CITY OF ORANGE LOCAL IMPLEMENTATION PLAN (LIP) SECTION A-9 EXISTING DEVELOPMENT SECTION A-9, EXISTING DEVELOPMENT A-9.0 EXISTING DEVELOPMENT The City has incorporated the Model Existing Development Program described in Section 9 of the DAMP as the basis for this section of its LIP. During the Third Term Permit period, several program components were developed to address the discharges that may occur from areas that are already developed. The Fourth Term Permit added the Residential and CIA/HOA programs. The existing development program consists of the following elements: 1. Industrial/Commercial Inspection Program 2. Food Facility Inspection Program 3. Mobile Business Program 4. Residential Program 5. Common Interest Areas/Homeowner Association Activities Program 6. Training and Outreach These programs are described in detail in the following sections, which describe and outline guidelines, procedures and requirements for the City. In addition, the Existing Development Program has been integrated with the other storm water management programs presented within the DAMP so that the City is able to leverage its finite resources and benefit from the other program efforts. The program integration for the City is illustrated in Figure A-9.I. Figure A-9.I City of Orange Local Implementation Plan (LIP) July 2011 Existing Development A-9-1 SECTION A-9, EXISTING DEVELOPMENT Storm Water Management Program Integration Introduction A-1 Program Management A-2 Coordination Meetings BMP Effectiveness Studies Plan Development A-3 Legal Authority A-4 Ordinance Review/Modifications Existing Municipal Activities A-5 Observe Ordinance Violations Development Program A-9 Public Education A-6 Provide Outreach Materials New Development A-7 Construction A-8 Existing Development A-9 Illegal Discharges Investigate Ordinance Violations & Illicit Connections A-10 Water Quality Monitoring Focus Investigations in Problem Areas A-11 Watershed Chapters A-12 City of Orange Local Implementation Plan (LIP) July 2011 Existing Development A-9-2 SECTION A-9, EXISTING DEVELOPMENT The key staff responsible for overseeing, implementing and enforcing the existing development storm water program elements are identified in Figure A-9.II below and described further in Table A-9.I. Figure A-9.II Industrial Program Organization Chart Santa Ana Regional Water Quality Control Board City of Orange Reporting Public Works Department Implementation Engineering Division City of Orange Local Implementation Plan (LIP) July 2011 Existing Development A-9-3 SECTION A-9, EXISTING DEVELOPMENT The City departments responsible for the implementation of the Existing Development Program element are shown below. Table A-9.I City of Orange Existing Development Implementation Responsibility Under the Department Activity Permit/DAMP Finance; Interact with Provide general information to Community businesses and the industrial and commercial Development; public businesses and the public Public Works regarding storm water management Finance Manage business Provides commercial and license application industrial information for the process inventory to LIP Management Public Works/ Manage existing Inventories, prioritizes and Engineering development maps facilities program Public Works/ Conduct inspections Implement inspections, require Engineering; and enforcement corrective actions to be taken, activities for existing report actions taken to LIP development sites Management All Refer ordinance Report violations of the water violations to LIP quality ordinance Management Public Work/ Enforce the water quality Engineering ordinance Key staff names for the departments can be found in Exhibit A-2.I City of Orange Local Implementation Plan (LIP) July 2011 Existing Development A-9-4 SECTION A-9, EXISTING DEVELOPMENT A-9.1 Industrial Program This program was developed pursuant to past and present Santa Ana Regional Board Orders and Section 9.0 of the DAMP and provides a framework and process for conducting the following types of NPDES permit compliance activities at industrial areas. • Pollution Prevention • Inventorying • Prioritization • BMP Implementation • Inspection and Enforcement A-9.1.1 Pollution Prevention and Program Administration The City’s Industrial Program component includes specifications for pollution-prevention methods for industrial areas and activities located within the City. Specific pollution prevention practices that are generally recognized as being effective and economically advantageous in each discharger’s industry or business activity are recommended and provided by the City to the industry or business (see Section A-9.1.4). Through an inspection program (Section A-9.1.5) the City verifies implementation of pollution-prevention methods and other BMPs by