IDNR - Complaince Rep WPCP Fields of Opportunities
THOMAS J. VILSACK, GOVERNOR
SALLY J. PEDER$ON, LT. GOVERNOR
STATE OF
IOWA
DEPARTMENT Of NATURAL RESOURCES
JEFFREY R; VONK, DIRECTOR
September 28, 2001
City of Dubuque
City Hall
50 W. 13th Street
Dubuque, IA 52001
ATTENTION: Mayor and Council
RE: Industrial Pretreatment Compliance Inspection
Facility No. 31-26-0-01
We have enclosed the inspection report prepared by our Field Office Staff and a copy for your
Industrial Pretreatment Coordinator.
You will find the inspection report self-explanatory. Dubuque continues to run a fine quality
pretreatment program with no significant deficiencies or areas of concern.
Should you have any questions, do not hesitate to write or call this office.
Sincerely,
ENVIRONMENTAL PROTECTION DIVISION
Doug A. Hawker
Environmental Specialist
Encs.
cc: Pretreatment Coordinator- Jori Brown
DNR - Wastewater Section - Des Moines
Paul Marshall ~ U.S. EPA, Region 7, 901 North 5th Street, Kansas
City, KS 66101
Field Office 1, 909 West Main Suite 4, Manchester, IA 52057
563/927-2640 FAX 563/927-2075
ENVIRONMENTAL PROTECTION DiViSiON
MICHAEL VALDE, ADMINISTRATOR
909 west Main; MancheSter~ ;Iowa 52057
phone: (563) 927-2640 FAX: (56~) 92~-2075
REPORT OF INVESTIGATION
INVESTIGATION DATE CURRENT: 9-19-01
LAST: 9-18-00
TO: City of Dubuque, City Hall, 13th & Central, Dubuque, IA 52001
RE: Dubuque Industrial Pretreatment Compliance Inspection
Permit# 31-26-0-01
PERSONS CONTACTED: Jonathan Brown - Assistant Plant ManagedPretreatment Coordinator
Distribution: Field Office: Central Office: Inspected Facility:
Paul Marshall, U.S. EPA, 901 North 5th Street, Kansas Cit~/, KS 66101
AUTHENTICATION
INSPECTOR: .~.~-~ ..~../~..~.~,,~ /,/~ . ~'-Z o~' o /
Doug A. Hawker, Environmental Specialist
REVIEWER: DATE:
Doug A. Hawker, Environmental Specialist
File Name: DubuquePTpci01.doc
On September 19, 2001 I performed an Industrial Pretreatment Compliance Inspection (PCI) of the City of Dubuque's
Industrial Pretreatment Program, The following is a list of comments relating to the attached Pretreatment Compliance
Inspection (PCl) checklist which covers the Calendar 2000 time period.
PLANT DESCRIPTION:
Wastewater from Dubuque and it's industrial contributors is treated by a high purity oxygen activated sludge WWTP. This
facility has a 30 day average design capacity of 15 MGD and a daily maximum design capacity of 34 MGD. Sludge is
routinely incinerated and the ash is stored in a pair of ash storage lagoons on site.
OBSERVATIONS/RECOMMENDATIONS:
2:
3.
Dubuque's Industrial Pretreatment Program has remained essentially unchanged since last year's inspection. The
biggest change in 2000 was the closing of Farmland Foods in June 2000. This will drop the number of significant
industrial users (SlU's) from 17 to 16 for 2001. Losing Farmland Foods has dropped the percentage of industrial flow to
the POTW from 30% to 8%.
Currently, Dubuque does not receive any hauled waste from outlying jurisdictions. The City does receive about 100 loads
per month from private septage haulers. There were no problems with these haulers in 2000.
The City is currently working on revising local limits. These have been submitted to DNR once for review, been returned
with comments, and have now been revised, it is now time for these revised limits to be resubmitted to Steve Williams of
the DNR Central Office for final approval.
