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compliance management. The GIS will have digital representation of all facilities in the program that are <br />within the City's service area, as demonstrated in the figure above. The GIS will also comply with Sections <br />IX and X of the NPDES Permit Requirements. <br />EEC will manage and execute all data and submittals pertaining to the Commercial/Industrial Facility <br />Program as required by Section I of the NPDES Permit Requirements. EEC will also participate in periodic <br />meetings with the City to provide updates on the progress of inspections, discuss enforcement issues, and <br />provide suggestions for improving the Inspection Program based upon field experience and maintaining the <br />Prioritized Facility Inventory. EEC will assist in the long-term management of the inspection program and <br />update the Prioritized Facility Inventory with information from the City's most current business license <br />database. EEC will provide the City with bi-weekly status reports via email and summary status reports with <br />the monthly invoices. <br />Subtask 2: Conduct Facility Inspections, Inventory Management, and Enforcement <br />Notifications <br />EEC will conduct on-site facility inspections as outlined in the City's NPDES permit. As part of the facility <br />inspections, EEC will assess indoor and outdoor areas associated with stormwater runoff and conveyance <br />and review the following: material and waste handling and storage practices; written documentation of <br />pollutant control BMP implementation, including internal inspection logs and reports, SWPPPs, and spill <br />response plans; maintenance procedures; implementation of source control measures; and digital <br />photographic documentation of any water quality violations, as well as evidence of past or present <br />unauthorized, non-storm water discharges and enforcement actions issued at the time of inspection. Sample <br />inspection forms aare included in Appendix B. EEC will also conduct personnel interview(s) to develop a <br />general assessment of the awareness of storm water pollution prevention measures by facility management <br />and employees. EEC will prepare an inspection report that assesses the facility's potential to impact storm <br />water quality and the effectiveness of BMPs to minimize pollutant exposure. The facility officials will be <br />informed of any required follow-up activities and all results will be entered into the City's NPDES database. <br />EEC - Santa Ana NPDES Proposal 125D-1 1 March 3, 2011