gasoline Service Stations 5551 Boat Dealers 5561 RV Dealers 5571 Motorcycle Dealers 5599 Other Dealers 7532 Body Shops 7533 Exhaust Repair 7534 Tires 7536 Glass Repair 7537 Transportation 7538 Miscellaneous Repair 7539 Miscellaneous Repair 7542 Car Wash 7549 Other Ventura Countywide Stoimwater Quality Management Program AiL"J" Drag February 12, 1996 N m Progras for Industrial /Commercial Businesses 4 Specific Business Outreach Programs Clean Business Program for Automotive Service Business A listing of businesses in each co- permittee's service area by SIC codes was distributed to the co- permittees through the Business and Illicit Discharge Subcommittee. This listing was developed in 1993 from Dun & Bradstreet records and can provide a starting point for identifying businesses in each co- permittee's service area. Preparation for Meeting Business Representatives Effective methods of working with the business community will also be established during this initial phase of program development. Before contacting the automotive service businesses in your jurisdiction, the following preliminary steps are recommended: Review existing legal authority. While this approach is intended to be non - regulatory, clear regulatory authority is important as a fallback when participa- tion is not obtained through voluntary means. Each co- permittee should understand their own legal authority and be aware of which agencies have enforcement powers in their jurisdiction. In addition, stormwater ordinances are being developed and participating in the Clean Business Program will help businesses comply with the ordinance once it is adopted. If the voluntary program (i.e., the Clean Business Program) works, then regulation through permitting may not be necessary. 2. Train the inspectors that will be implementing the program. The inspectors need to be educated about existing regulations and upcoming regulations (e.g., a new stormwater ordinance), stormwater discharges from vehicle service facilities, BMPs, and Clean Business Program elements. They should be able to answer the questions that a business is likely to pose. In particular, they should be well versed on the reasons to participate in the program (e.g., regulations, public perception, protecting the environment). 3. Arrange to meet with a small select group of businesses to discuss the up- coming program and obtain their comments. A select group of business owners who are representative of the overall group of automotive service businesses should be selected. The support of these businesses will lend credibility to the developed program. In addition, their participation will give them a sense of ownership regarding the Clean Business Program and will increase the probability that a program will be developed that is acceptable to the business community as a whole. Select Target Businesses The next step is to set priorities for implementing the Clean Business Program. The subcommittee has identified automotive service businesses and restaurants as the highest priority businesses with respect to their potential to contaminate stormwater discharges. The initial Clean Business Program will target automotive service businesses. In general, any business with a service bay would be a candidate for the program. The targeted automotive service businesses are summarized in Table 3. '000230 1 Ventura Countywide Stormwater ry Quality Management Program Draft February 12, 1998 _ _, Programs for Industrial /Commercial Businesses 5 Specific Business Outreach Programs Clean Business Program for Automotive Service Business Table 3 Target Automotive Service Businesses for Clean Business Program • Gas stations ■ - Car washes • Auto repair shops ■ Auto dealers • Fluid replacement shops ■ Vehicle maintenance jrards G • Radiator shops ■ Exhaust system repair shops " • Transmission shops ■ Other businesses with service • Auto body and paint shops bays (e.g., retail shops, tire dealers) The co- permittees may want to phase in the Clean Business Program by initially addressing only the businesses of highest priority according to the following criteria: • Business size • Business' compliance history Select Control Measures /BMPs The primary goal of the Clean Business Program is to control pollutant generating activities at automotive service facilities. To this end, the Business and Illicit Discharge Subcommittee defined selection criteria for Clean Businesses, and suggested control measures that businesses may use to meet these criteria. Table 