4. The City's last formal Industrial Waste Survey (IWS) took place in 2000. There were no new SIU's identified and no
significant changes to the current industrial wastewater discharges.
ENVIRONMENTAL PROTECTION DIVISION
MICHAEL VALDE, ADMINISTRATOR
When the Farmland Food facility was purchased by Gold Label Meats, a subsidiary of John Morrell, it was anticipated that
they would reopen the packing plant with some form of specialty production. To date, this has not happened and it now
appears doubtful whether this will occur at all. Needless to say, this has opened up a large amount of available treatment
capacity by the Dubuque municipal WWTP that is available to current industries and potential future industries.
All "wet" industries are required to have slug control plans while all the "non-wet" categorical industries are not required to
have such a plan. The City of Dubuque has determined that any type of slug discharge from their categorical industries
would not be significant enough to warrant the industries having such a control plan.
7. The City continues to do all the monitoring for all their SIU's thereby allowing the City to be aware of any discharge
violations even before the industries are aware of this themselves.
Overall, it appears that the compliance record of Dubuque's SlU's has been very good throughout 2000. There have not
been any instances of Significant Non-Compliance by any industry for the past couple of years. During 2000, one written
notice of violation (NOV) was sent to AIH (a categorical industry) for minor discharge violations, and a total of 16 written
NOV's were sent out to three non-categorical industries, SKVV Gelatin, Inland Protein, and Swiss Valley Farms.
The two SlU's with the highest number of minor permit violations continue to be SKW Gelatin and inland Protein. The
City is encouraged to continue working with these two industries to obtain better overall compliance. It is noted that SKW
may need to renegotiate their current pretreatment agreement with the City in the near future as they revise their current
disposal practices of "Stix" water. They currently land apply this high strength wastewater on area farm ground but are
being required by DNR to revise this practice.
CONCLUSIONS AND RECOMMENDATIONS:
Dubuque WWTP personnel continue to operate a quality industrial pretreatment program. No significant areas of concern were
noted during the course of this inspection. As noted in the text of this report, it is important that the City submit their revised
local limits to Steve Williams of the DNR Central Office for final approval. This should be done immediately.
The City should also keep in close contact with SION Gelatin officials regarding the future disposal of the company's Stix water.
The time and cooperation of Mr. Jonathon Brown during the course of this inspection was appreciated.
PCI
Date(S):
'~
JUN -4 2001 LYJ
DN~,-E?D-F.O.1
.ent Compliance Inspection
FY 2001
POTW:
Address:
Contact:
Title:
Phone:
Fax:
CITY OF DUBUQUE
13TH AND CENfRAL
DUBUQUE
IOWA 52001
JONATHAN BROWN
ASST. PLANT MANAGER
319-5894176
319-5894179
Date of last PCI/Audit:
09/18/00
NPDES Permit No.:
IA 004d458
State Permit No.:
31-26-0-01
Expiration Date:
07/14/03
Partici )ants
POTW: .-To~.ik~,, ~.~ Inspectors:
Period covered by this PCI/Audit: C
POTW Information
Total for ALL Treatment Plants (MGD)
Design Daily Ave. 'Actual Daily Ave. Design Peak: % Industria/~,Flow:
13.39 10 34 ...,30" g'7,
Number of Plants: % Combined Sewers: Type of Treatment at PrincipaI Plant:
I NONE 02 AS
Sludge Disposal Method: Quantity (dry/tons/Y): Receiving Stream:
INCINERATION 4200 MISSISSn~PI R.
closed
PART I: PROGRAM BACKGROUND INFORMATION
LA. Approved Modifications to the Original Program
1.
