PROGRAM CONTINUOUS IMPROVEMENT · PDF fileThe continuous improvement process is described on...

Santa Clara Valley Urban Runoff Pollution Prevention Program FY 2003-2004 Work Plan

SECTION 1

PROGRAM CONTINUOUS IMPROVEMENT TASKS

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1. PROGRAM CONTINUOUS IMPROVEMENT WORK PLAN

INTRODUCTION The 1997 URMP commits the Program and Co-permittees to a process of continuous improvement. The concept of continuous improvement acknowledges that the definition of “maximum extent practicable” evolves over time. Through continuous improvement, the Program will continue to develop and implement reasonable control measures to help advance the goal of achieving water quality objectives in South San Francisco Bay. The continuous improvement process is described on pages 31-35 of the Program URMP. As shown in Figure 3 (page 35 of the URMP), areas for continuous improvement are identified through the Program and Co-permittees’ participation in the Santa Clara Basin Watershed Management Initiative (SCBWMI) and the Program and Co-permittees’ annual evaluations and annual reports. Regional Board staff and representatives of interested parties (including CLEAN South Bay) review the Program and Co-permittee annual reports and work plans, and participate in Co-permittee performance review meetings (see Section 9). Comments from these reviews and meetings help to identify specific continuous improvement (CI) tasks. The Program’s FY 03-04 Budget (Section 8) includes a line item allocating funds to perform CI tasks.

FY 03-04 CONTINUOUS IMPROVEMENT WORK PLAN FY 03-04 Program Continuous Improvement Items Table 1-1 includes a list of Program CI tasks for FY 03-04 and an approach and schedule for their implementation by Program staff. These tasks were identified in the FY 02-03 performance review meetings conducted in November and December 2002. Identified CI items involve suggestions on improving the implementation of New and Redevelopment Controls (Provision C.3.). No specific comments from Regional Board staff have been received on the FY 01-02 Annual Report, so no additional CI tasks have been identified from this source. Regional Board staff comments on the FY 02-03 Work Plan were addressed in the document entitled Response to Regional Board Staff Comments- 06/19/02- FY 2002-2003 Work Plan (submitted to the Regional Board on September 13, 2002). Table 1-2 within Attachment 1-1 provides an update on the status of ongoing continuous improvement tasks identified in previous fiscal years. Program Data Management Improvements Various projects are underway to improve the management of Program data and to enhance Co-permittee and public access to Program data. These projects include:

1. Using a Microsoft® Access Database to house enhanced reporting of IND and ICID data. Co-permittees have been requested to submit raw IND and IC/ID data on a quarterly basis. By February 2003, most Co-permittees had submitted raw data for the first half of FY 02-03. Raw data was reviewed and preliminary summary reports were created showing required data categories. This process has enhanced data quality;

Section 1 Program Continuous Improvement Work Plan

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2. Improving the mechanism used to track Program staff attendance at meetings. A revised written procedure has been implemented requiring Program Staff to provide pertinent meeting information on a monthly basis;

3. Creating a Microsoft® Access Database to house pertinent meeting information. Queries may be conducted to obtain meeting information.

4. Maintaining the Program’s files of electronic data and links to other data sources used by the Program. Maintenance tasks completed include data transfers, conversions, backups, storage and organization.

5. Updating the Program’s work product inventory (Table 4-2) on a routine basis. Relevant Work Product information is housed with a Microsoft® Access Database. Queries may be conducted to obtain work product inventory information. Reports are available detailing the Program’s Work Products;

6. Continually updating and improving the entire structure and content of the Program’s web site.

Trash Assessment Planning Activities The Program is well underway with activities which begin identifying a strategy for municipalities and agencies (within the Program’s jurisdiction) to address trash problem areas that occur in urban streams and waterways. A Trash Work Plan was developed and submitted (within Section 4 of the FY 03-04 Work Plan) to fulfill a Program FY 01-02 CI item and actions identified within the Program’s Multi-Year Receiving Waters Monitoring Plan. The results and implementation efforts over the next two years will be documented and provided within the Program’s and Co-permittee’s Annual Reports.

Table 1-1 FY 03-04 Program Continuous Improvement (CI) Tasks

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Tasks Updated Schedule

Status Evaluation of Effectiveness

FY 03-04 CI Tasks – New Development and Redevelopment

1. Develop written tools to be used to train staff on Provision C.3 requirements (in case of staff turnover)

December 2003 In Progress – Program staff are working on C.3. guidance for the Co-permittees. Upon completion, staff will obtain feedback from the C3PO AHTG and the MC as to whether additional training products are needed.

Cannot be evaluated at this stage.

2. Hold future training workshops on multiple days to increase the chances staff will be able to attend.

June 2003 and ongoing consideration

In Progress – Program staff were requested by the C3PO AHTG to hold the Spring 2003 New Development Workshop on two consecutive days, to accommodate municipal staff schedules as well as to allow engineers and consultants to attend.

Cannot be evaluated at this stage. Evaluation forms will be used to get feedback from participants at the workshops.

3. Develop brochures/handouts to provide to developers containing information on Provision C.3 with reference to resources containing ideas.