4 is a list of criteria for "clean" automotive service businesses that a business must meet to be designated as a Clean Business in Ventura County. Table _4 Clean Business Criteria for Automotive Service Businesses M Educate and train employees and customers. • Use "dry shop principles" when servicing and repairing vehicles. • Outdoor work areas should be designed to minimize stormwater runoff from wet operations. • Contain vehicle parts and batteries to prevent leaks and spills. • Prevent spills and leaks during fueling. • Prevent wastewater discharges to storm drain. • Collect automotive fluids and recycle /dispose properly. • Prevent grinding and machine filings from being discharged to storm drain. BMPs were developed by the subcommittee in coordination with representatives of automotive service businesses and other public agencies to select affordable, achievable control measures that complement other pollution control requirements. 000231L Ventura Countywide Stormivater Quality Management Program Draft February 12, 1996 _ _, Programs for Industrial /Commercial Businesses 6 Specific Business Outreach Programs Clean Business Program for Automotive Service Business Attachment 2 is a matrix comparing automotive service facility control measures or BMPs to automotive service activities. Contact Target Businesses Once the groundwork for the program has been laid by the previous steps, businesses are contacted and visited. There are two types of contact with the targeted businesses: the initial contact to introduce the program, and the inspections to assess Clean Busi- ness status. Initial Contact The approach used for the initial contact depends on the size of the business com- munity and the existing relationship with the businesses. Options for the initial contact include conducting a workshop, sending a letter describing the program, or conducting site visits. In a community with a large number of automotive service businesses, a workshop may be a good initial contact. For a community with a small number of businesses, a workshop may not be effective and a letter will be more appropriate. A letter and a workshop are the best approaches if there is no existing relationship between the agency and the targeted businesses. In a community like Simi Valley where the industrial Pretreatment Program already inspects the auto- motive service businesses, a site visit was used as the initial contact. Regardless of the approach selected, the initial contact is used to explain the program. Attachment 3 is a collection of items that are distributed at the initial contact (either mailed or handed out at a workshop or site visit): ■ Introductory Letter ■ Stormwater Pollution Prevention Handout ■ BMP Handouts Topics covered include describing stormwater pollution, general practices that will prevent pollution, how to qualify as a Clean Business, and incentives for becoming a Clean Business. The introductory letter should notify the businesses of when co- permittee representatives will be in their area to evaluate BMP implementation. Clean Business Evaluation After the initial contact, evaluations are conducted to determine which businesses meet the Clean Business criteria. In addition, the visits should be viewed as an opportunity to further educate the business about stormwater pollution and methods for preventing it. These visits can be scheduled or unannounced and may be conducted using one or two inspectors. At least four weeks should separate the initial contact and the Clean Business evaluation to allow the business time to review their facilities and implement BMPs. Evaluations are conducted using the checklist found in Attachment 4. The inspector begins the inspection by clearly describing the program and its objectives. Next, the inspector walks through the facility, indoors and outdoors, with a business represen- tative and completes the checklist. It may be useful to talk to shop employees to ^,, Ventura Countywide Storrnwater Quality Management Program W 02 Draft February 12, 1996 _ a Programs for Industrial /Commercial Businesses 7 Specific Business Outreach Programs Clean Business Program for Automotive Service Business determine how the various BMPs are implemented at the shop level. Inspections should be expected to take up to an hour. At the end of the inspection, the results are discussed with the business. A copy of the inspection report can be left with the business or mailed at a later date. Although this program is voluntary, violations of