|
Through the successful
collaboration of the various branches in the Permitting and Enforcement
(P&E) Division, a set of “triggers” was established with the main
purpose of determining the appropriate time to initiate the offer of assistance
to Local Enforcement Agencies (LEA). These triggers are intended to flag
trends in an LEA program’s performance of duties; thereby, giving California
Integrated Waste Management Board (CIWMB) staff reasons to offer assistance to
the program should the trend indicate a gap in performance. Subsequently,
staff conveys the trend to the LEA along with the offer to assist. Triggers will not be used to evaluate programs. Contrarily, they can be
used to reinforce the components needed to maintain a successful program.
The triggers will be
available to LEAs so that they are aware of the same type of data that CIWMB
staff will use in the assistance mode. Although many situations are
handled on a case-by-case basis, the triggers allow staff and the LEAs to
understand common goals in the shared programs. At any point, the list can
be adjusted to best fit the regulatory requirements and data systems.
-
Are permitted, illegal, inactive,
abandoned, and exempt sites inspected according to the required regulatory
frequency?
-
Does the LEA send inspection reports to
the CIWMB within 30 days?
- Does the LEA represent inspections
correctly?
-
Does the LEA fill out inspection forms
correctly?
-
If there are written complaints, is the
LEA following up appropriately?
Top of Page
-
If any of the LEA’s sites are on the inventory of solid waste facilities
violating State Minimum Standards, has the LEA issued a
compliance schedule within 15 days and is following up appropriately?
-
The LEA may not be taking appropriate
enforcement action.
-
Is the LEA writing enforcement orders
correctly per CCR, Title 14, Section 18304?
-
Is the LEA enforcing orders?
Top of Page
-
Is the LEA submitting complete and/or
correct packages per CCR, Title 27, Section 21685 and for tiered permit process?
-
Are permit review reports and
reissuances prepared adequately and submitted as required?
-
Is the LEA preparing and issuing
permits/RFI amendments according to the time frames?
-
Is the LEA identifying and pursuing
permits for active unpermitted facilities?
-
Is the LEA properly processing
owner/operator changes and/or RFI amendments per CCR, Title 27, Sections 21665
and 21670?
-
Is the LEA pursuing permit revisions as
identified in the permit review report or during inspections?
-
Is the LEA providing evidence of the
required findings for permit/CEQA/RFI amendments correctly?
Top of Page
-
Have sites within the LEA's
jurisdiction met applicable closure/postclosure requirements?
-
Are closed sites within the
jurisdiction inspected quarterly or at an approved Site Identification Process
(SIP) frequency?
-
Are any closed sites not
maintaining compliance with closure/postclosure requirements as reported on
closed site inspection forms?
-
Are appropriate enforcement actions
taken for facilities not complying with closure regulations?
-
Are any sites in the LEA’s
jurisdiction listed for non-compliance with closure requirements?
-
Is the LEA assessing closed, illegal, and abandoned sites that need to be
investigated?
Top of Page
-
Are there any changes in the
designation or responsibility of an LEA that may result in a conflict of
interest?
-
Is the LEA maintaining the staff
technical expertise and levels identified in its EPP?
-
Does the current budget indicate
adequate resources?
-
Is the EPP updated annually as
required?
-
Are training requirements being met?
-
Is the EPP facility/site
enumeration consistent with SWIS? If not, Certification staff will
forward discrepancies to the appropriate Permitting and Inspection or Closure
staff contacts to reconcile SWIS with the LEA's updated information.
Note: All P&E Division branches will coordinate issues. When assistance is given to the LEA by CIWMB staff other branch contacts are
notified so that other issues can be coordinated (as needed) at the same time
Top of Page
|
