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Background First ERP written in 1991 Revised in 1998

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Presentation on theme: "Background First ERP written in 1991 Revised in 1998"— Presentation transcript:

1 Tuning up Your ERP for Performance and Efficiency: A Review of San Jose’s Enforcement Response Plan

2 Background First ERP written in 1991 Revised in 1998
Revised again in 2002 To be revised in 2003 A never ending tale of the search for perfection

3 More Background Internal City Audit Conducted in 2000
Audit Report Findings of May 2001

4 Tune-up Considerations
What items needed to be addressed from the City Audit What items do the guidance document suggest What items will your Regional Board be checking for

5 Audit Findings Issued incorrect enforcement actions.
Did not issue enforcement actions for all identified violations. Missed some administrative citations. Did not apply sewer surcharge correctly.

6 Audit Changes Provide for consistent enforcement
Build clear guidelines into the ERP and ERG Support the ERP with procedures

7 Areas of Improvement Better describe the duties and responsibilities of pretreatment staff. Refine the Enforcement Response Guide to allow more flexibility. Ensure supervisory oversight. Include supporting procedures. Include supporting flow charts.

8 Responsible Staff Prior to Audit
Prior to our City audit, an inspector was designated as the Enforcement Coordinator After the audit, the Senior Environmental Inspector was designated as the Enforcement Coordinator in order to provide supervisory oversight

9 Responsible Staff Enforcement Coordinator
Enforcement Coordinator Assistant Inspector

10 Enforcement Coordinator
Reviews violations and makes final determination of enforcement action Signs routine enforcement actions Review response letters Coordinates and moderates compliance meetings Reviews company’s compliance history Compiles compliance reports for pretreatment program compliance reports Works with tributary agencies and their respective attorney’s office

11 Enforcement Coordinator Assistant
Review monitoring results and verify discharge violations Verify timely responses for violations, compliance meetings and compliance schedules Assist with compliance meetings Prepare weekly compliance reports

12 Inspector Review monitoring results and identify any violations
Recommend enforcement actions to the EC Track the Industrial User’s response to violations, and compliance schedules Prepare compliance letters Review compliance history of IU Enter all enforcement actions into tracking

13 Elements of an ERP Describe how the POTW will investigate instances of noncompliance. Describe the types of escalated enforcement actions that the POTW will take and the time periods for these actions. Show how the POTW will enforce on violations of the pretreatment standard. Criteria for scheduling sampling and sampling. A system to track due dates for SMR’s, responses to notices of violation and other enforcement actions.

14 Regional Board Checklist
When the Regional Water Quality Control Board reviewed our Enforcement Response Plan a five page checklist was used. Some of the key areas of this checklist are as follows.

15 Checklist Details How does the POTW investigate instances of noncompliance? Describe the types of Escalating Enforcement Responses the Control Authority will take. Identify the officials who must approve each type of response. Does the ERP present any obstacles to effective enforcement?

16 More Checklist Items Responsible Staff Time Frames
Inspection Procedures Sampling Procedures Data Management Escalating Enforcement Details


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