other agencies' programs may be discovered. In this situation, the business should be informed of the nature of the violation. If necessary, the appropriate agency should be informed so that follow -up action can be taken. Before contacting another agency, the business should be informed that this action is planned. Optional Follow -up Visit If the business does not meet the Clean Business criteria, the inspector may decide to schedule a follow -up inspection. The purpose of this second visit is to encourage the business to comply by giving them a second chance. While the follow -up inspection is at the discretion of the inspector, it is recommended as a further effort to cooperate with the targeted businesses. Determining Compliance with Clean Business Criteria During the inspection, the inspector needs to determine if the objectives of the Clean Business Program are met. As mentioned above, the evaluation checklist is used as a guide to determine if the Clean Business criteria are being met. The purpose of the criteria is to ensure that no unacceptable discharges are entering the storm drain and to provide countywide consistency in implementing the program. Some guidelines for determining if the criteria in Table 4 are being met are listed below. While it is not necessary that a business carry out every practice mentioned for each criteria, they should have taken some steps to meeting the intent of each criterion. Educate and train employees and customers. To meet this criterion, shop personnel should, at a minimum, be aware of dry clean -up methods, procedures for preventing spills, and the location of spill containment materials and waste disposal containers. The inspector should question shop personnel if possible. In addition, the inspector can see if BMP reminders are posted and if written information is available summarizing this information. 2. Use "dry shop principles" when servicing and repairing vehicles. To meet this criterion, shops should employ practices that minimize the use of water during cleanup. Rather than hosing down a floor or parking lot, a three step process should be used. First liquids such as spilled oil are wiped up with rags or absorbent that are then disposed of as hazardous waste. Rags may also be cleaned by an industrial laundry service and reused. Next, the area is swept or vacuumed. Once, these two steps are taken, the floor may be mopped. Whenever possible, the mopwater should be poured through an oil /water separator and never down the storm drain. The inspector should look to see that the appropriate materials are available (i.e., rags, mops, NOT hoses). In addi- tion, the inspector should ask shop personnel how they clean the floors, etc. Ventura Countywide Stortnwater Quality Management Program Draft February 12, 1996 Programs for IndustriallCommercial Businesses 8 Specific Business Outreach Programs Clean Business Program for Automotive Service Business 3. Outdoor work areas should be designed to minimize stormwater runoff from wet operations. To meet this criteria the business should employ practices that prevent stormwater from flowing across contaminated areas and entering the storm drain. Berms, paving and grading can be used for this purpose. In addi- tion, vehicle wastewater should not be discharged to the storm drain. Options to accomplish this include a washpad, covered area, inflatable berm or some combination of these items. The exception to this is that, if vehicles are washed with water only (no detergents, etc.), this water may go to the storm drain. 4. Contain vehicles, parts and batteries to prevent leaks and spills. To meet this criterion, the shop should take measures to minimize the possibility that fluids such as oil or antifreeze will leak or spill and possibly enter the storm drain. The inspector should look to see if drip pans are available and if they are being used under wrecked vehicles. Wrecked vehicles and parts should be drained of all fluids. Fluids removal is conducted on a non - porous floor (NOT dirt or asphalt). Spill containment kits and /or inflatable berms should be readily available to shop personnel. Batteries should be stored indoors in an area without drains. If batteries are stored outside the area should be covered. If there are drains in the storage area, secondary containment should be used. This can simply be a plastic tub that would hold the contents of a leaking bat- tery. 5. Prevent spills and leaks during fueling. Fueling areas should be covered. When practical, the area should be graded, paved and drained to prevent stormwater from flowing across the fueling area from somewhere else. It may be necessary to install a gfease [sand /oil] trap for gravity separator] in the drain for the fueling area. Fuel pumps should have automatic shut -offs. 6. Prevent wastewater discharges to storm drain. The shop should have no con- nections between indoor drains or sinks and the storm drain. There should be no hoses available to make this type of connection. Storm drains should be stenciled to remind employees concerning unacceptable discharges. 