industries. A-9.1.2 Inventory The City is required to annually update its inventory of all industrial sites within its jurisdiction, regardless of site ownership. However, sites with SIC industrial codes that function merely as offices or do not utilize any operational processes are not included in the City’s inventory for inspection. For all applicable industrial sites, the City’s inventory includes the following types of information listed below for each industry identified within the City’s jurisdiction. Business Name; Physical Address Information; General Permit ID # (if applicable); Ownership Business License Size SIC Code; Watershed; GIS Coordinates, and Comments/Notes. The City continually reviews and revises the inventory based on the latest information gathered from facility inspections or other information reviewed by the inspectors. New facilities are added to the inventory based on a review of the City’s monthly new business license report or City of Orange Local Implementation Plan (LIP) July 2011 Existing Development A-9-5 SECTION A-9, EXISTING DEVELOPMENT from information gathered by inspectors or from referrals. Existing facilities may be deleted if during site visits inspectors find that a facility is no longer in business. Based on this information, a facility is crossed off the inventory for that year and completely deleted from next year’s inventory. The industrial facility inventory and GIS map showing facility locations are included in Exhibit A-9.I. The inventory is updated on an ongoing basis to reflect the latest information and the most current inventory is submitted to the Regional Board with the annual progress report. A-9.1.3 Facility Prioritization The City prioritizes industrial facilities as High, Medium, and Low, based on their respective threat to water quality and the procedures set forth in the DAMP. A designation of High Priority indicates that the facility contains a site or sources with a high potential threat to water quality. The Permit identifies some facilities to automatically be designated as High Priority eliminating the need for City evaluation. For industries that are not pre-designated, the process consists of prioritizing each facility based on the following criteria: Type of Activity Material Used Waste Generated Pollutant Discharge Potential Non-Storm water Discharges Size of Facility Proximity to an Area of Special Biological Significance (ASBS) Industries that receive a score equal to or greater than 25 are ranked as High Priority, those with a score below 25 and greater than 15 are ranked as Medium Priority, and those with a score less than or equal to 15 are ranked as Low priority. New facilities are initially assessed and prioritized by the inspector based on personal knowledge and information provided in the business license report or other available information. A formal inspection of the facility and prioritization evaluation is conducted during the fiscal year. During the course of a facility inspection, its prioritization is reviewed and reassessed based on the inspection. If warranted, the facility may be assigned a different priority based on a rescoring of the criteria noted above. Facilities excluded from reprioritization are those facilities automatically designated as High Priority in the permit. The latest prioritization information for each industrial site is included in the inventory in Exhibit A-9.I. City of Orange Local Implementation Plan (LIP) July 2011 Existing Development A-9-6 SECTION A-9, EXISTING DEVELOPMENT A-9.1.4 BMP Implementation The City has listed below in Table A-9.II the BMPs that are appropriate to prevent or mitigate pollution generated from the specific activities at each type of industrial facility. The corresponding fact sheets are presented in Exhibit A-9.II. The City encourages the implementation of the designated BMPs at each industrial facility based on site-specific conditions in order to limit that facility’s impact on receiving waters. If particular BMPs are infeasible at any specific site, other equivalent BMPs may be implemented. Table A-9.II - Industrial Activity BMPs BMP Fact Activity Sheet IC1. AIRPLANE MAINTENANCE AND REPAIR IC2. ANIMAL HANDLING AREAS IC3. BUILDING MAINTENANCE IC4. CARPET CLEANING IC5. CONCRETE AND ASPHALT PRODUCTION, APPLICATION, AND CUTTING IC6. CONTAMINATED OR ERODIBLE SURFACES AREAS IC7. LANDSCAPE MAINTENANCE IC8. NURSERIES AND GREENHOUSES IC9. OUTDOOR DRAINAGE FROM INDOOR AREAS IC10. OUTDOOR LOADING/UNLOADING OF MATERIALS IC11. OUTDOOR PROCESS EQUIPMENT OPERATIONS AND MAINTENANCE IC12. OUTDOOR STORAGE OF RAW MATERIALS, PRODUCTS, AND CONTAINERS IC13. OVER WATER ACTIVITIES PAINTING, FINISHING, AND COATINGS OF VEHICLES, BOATS, BUILDINGS, IC14. AND EQUIPMENT IC15. PARKING AND STORAGE