Date of last NPDES permit modification: Date of original Program approval: 09/29/83
07/18/98 Date NPDES Permit originully
modified to require implementation
[PTIM]: 09/29/83
Approved Pretreatment Program modifications:
REQUIRED APPROVAL OTHER APPROVED APPROVAL
MODIFICATIONS DATE MODIFICATIONS DATE
PIRT SUO Revisions 05/13/93
List of SIUs [403.8(0(6)1 03/01/92
Enforcement Response Plan 09/15/94
DSS SUO Revisions 05/13/93
LOCAL LIMITS 1983
3. Is the POTW presently working on any program modifications? /-ocli
4. Does ~e PO~ have ~y pro~ modificafio~ c~renfly berg reviewed by ~e Approv~ Au~ori~
I.B~ Approved Program Coments
5. Authority to enforce Pretreatment Standards contained in:
ART. 2, DIV 6, CH 44
6. Date enacted or adopted: 08/15/93
7. Approved Control Mechanism: PERMITS
2
8. What is the frequency required by the approved program/modifications for:
Non-
Activity categorical Categorical
SIUs SIUs~
POTW sampling of: DAILY 14/Y
POTW inspection of: 1/Y 1/Y
SIU self-monitoring: NA NA
S1U reporting: NA NA
9. What types of enforcement options are available through the approved program:
10. COMMENTS:
Y Notice of Violation (NOV)
Y Administrative Order (AO)
Y Show Cause Hearing
Y Establishment of Compliance Schedules
Y Revocation of Permit
Y Injunctive Relief
Y Fines; Maximum $1000/day/violation
N Criminal Penalties
Y Termination of Service
3
PART H: INTERVIEW QUESTIONS
ff.A~ Legal Authority and Jurisdiction
11. Have any Pretreatment modifications been made to the Sewer Use Ordinance since the last PCl/Audit
that have not been approved by the Approval Authority.
12. List by name and location any SIU~ that discharge to the POTW from outlying jurisdicffons.
NA
Indicate which of the above are nor covered by a contract/agreement requiring them to abide by the
POTWs legal authority.
13. Does the POTW have the authority to seek fines up to $1000 per day? [403.8(f)(1)(vi)]
YES
14. If the POTW bas not yet developed an Enforcement Response Plan when does the POTW feel it will
complete this requirement?
15. COMMENTS
II. B. Control Mechanism
16. General Information:
Type: PERMITS
Duration: 3 YEARS
17. Do all SIUs have current (unexpired) control mechanisms? {NOCM}
Issued to Noncategorical SIUs? [DSS: 403.8(f)(2)(i)]
YES
18. List by name those that do not and indicate which ones have not had a current control mechanism .
for 180 days or more; {RNC/SNC} Iq/~
4
II.c. HaUled WasteS
19. Does the POTW accept hauled waste? (If "no," go to question 25)
YES
a. if so describe (include approx, no.' of loads per month):
100/MO
b. How does the POTW ensure that it does not accept hazardous waste?
MANIFESTS
20. Does the POTW have a control mechanism for regulating waste haulers, and if so describe.
YES
21. Does the POTW have a designated discharge point (or points) for waste haulers? [DSS: 403.5(b)(8)]
Describe: YES
22. Are all applicable Categorical standards and Local Limits applied to IUs whose wastes are hauled
23. Describe the method used to apply local limits to hauled waste.
kJo 1'~ ~,Je~
24. COMMENTS:
II.D. Industrial User Characterization
25. How often does the POTW update its Industrial Waste Survey (IWS) to identify new S1Us or changes
to wastewater discharges?
a. Whenwas thelast formal update: ~
5
2~. What is the POTW's current industrial base?
Last
Current Industrial User Type Reported
Categorical SIUs
(~ {cms} 6
/o Non Categorical SIUs ............
Total all SIUs
/(~ {SWS} ~7
II.E. Local Limits
27. Does the POTW have numerical limits for metals in its NPDES permit? If so list the metals and the
limits (or attach lis0.