7. Collect automotive fluids and dispose of properly. This criterion is met if the business has taken steps to collect all automotive fluids. Drums are available for fluid disposal, drip pans are used to collect fluids from leaks and spills. Secondary containment is used when storing fluids outdoors. 8. Prevent grinding and machine filings from being discharged to storm drain. Machining and grinding operations should be enclosed if possible or a bin can be installed under the equipment to catch filings. Dry shop principles should be used in these areas. Loose chips or filings should be vacuumed or swept up. They should not be mopped up. Alternatively a tarp or plastic liner can be placed on the floor of this area to collect filings. To determine if this. criterion is being met, bins or tarps should be present or shop personnel can be questioned regarding practices used in this area. Ventura Countywide Storm water "000234 t) Quality Management Program Draft February 12, 1996 `R Programs for IndustriallCommercial Businesses 9 Specific Business Outreach Programs Clean Business Program for Automotive Service Business Award Clean Businesses Once the inspections are completed, the businesses that Feet -all (sufficiently satisfy the) criteria are tentatively identified as Clean Businesses. The agencies listed in Attachment 1 are then asked to review the candidate businesses to verify that the business has no outstanding violations in the agency's respective programs. If an agency has had a problem with a business on the list regarding environmental compli- ance, they will not receive an award. The final list of Clean Businesses is prepared. Businesses that qualify are given an award package and included in the various public announcements. Businesses that do not qualify should be informed of the actions to be taken to qualify during the next round. The Clean Business award should be structured in such a way that it will provide a perceived marketing advantage for the recognized business. Table S lists possible award /recognition items for businesses that qualify for the program. A business concerned about its image will respond to a program that is well received by the com- munity. Therefore, educating the general public about the program is essential. Press releases, newspaper advertisements and other media displays are provided by the Clean Business Program to inform the public about Clean Businesses in their community. Some examples of materials used in Palo Alto's recognition program are found in Attachment 5. Table 5 Possible Award /Recognition Items • Stickers /posters for display at businesses ■ Promotional Coupons • Brochures describing program ■ Billboard or bus placard ads • Newspaper Ads ■ Public Service Announcements • Press Releases ■ Radio Ads • City Council Certificate ■ Reduced Permit Fees Finally, press releases and other promotions to publicize the Clean Businesses should be prepared to inform the general public about the program. The various promotions and advertisements should be conducted repeatedly throughout the year to increase the level of public awareness. Remember, public recognition is critical to the program's success. The Clean Business Program may be publicized around Earth Day in the Spring and during Pollution Prevention Week in the Fall. In addition, county fairs and other local events may provide opportunities to increase public awareness. The fre- quency of promotions may depend on a program's budget but there should be oppor- tunities to coordinate these efforts with those of other programs. For example, the Waste Watch Program is planning a Used Oil Month in the Spring. Publicity efforts may be coordinated with this event. I �` � Draft Febru Ventura Countywide Stormivater Quality Management Program uy 12, 1998 _ ' Programs for Industrial /Commercial Businesses Specific Business Outreach Programs Clean Business Program for Automotive Service Business