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Based on the results of the inspections or as requested by the City, EEC will investigate and respond to <br />infractions or complaints related to the City's NPDES permit and the City's Water Pollution Regulations. In <br />the event that inappropriate material or waste handling or storage practices are observed; there is evidence <br />of past or present unauthorized, non-storm water discharges; if BMPs are determined to be ineffective in <br />eliminating storm water exposure; or if applicable plans have not been prepared or maintained, including <br />SWPPPs and spill response plans, EEC will determine if an enforcement order is required. EEC will <br />coordinate with the facility to remedy noncompliance and conduct re-inspections that are adequate to bring <br />the facility into compliance. Administrative remedies administered by EEC may include verbal or written <br />notices of noncompliance. If necessary, administrative compliance orders or cease and desist orders will be <br />coordinated with the City. Sample enforcement correspondence that was developed by EEC for the City of <br />Stanton is provided in Appendix C. <br />Subtask 3: Additional Program Assistance as Needed <br />EEC will provide additional technical and regulatory assistance related to the Overall NPDES Program as <br />requested by the City. This may include special inspections as they occur, updating handouts for BMPs, <br />translation of materials into other languages, and other tasks related to improving the City's NPDES <br />Program. This task will also include response and representation on discharges on the City's behalf. EEC <br />will act on the City's behalf to ensure proper response and cleanup of discharges (into the public right of <br />way) are accomplished according to NPDES permit requirements. EEC inspectors will develop an on-call <br />schedule that will ensure at least one inspector is available, 24/7, for immediate illegal discharge response. <br />EEC inspectors are familiar with the proper NPDES inspection procedures and have reviewed the County of <br />Orange's training program documents (e.g. IDIC training). EEC inspectors are also trained on the proper <br />response procedures for responding to emergency discharges or discovered NPDES violations. EEC <br />inspectors will attend any available training courses deemed appropriate through the County of Orange or <br />the California Stormwater Quality Association (CASQA). <br />EEC - Santa Ana NPDES Proposal T 5 D A March 3, 2011