NONE
28. Have there been any numerical NPDES permit violations in the last 12 months?
a. Were any of the numerical NPDES violations, identified above, a result of interference or pass
throu~? h/o
1. Was the interference traceable ro an industrial user?
2. Was action taken that led to elimination within 90 days of the interference or pass through?
{sNc~ ~/~
3. Was the responsible industry placed on an enforceable compliance schedule within 90 days
6f discovery? {SNC} If not, why?
29. How many times per year does the POTW regularly sample its PRINCIPAL plant for the following?
Parameter [ Influent [ Effluent [ Sludge
Metals 1 1 4
~ro×ic Org~ ){ ~ tr ~ . X t
Biomoultoring
TCLP
:.: :~!:~+~ :~:::: i:!:,:: ::::::::::::::::::::::::::::
30. List below the numerical value for the local limits derived by technical analysis. If a technical
analysis was performed but the limit not adopted enter DNA in the block. (Values assumed ro be
rog/1 unless otherwise noted). {EVIL} {ADLL}
Comments:
t~OLLUTANT DAILY MAX POLLUTANT DAILY MAX
ARSElqlC .04 LEAD .20
CADMIUM .01 MERCURY .01
CItROMIUM .7 NICKEL A
COPPER .2 SILVER .1
CYANIDE 5.0 ZINC .5
TOLUENE 500 O&G 100
PItENOLS 2.5
31. Are the POTW's BOD and TSS limits technically derived (ie. based on plant capacity)?
32. Are BOD and TSS violations treated as violations 'of technically based local limits?
YES
33. If them is more than one treatment plant, were the local limits established specifically for each plant?
NA
34. Has the POTW made any changes to its Local Limits which have not been approved, and if so
provide details. [403.181 N o
35. Has the POTW granted any Net/Gross allowances under 403.157 NO
7
II.F. Standards and Requirements for Industrial Users
37~ Does the POTW compare local limits against federal Categorical standards and apply the most
stringent standards to Categorical 1Us? [403.4]
38. Has the POTW notified its IUs of possible RCRA obligations? [40 CFR 40J.8(0(2)1 YES
39~ Does the POTW allow Categorical users to use Solvent Mansgement Plans/certification or surrogate
test procedures to meet TTO requirements? ~es,
II.G. POTW Compliance Monitoring and Inspections
40. What is the current frequency for:
NOll-
Activity categorical Categorical
SIUs SIUs*
POTW sampling of.' 300/Y 1-4/Q
POTW inspection of: I/Y 1/Y
SIU self-monitoring: NA NA
SIU reporting: NA 1/M
41. List exceptions:
42. List those SIUs that were not sampled by the POTW within the last 12 months. [DSS: 403.8(f)(2)(v)]
43. List those SIUs that were not inspected within the last 12 months. [DSS: 403.8(f)(2)(v)l
44. How msny industries were neither sampled nor inspected within the last 12 months. [DSS: 403.8(f)(2)(v)]
{NOn~r}{m~c~s~c}
45. Does the POTW sample its SIUs for all regulated pollutants at least once annually? [405.8(0(2)(v)]
8
46. Sample/Analysis Precedu~es:
Chain-of-Custody always used?: YES [ Sampling method, metals: TIME/FLOW COMP
Ability to sample on short notice? YES Sampling method, CN: GRAB
In-house analysis of toxic pollutants: CN,METALS Sampling method. O&G: GRAB
Do in-house analytical methods conform to 40 CFR pan 1367 YES
47. How does the POTW document its industrial user inspections? [NSP. FORM
48. Does the POTW evaluate all SIUs at least every two years ro determine the need for a slug
discharge/spill control plan? [DSS: 403.8(0(2)(v)1'
a. Describe the method used by the POTW to evaluate the need_ for a slug control plan.