Evaluate Program Effectiveness Program effectiveness can be measured by tracking the number of eligible businesses that qualify as clean businesses and evaluating public awareness of the program. These measures are used to plan future direction for the program. If a low percentage of eligible businesses are qualifying for the program, the criteria should be reviewed with the Subcommittee and the incentive program should be reexamined. Feedback from the businesses on these topics is helpful. If public awareness of the program is poor, education efforts can be increased and new tactics tried. While program participation by the businesses can be evaluated during the first year, noticeable changes in public awareness may take longer. A summary sheet that can be used to evaluate the program is found in Attachment 6. � �wo236 Ventura Countywide Stormwater Quality Management Program Draft February 12, ,sse _ _. Programs for Industrial /Commercial Businesses Specific Business Outreach Programs Clean Business Program for Automotive Service Business Program Administration Needs Estimates of staff time, staffing levels and other expenses described in this section are based on the experiences of Simi Valley and Thousand Oaks during the pilot program conducted in the Spring of 1995. Thousand Oaks conducted an initial site visit to introduce the program and distribute BMP handbooks and a follow -up visit to conduct an inspection using the evaluation checklist. The initial visit took approximately 1.4 hours per business including travel time and preparation time. The follow -up visit took approximately 2 hours per busi- ness including travel time, preparation time, and time to schedule appointments. Simi Valley conducted the Clean Business inspection in conjunction with their illicit discharge inspections. In the initial visit, they introduced the program and completed the checklists. This took approximately one hour per business and was conducted over a period of two weeks. Approximately two months later, a follow -up inspection was conducted that took approximately 15 minutes per business. Simi Valley spent a total of approximately two hours per business including travel time. The total staff time necessary is directly related to the number of businesses in the Clean Business Program, how the inspections are conducted, and the experience level of the staff. Thousand Oaks used an Environmental Program Specialist to conduct the program. This person also conducts industrial and commercial wastewater inspections and does a lot of public outreach work. Simi Valley used three Source Control Inspectors who also conduct illicit discharge investigation and pretreatment inspections. Both programs found that establishing a good rapport with the businesses is essential to a successful program. It was also observed that mailing out information before the visits can reduce total inspection time but can add other direct costs. lmplemen to tion Schedule The implementation schedule shown in Table 6 includes a period of initial implemen- tation to test the program on priority businesses or areas, and then a date for assess- ment and possible refocus of efforts. Additional dates and deliverables to incorporate in the schedule will consist of annual submittals to the county on program effective- ness. 231 Ventura Countywide Stormwater Quality Management Program M_' Drift February 12, 1896 Programs for Industrial /Commercial Businesses 12 Field Experience Specific Business Outreach Programs Clean Business Program for Automotive Service Business Table 6 Proposed Implementation Schedule Program Task Identify and Evaluate Existing conditions Set Priorities Select Controls Visit Target Businesses Award Clean Businesses Evaluate Program Effectiveness Pilot Program Annual Clean. Business Program Schedule March 1996 April 1996 April 1996 May 1996 -June 1997 July 1997 1997 In the spring of 1995, the cities of Simi Valley and Thousand Oaks each conducted a pilot Clean Business Program. Their experiences are described below. Thousand Oaks Thousand Oaks initially visited 19 auto repair facilities over a one -week period, including 13 auto dealerships, and conducted follow -up visits two months later at only 16 of the businesses, as three businesses declined to participate. Based on the draft criteria developed by the subcommittee for automobile service businesses, none of the businesses inspected qualified as a Clean Business. The city discovered that it was extremely important to clearly