December 2003 In Progress – Program staff distributed the Regional Board’s C.3. fact sheet to the Co-permittees for their use. Additional fact sheets will be developed in FY 03-04 based on direction from the C3PO AHTG.


4. Develop design guidance containing stormwater control opportunities for small road modifications.

June 2003 In Progress – This will be included in the Program’s C.3. guidance.


5. Follow-up on pesticide reduction guidance to ensure effectiveness. Research conflicts between water conservation and pest resistance/pesticide reduction.

June 2004 To Be Done – An evaluation of the effectiveness of the Program’s pesticide reduction guidance will be performed as part of the FY 02-03 and FY 03-04 Annual Reports.


Attachment 1-1

Attachment 1-1

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1

ON-GOING CONTINUOUS IMPROVEMENT ITEMS Table 1-2 provides an update on the status of ongoing continuous improvement tasks identified in previous fiscal years. Items that were noted as completed or on-going in Table 2-6 of the FY 01-02 Annual Report have been removed from the list, and any schedule changes are noted on the table. Work will continue on these remaining improvement tasks and the results reported in the FY 02-03 Annual Report. The Program’s focus during FY 02-03 was on implementing new requirements of its NPDES permit and less on continuous improvement of existing Program elements. For clarification, no new continuous improvement items were identified for FY 02-03 (see Section 1 of FY 02-03 Work Plan).

Table 1-2 Status of Ongoing

Program Continuous Improvement (CI) Tasks

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Task Updated Schedule1 Status Evaluation of

Effectiveness

Remaining FY 99-00 CI Tasks – Program Management

6. Send letter to contractors who received Construction General Permit Binder, explaining that the binder is being revised and contractors should reference the Regional Board’s Erosion Control Field Manual. (Priority- Medium)

December 2003 In Progress –In the near term, the Program will focus on outreach to developers regarding Provision C.3., but this will be followed by completing the guidance to contractors. The Program will send letters to contractors in its database, plus any additional names provided by the Co-permittees, about availability of completed Program guidance materials.

Cannot be evaluated at this stage. Will obtain feedback from contractors as to the usefulness of the binder through an evaluation form or survey following distribution of the binder.

9. Consider developing, with the help of an ad hoc task group, a fact sheet addressing common construction BMP problems, like drain inlet protection and dewatering. (Priority – Medium)

June 2003 In Progress – Management Committee approved having the Program adapt an existing brochure on dewatering (created by Palo Alto, Mountain View and San Jose) for the other Co-permittees’ use. Program staff are in the process of arranging for the adaptation and printing.


11. Investigate the issue of maintenance and durability of porous paving materials. (Priority – Medium)

June 2003 Update -- Program staff will collect information on experience with these materials, including effectiveness of Co-permittee “pilot projects”. This information will be made available to the Co-permittees as part of the guidance developed by the Program to meet the C.3. provisions for new and redevelopment controls.


12. Work with Regional Board staff to provide guidance on: 1) approaches to plan review; and 2) requirements and acceptable alternatives for post-construction controls. (Priority – High)

June 2003 Update – Program staff will present guidance on plan review and information on post-construction controls as part of the guidance developed to meet the C.3. provisions.

Cannot be evaluated at this stage. Was discussed during performance reviews this fall (see FY 03-04 CI tasks)..

1 See FY 01-02 Annual Report for previous version.





Effectiveness

15. Look into providing storm water training to building officials through the Peninsula Chapter of Building Officials monthly training sessions. (Priority –Low)

June 2004 Update – This item is low priority, and has been delayed due to Program staff’s focus on higher priority items. It is now more appropriate to provide training following completion of the C.3. guidance.


Remaining FY 99-00 CI Tasks – PI/P

Independent Pool and Spa Service Association Presentations – investigate alternatives to the filter backwash BMP in the Program’s pool brochure, and consider developing a bill insert for educating pool owners.

June 2003 In Progress – This item will be completed as part of the Pool Pump Magnet Project, which is now focused on reprinting the brochure instead of developing a magnet. Language in the brochure was changed to address the filter backwash BMP. The distribution plan has not yet been developed.

Cannot be evaluated at this stage. Will obtain feedback from pool service contractors and pool owners following distribution of the brochure.


2. Work with Co-permittees to finalize the draft Section 6.7.2, “Comparison of Development Policies” of the SCBWMI Watershed Characteristics Report (WCR) and provide guidance for strengthening local land use policies. (Priority – High)

January 2003 Completed – The Development Policies Comparison Project, which consisted of reviews of Co-permittee policies, codes, and ordinances and comparison to a checklist of desirable element for watershed protection (and compliance with C.3.), was completed in January 2003. The draft sections were distributed to individual Co-permittees for review, and their comments incorporated. It is now being reviewed by the WMI LUS.

Effective – Responses from Co-permittees involved in review meetings have indicated that this review process has been useful in helping them identify changes that need to be made in local policies, codes, and ordinances to meet the Provision C.3. requirements.