II.H. IU Self Monitoring and Reporting
49. Are all Categorical IUs required to self-monitor for all pollutants regulated by the respective
Categorical standardatleasttwiceperyear? [403.~2(e)1 ~es- do,,, /,?, ¢,-~
50. Were any Baseline Monitoring Reports or 90 day Compliance Reports due within the pas~ 12
months? If so, from whom? Were the reports submitted?
51. Are IUs required to report spills, slug discharges, etc. to the POTW? [403.12(f)1 ~e ~
52. Are IUs required to report violations within 24 hours of knowledge of the violation? [403.12(g)(2)]
53. Are IUs required to resample and subfi~it' cesults-within 30 days following a violation as per
403.12(g)(2)? /y//} (2.g-/ dots ~,.~l! ~a~,~,l:,,~
H.I. Data Management
54. Are files/records computerized? YES
a. Does the POTW use EPA's PCME software package? NO
55. Are all records maintained for at least 3 years? [403.12(o)1 ~ $
56. Are program records available to the public as required by 40 CFR 403.t4(b)? ties
57. Does the POTW have provisions to address confidential business information? [4o3.14(a)]
58. How is compliance status calculated? Describe the procedure used in determining Significant
NOncompliance (eg. are mo; avg. violations considered as well as daffy max?).
~,¢,,:~.s Md. ~,~:l7 r~lol'~ ,~,t
II.J. Program Resources
59. What percent of the .Pretreatment Coordinator's time is spent on pretreatment? 15-20%
60. What computer programs does the POTW use for:
Wordprocessing: WORD 97
Spreadsheet: EXCEL 97
Database: ACCESS 97
61. Does the POTW believe its annual budget adequate for implementation? ~$-
a. If not, is the level of money available for pretreatment less than that in the approved program
or approved modification?
II.K. Special Questions
62. Are there any issues that the POTW would like to discuss?
10
PART IlI: FILE AND RECORDS-REVIEW
Following is a table containing the POTW's Significant Industrial User inventory regulfitecl by its Pretreatment
Program. PleasE verify that all information in the table is correct and current. For those industries no longer
regulated draw a line through the enuy. Add all new industries and provide the information sought by the table.
Below is a guide to the information sought by the table and suggested abbreviations.
INDUSTRY:
Provide the name of each industrial user regulated under the prerreannem program.
CAT STND:
Provide the categorical standard code number. For example, industries subject to the Metal Finishing
regulation should be designated "433." For noncategorical industries indicate "NA" in this column.
REG PROCESS:
indicate what process the industry performs to qualify for inclusion in the prerreamaen~ program. For example,
if an industry is subject m Metal Finishing regulations because it performs zinc and chromium plating indicate with
"ZnCrPL'~ or a slmil~r abbreviation.
TMT:
If the facility rream its wastestream(s) indicate "Y." If no treatment is provided indicate "N."
TYPE:
Indicate the type of pretreatmenr system (if applicable) the industry has. Suggested abbreviations: "precip"
for precipitation/clarification; "precp/flff for precipitation followed by filtration: "DAF" for dissolved air flotation;
PEG FLOW:
Provide the industry's average daily flow for its re~mflated processes in gallons per day. The abbreviation "I<2"
stands for I000.
TOT FLOW:
Provide the average daily total plant flow in gallons per day.
indicate if the industry uses the Combined Wastestream Formula to determine compliance with categor/cal
standards. "Y" = yes, "N" = no.
COMPLIANCE STATUS FOR THE 6 MO PERIOD ENDING:
For the six month periods listed, indicate if the indust~y's compliance states. Use the following abbreviations:
C
I
SNC,S
SNC,R
SNC,M
SNC,C
In compliance with all standards: no violations.
Infrequent noncompliance with discharge standards: the facility had some violations but not severe
enough to be considered in significant noncompliance.
In significant noncompliance with discharge standards.
In significant noncompliance with reporting requirements: the industry failed by greater than 30
days to submit reports as required.
In significant noncompliance with self monitoring requirements: the industry dkl not properly'
report its compliance status on its self monitoring report.