explain the reason for the program and the program objectives. They found the initial visit was an effective method of communicating the objectives of the program before the follow -up visit, but felt a letter introducing the program would be less time consuming and just as effective as the initial visit. Most of the business owners and service managers were receptive or neutral to the program. In general, they felt the program should provide incentives and workable solutions to waste disposal problems to be successful. Stickers, plaques and posters to be displayed in the business, newspaper ads and fee reductions were all identified as good incentives for such a program. Simi Valley Simi Valley conducted its initial Clean Business Program for automotive service businesses in conjunction with its illicit discharge control investigations in the Tapo Canyon Channel area. This reduced the number of visits to the site, and allowed the inspectors to distribute BMP information in person. However, the area initially selected for this year's illicit discharge investigations contained only four automotive facilities. Therefore, the program was expanded to include facilities outside the area. I Ventura Countywide Sta-mwater ry Quality Management Program Draft February 12, 1996 '0.1 Programs for Industrial /Commercial Businesses 13 Specific Business Outreach Programs Clean Business Program for Automotive Service Business This resulted in visits to a total of 11 automotive facilities, and included four restaurants to receive an initial reaction from them to the program. Source Control staff used the automotive service facility Clean Business Program checklist to record details of the visit and any response to the discussion about the Clean Business Program. The visits were unannounced at the facilities and in most cases were met without resistance. After approaching the business owner and inform- ing them of the purpose and intention, Source Control staff looked over the site. They then discussed the results with the owner /operator to point out problem areas, to distribute the BMP information, and ask their opinion of a possible Clean Business award program. Award items the owner /operators preferred included free newspaper advertising, plaques for business lobbies, free discharge permits and equipment (e.g., sheds, storage bins, etc.). Staff at only two facilities voiced total objection to the program. They felt it involved more regulation and would eventually involve a fee. The other 13 facilities were in agreement with the initiation of the Clean Business Program and thought the program would be beneficial. Of all 15 sites reviewed, eight met the criteria for a Clean Business. Four weeks later, the city conducted follow -up visits. The same eight facilities qualified as Clean Businesses, two had made no improvement, and the remaining five had implemented several of the recommended BMPs. The implementation ranged from requiring all employees to review the educational BMP materials, to installing a trench drain to recover a greasy wastestream that was draining to the storm drain system. Overall, the staff at the facilities appreciated the opportunity to have input into the Clean Business Program and supported the effort. Because the program was voluntary, the city feels the facility staff did not perceive a regulatory threat, which reduced tension and allowed a full discussion of the Clean Business Program. Programs in Other Communities The City of Palo Alto and the City of Santa Rosa have both implemented Clean Business Programs for automotive service facilities. Each program is described briefly below. Palo Alto RWQCP In 1992, Palo Alto began a vehicle service regulatory program targeting both stormwater and sanitary sewer discharges that targets approximately 330 businesses including auto repair shops, gasoline stations, fleet maintenance facilities, commercial car washes, parts cleaning and repair facilities, and autobody repair shops. The' program focuses on eliminating discharges to the storm drain and reducing or eliminating discharges to the sanitary sewer. Palo Alto has included requirements for vehicle service facilities in their sewer use ordinance. Businesses are visited annually for the purposes of education and encouraging compliance. Ventura Countywicle Stontrnvater , Draft February 12, 1996 1 Programs for 1 xlustrial/Cornmer ial Businesses Program 14 Specific Business Outreach Programs Clean Business Program for Automotive Service Business Palo