EPA Region 9 and the Los Angeles Regional Water Quality Control Board conducted on-site audits of City of Los Angeles’ and City Long Beach’s municipal storm water programs and conducted 55 individual storm water inspections of port tenants in May 2007.
As a result of this effort, on November 9, 2007, EPA issued an audit report and 20 Administrative Orders to facilities at the Ports of Los Angeles and Long Beach for being not in compliance with California’s Industrial General Permit.
One of the facilities was cited for:
Not identifying a pollution prevention team in its storm water pollution prevention plan (SWPPP)
Not maintaining sampling records of monthly visual storm water discharge observation
Not adequately implementing Best Management Practices (BMP) as identified in its SWPPP. In this case, the facility lists good housekeeping as a BMP. And yet the EPA inspectors observed significant amount of trash and white material on the ground at a location that drains toward the storm drain. There were also evidence of tank overfilling and spillage of glycol and latex paint.
These are common violations for many SWPPPs because facilities often ignore the written plans and fail to IMPLEMENT them. It is very easy for an inspector to look at the written plan and compare it to reality. More often than not, the written words and reality fail to match.
The issuance of 20 Administrative Orders by EPA is convincing proof that the agencies always LOOK for evidence of implementation when it comes to environmental plans such as SWPPP. It is NOT sufficient to just hire some consultants to prepare a nice looking plan for you. You have to actually do what the consultants have put into the plan.
So always manage your consultants and make sure they don’t put something in your plan that you can’t implement. Remember: they get paid whether you implement the plan or not. Work with the consultants and your staff who will be implementing the plan to make sure your staff has ownership of that plan.
Without ownership, it is likely no one will implement the plan.