Effectiveness

3. Provide guidance to Co-permittees on requirements for temporary non-stormwater discharges to storm drains.

pending Update – Co-permittees have requested assistance from the RWQCB staff with determining under what conditions temporary non-stormwater discharges are allowed to flow to storm drains. To date, RWQCB have only provided guidance in individual letters to contractors.

Cannot be evaluated at this stage. Waiting for direction from RWQCB staff.

6. Conduct a workshop for municipal staff based on the municipal training protocols being developed by an ad hoc task group. (Priority – Medium)

June 2004 In Progress- – Four municipal training protocols have been developed. One additional protocol on Mercury Pollution Prevention to be developed. Upon completion and approval of funding Co-permittees, planning will begin for the workshop. The workshop will be held during FY 03-04. (The workshop is a lower priority than those for needed for new development topics.)



3. Develop formal mechanism with RWQCB to distribute NOI lists. (Priority - Low)

Ongoing Ongoing – Program staff are downloading and converting the databases into useful spreadsheets with NOI information. The spreadsheets are posted on the SCVURPPP website (www.scvurppp.org) for Co-permittee review and use. The NOI lists are updated on a quarterly basis.

Effective – This has been a useful service to the Co-permittees.

4. At the completion of the performance review meetings, compile list of continuous improvement items that relate to restaurant inspections and meet with County Department of Environmental Health staff to discuss. (Priority – Medium)

December 2003 In Progress – Program staff plan to conduct a meeting with County DEH, restaurant inspectors and Co-permittee staff to reinforce inspection expectations, improve communication and coordination, and discuss their use of Program outreach materials.


http://www.scvurppp.org/





Effectiveness

5. Provide guidance to co-permittees on recommended education approach and BMPs for targeted industries identified in IND-2 final report. Determine whether additional steps should be taken per the Copper Action Plan. (Priority – Medium)

December 2003 Update – City of San Jose staff have the lead. Program staff will work with City of San Jose staff to prepare guidance as part of follow-up to the IND-2 outreach project (SC25.12). Due to significant City of San Jose (CSJ) staff changes over the past year, the project has been delayed. New CSJ staff has been assigned and the work rescheduled (see CSJ Work Plan).


6. Conduct follow-up to Mobile Polluter Database Feasibility Study. (Priority - Low)

December 2003 Update -- Program staff will address this as part of ICID data management and continuous improvement tasks.


9. Explore mechanisms to provide outreach and BMP information to concrete workers and saw cutters in Santa Clara County (private and municipal). [Added per RWQCB comments on FY 99-00 Annual Report, 3/27/01]

March 2003 Completed – The Program worked with the BASMAA New Development Committee to implement the Regional Construction Education Program III, which is focused on outreach to subcontractors, specifically concrete workers, saw cutters and painters. Products developed include: construction BMP plan sheet, water quality protection language for municipal contracts, illicit discharge prevention cards, and a brochure on proper saw cutting techniques. A mailing of the information to the problem subcontractors was completed.

The final products have been received on CD and will be distributed to the Co-permittees.






Effectiveness

Remaining FY 01-02 CI Tasks – PI/P

2. Review and update the review process established for the Watershed Education and Outreach Campaign.

March 2002;

Next update: June 2003

Completed in FY 01-02. However, the table listing review required for each product needs to be updated as part of development of each year’s work plan.

Effective – The established process has been useful for guiding the levels of review needed for campaign products.

Needs Improvement – as described under “Status”.

3. Support Co-permittees efforts to document and assess the reach of existing schools outreach programs.

September 2003; Ongoing

Completed/Ongoing – Regional Board staff requested Co-permittees to document existing outreach to schools on watershed awareness and pollution prevention, which schools were receiving the outreach, and which schools were missed, and include it in their annual reports. Tables with information on Co-permittee efforts are provided in Section 9 of the Program’s FY 01-02 Annual Report. A work group is currently working with the City of San Jose to develop GIS map layers to show the distribution of existing outreach.






Effectiveness

Remaining FY 01-02 CI Tasks – Data Management

7. Follow up on monitoring project results and recommendations.

Ongoing (New projects

incorporated as part of Annual Work

Plans);

Ongoing –Results and recommendations from Program monitoring projects are incorporated into the continuous improvement items list, where progress made can be tracked. Table 4-1 (contained in each Annual Report) is used to update and track monitoring projects. Table 4-2 is used to track all projects, including monitoring projects and products. All major reports and work products are on the SCVURPPP website.

Effective – This process has been effective for tracking the progress and completion of monitoring projects.

Needs Improvement – A process (e.g., a table containing a summary of recommendations from completed projects) is needed to prioritize follow-up monitoring projects.

Remaining FY 01-02 CI Tasks – Trash

1. Conduct trash assessment planning activities.

Ongoing Completed– Trash Work Plan was submitted in FY 03-04 Work Plan (as an attachment in Section 4)

Ongoing- Program staff will complete relevant Trash Work Plan tasks; continue to plan and organize Trash AHTG meetings to facilitate review and approval of Program work products; and attend one to two “Pick-Up San Jose” Technical Advisory Committee meetings each year.

Effective – The Trash Work Plan provides the Program’s strategy for investigating the extent of the trash problem and possible solutions (prior to permit requirements being established for trash management).

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