Alto developed the Clean Bay Business recognition program as an incentive for businesses to comply with the vehicle service facility requirements. A business may be designated as a Clean Bay Business based on the results of their annual inspection. Criteria for recognition as a Clean Bay Business include completion of an inspection, substantial compliance with the ordinance requirements, and the lack of significant violations of other environmental regulations. Clean Bay Businesses are provided with free advertising tools such as stickers and placards to be displayed at their facility. In addition, the facilities are recognized publicly through press releases and lists published in the local newspapers. Of the 330 vehicle service facilities, 179 businesses were designated as Clean Bay Businesses in the fall of 1993. Common reasons that businesses did not qualify as Clean Bay businesses included failure to meet requirements regarding employee training, spill prevention and cleanup, secondary containment for vehicle fluid removal, vehicle washing and containing vehicle leaks. City of Santa Rosa The City of Santa Rosa developed and implemented the Compliance Incentive Program (CIP) for the auto repair and service industry targeting approximately 275 businesses. The CIP consists of four elements: technical assistance, regulatory streamlining, recognition, and consumer awareness. Businesses that comply with all environmental regulations are presented with a regional sticker recognizing that they are a "Sonoma Green Business." A significant public outreach effort has been initiated to educate consumers about the program and the meaning of the recognition stickers. The CIP is a voluntary program with businesses requesting the inspections to be certified as Green Businesses. CIP inspections began in April of 1993 and over 150 inspections had been conducted by the fall of 1994. Thirty three businesses were found to be in full compliance. An important component of the CIP is the coordination and communication among the eight regulatory agencies responsible for environmental compliance in Sonoma County. These agencies are the Santa Rosa Industrial Waste Section, Santa Rosa Fire Services, Sonoma County Fire Services, Sonoma County Environmental Health, North Coast Regional Water Quality Control Board, Bay Area Air Quality Management District, Department of Toxic Substances Control, and Cal -EPA. Representatives from these agencies meet once a month to discuss environmental compliance issues and share information on non - complying businesses. Attachments 1. Public Agency Matrix and Contacts 2. BMP /Activity Matrix 3. Clean Business Program Information Packet 4. Clean Business Evaluation Checklist 5. Recognition Program Materials 6. Clean Business Program Summary Sheet 'C240 Ventura Countywide Stormwater Quality Management Program Waft Febrwry 12, lass ` Programs for /ndustrlallCommercial Businesses 15 EXHIBIT B +pM241. Date: Facility Name: Facility Address: Mailing Address: Contact Person: Title: Phone Number: Business Activity: (check all that l Gas Station © Maintenance Yard 0 Mobile Auto Repair apply) ti Auto Dealer C3 Car Wash 0 Retail w /Repair Radiator Shop Autobody Repair /Painting 0 Exhaust System Repair Transmission Shop Ira Automotive Repair Tire Dealer Municipal Yard Fluid Replacement Wrecking Yard Estimated Flow: (or zero discharge) No. of employees 6 No. of cars serviced per week (indicate storm drains, floor drains, work areas, storage areas) Inspected by: 00- (indicate which activities, practices, or equipment are used to satisfy each criteria) Acceptable 1. Use BMP Criteria "dry shop" orincioles when wnrkinn nn voh;Al See Comments Clean drips & spills with rags, dry adsorbents (2) Yes No 'U N/A 10 N/A Drain fluids from wrecked vehicles promptly (2) Yes No Sweep or vacuum instead of mopping (2) Yes Ci ENo-tl N/A Routinely inspect shop equipment & procedures (2) Maintain equipment to prevent leaks (2) Use drip pans under vehicles (1) Yes 10 No Avoid hosing down or wet mopping floors, bays, or fueling areas (2) N/A 'i N/A Don't leave open containers & drip pans (2) Yes Ci No Pts Z o. N/A U Comment: 7 D. - -' Pts Wrecked vehicles with exposed parts stored outdoors should be covered (1) Yes -0 No 'U N/A 10 Help customers by taking their used oil, etc. (1) Drain fluids from wrecked vehicles promptly (2) Yes No N/A Monitor customer activities at your site (1) Keep adequate spill containment on hand (2) Yes TT b_ N/A Routinely inspect shop equipment & procedures (2) Maintain equipment to prevent leaks (2) Yes N/A Avoid hosing down or wet mopping floors, bays, or fueling areas (2) Yes JUN 'i N/A Comment: Pts Z o. - _ •- .,101,1 in1 ycs w swan cram or sewer Wastes are not poured down storm drain or receptacles (21 Yes No Never connect indoor drains to storm drain (2) Yes No Comment: 4. Educate/ train emolovees & custnmPrc Review BMPs w/ employees annually (2) Yes ;0 No 10 Help customers by taking their used oil, etc. (1) Yes No 'b Monitor customer activities at your site (1) Yes i No Routinely inspect shop equipment & procedures (2) Yes No N/A N/A N/A N/A N/A N/A Clean parts and control residues with mechanical, thermal or abrasive methods (1) Use self- contained solvent sinks or enclosed parts washers (2) Solvents are not evaporated as disposal method (2) Solvents are not poured down the drain (2) Comment: Yes No N/A Yes 'd No `' N/A 13 Yes ff No —OT/A710— N/A Yes 10 No N/A N/A ar (1) 6• Minimize spills & leaks during fueling Never hose down fueling areas 0 ) Yes Clean up outdoor spills promptly (2) Yes m Coment: 7• Treat batteries as hazardous waste Recycle batteries in a timely manner (2) Store batteries inside or under cover and in containment (2) Comment: 8. Properly prepare outdoor work areas Pave surfaces with concrete instead of asphalt and /or use coat (2) Comment: 9• Minimize wastewater from veh' I No No N/A N/A Yes 0 I No - I N/A I Yes 03 1 No `0 1 N/A seal Yes No Ni N/A Pts No is e, engine & steam cleaning Uollect and recycle or treat vehicle wash -water (1) Water (no soap) washing can go to storm drain (2) Regular washing needs oil /grease pretreatment for sewE Pretreatment needed for engine /steam cleaning for sew Use enclosed bay for steam cleaning or rainwater divert Comment: Yes ! No ti N/A Yes C. No N /Al r (1) Yes No N/A 'r (2) Yes 0 No 0 N/A ar (1) Yes No i N/A 'C P's Change fluids in designated area w/o drains (2) Separate spent fluids. to aid recycling (2) Reuse, then recycle radiator flushing fluid (on site or reclaimer) (2) Use suppliers who recycle used materials Purchase & store supplies in bulk in smallest quantities possible Comment: Yes L1 No 0 N/A Yes . No N/A Yes No N/A Yes CI No N/A Yes No N/A 11. Don't "dump" sanding or grinding & machining filing residues Sweep or vacuum filings, sanding and residue (1) Yes U No Comment. N/A EXHIBIT C tIII Subtotal: CITY _CD = 5291, 34 records. -------------- ----------------- - - - - -- ntura Automotive Businesses Listing, Co- permittee & SIC Sequence r 12, 1994 Page ,,Ic# Company Name --- - - - - -- mailing Address --------------- Mailing CityI ' 5531 A & P TIRES - - - - -- 13850 E LOS ANGELES AVE ---- - - - - -- MOORPARK 5531 MOORPARK CMNTY TIRE & SVC CTR 480 MOORPARK AVE MOORPARK 5531 NORTH OAKS AUTO PARTS 401 MOORPARK AVE MOORPARK 5531 OFF ROAD ENGINEERING 13200 VIEW MESA ST MOORPARK 5531 RANDYS TIRE INC 460 E HIGH ST MOORPARK 5531 REYES ENTERPRISES 12290 CHERRY GROVE ST MOORPARK 5531 SPORTS TRUCKS BY SEARS 5150 GOLDMAN AVE MOORPARK 5541 ABSCO ENTERPRISES INC 502 E LOS ANGELES AVE MOORPARK 5541 ALAN WUTKEE CHEVRON 502 NEW LOS ANGELES AVE MOORPARK 5541 BILLS UNION 506 E LOS ANGELES AVE MOORPARK 5599 RIDDLE AVIATION INC 13840 E LOS ANGELES AVE MOORPARK 7513 ACR LEASING CORP (NOT INC) 165 E HIGH ST MOORPARK 7532 ALLBODY 619 FITCH AVE MOORPARK 7532 DONALD G FENDER SR 14875 CAMPUS PARK DR MOORPARK 7532 PACIFIC COAST AUTO BODY INC 5162 GOLDMAN AVE MOORPARK 7532 PETES AUTO BODY SHOP 480 MOORPARK AVE MOORPARK 7532 STUDEBAKER SERVICES AUTO PNTG 5090 GOLDMAN AVE A MOORPARK 7537 AA MOORPARK TRANSMISSION 21 W HIGH ST MOORPARK 7537 TRANS PRO TRANSMISSIONS 5162 GOLDMAN AVE MOORPARK 7538 DONS TRUCK REPAIRS 11812 ELWIN LN 850A MOORPARK 7538 DONS TRUCK REPAIRS 850 W LOS ANGELES AVE MOORPARK 7538 E AND M ENTERPRISES INC 476 W LOS ANGELES AVE MOORPARK 7538 HI TECH AUTO & TIRE CENTE 548 LOS ANGELES AVENUE A MOORPARK 7538 MOORPARK AUTO SERVICE 5162 GOLDMAN AVE MOORPARK 7538 7538 RAYS AUTO RICHARD DARREL BROCK 320 E LOS ANGELES AVE MOORPARK 7539 MOTOR FUEL & TUNE 476 W LOS ANGELES AVE 4860 AVEDON RD MOORPARK 7542 CLASSIC CAR CARE 1813 SAVANNAH AVE VENTUR MOORPARK MOORPARK 7542 MOORPARK CAR CARE INC 75 PARK LN MOORPARK 7549 7549 CSP TOWING EASY OIL 15375 BRAUN CT MOORPARK 7549 EXECUTIVE TOUCH MOBILE DE 77 PARK LN APT F 11566 CHESTNUT RIDGE ST MOORPARK MOORPARK 7549 EXPRESS TOWING SERVICE 5158 GOLDMAN AVE MOORPARK 7549 RICKS JAPANESE CONNECTION 476 W LOS ANGELES AVE MOORPARK Subtotal: CITY _CD = 5291, 34 records. -------------- ----------------- - - - - --