Failure to meet a compliance schedule milestone by 90 days.
LAST INSPECTION:
Date of the last inspection performed by the POTW.
1I
8]ECTION VIII SIGNIFICANT INDUSTRIAL USERS DUBUQUE, IOWA
T C Compliance Status for Six Month Period
Cat M W Ending: Last
Stnd Reg Process T Type Reg Flow Total Flow F Inspection
Industry Name JUN'99 DEC'99 IUN'00 DEC;00
A,Y, MCDONALD NA BRASS VALVBS N NO DISC < 10K NA C C C C~ ~' 2 8 '* do
AUTOMOTIVE INDUSTRIAL HARDWARE 433NS CuNiCrPL Y EVAP 2K N C ! ~/ ~ ~. ]~2 -/g' - Go
DBBUQUE COUNTy LANDFILL NA LEACHATE N 15K NA C C C P.
DUBUQUE HARBOR SERVICE NA BARGE CLEAN Y SETTLING 20K NA C C C C
DBBUQUE STAMPING & MFG NA CN HEAT TRT N ~[}K 40K N C C C C [t~ ~ ? ~ 0o
EAGLE WINDOW AND DOOR 433NS CrCC Y CrDST1UPRCP C C C C I~. ~ ?' GO
FLI]XSTEBL 433 PeP}lOS N 6-10K 10K N C C C ~
HANDEX NA GSLN CLNUP Y AIRSTRIP NA C (~
INLAND PROTEIN NA DRYBLOOD N I~"O ~ NA I I I I
KEY CITY PLATING CO. 413 CuNZCrPL N 5K 8K N C C C C I~,
KLAUER MFG. 433 PHOS N 2-3K N C C C (.
MIDWIEST GAS NA GW RMDTN y 188K/Q NA C (
NEWT MARINE SERVICE NA BARGE CLN y STTL NA NO DISC NO DISC NO DISC ~/a ~f't¢
SKW NA GELATIN Y DAF/pHADJ 180K NA I I 'f I].- Iq- GO
SWISS VALLEy FARMS NA MILK 200K NA C C C .~ /g~O. O0
THERMOLYNE (BARNSTEAD) 433 PHOS Y pHADHDSTL 3K N C C C C IZ ~ f~ ' GO
I]IILB. Significant Industrial User' Compliance Evaluation
63. From the above list of industries, how many are in Significant Noncompliance (SNC) with either
discharge standards or reporting requirements based on the most recent six-month reporting period?
64. List by name, those industries currently on a compliance schedule. Complete the table below.
65. List those industries last published in the newspaper for noncompliance and provide the date (or
attach a copy of the public notice).
66. If an industry has been deleted from the list of Significant Industrial Users list by name below and
providethereason. F~....l~,,,.t ~,d~ ' .g*(d a..,,t
67. For those industries in SNC within the last 12 months complete the following table for all written
enforcement actions. No n ¢
IU Name Violation Date of Date of Enforcement ERP required
POTW Action Action actiOn
knowledge
/
13
68L Provide .the total number of NOVs, Administrative actions~ Sudicial referrals, and criminal
prosecutions that occurred in the last twelve months. {FENt} {JUDI}-
69. Were all actions taken by the POTW within 30 days of knowledge of a violation? {RNC/SNC}
70. Did all industries in SNC either remm to compliance within 90 days, receive escalated enforcement
action by the POTW within 90 days, or become placed on an enforceable compliance schedule within
90 days (of knowledge by the POTW) of the violation? {RNC/SNC}
III. C. ControI Mechanism Evaluation -
71. Do the POTWs control mechanisms: Permittee:
REQLrIRED [DSS: 403.8(f)(1)(iii)] SUGGESTED PROVISIONS
Specify duration (no > 5 ~s.):
Contain the correct discharge limits:
Specify sample type for ILl self monitoring:
Adequately identify sampling location:
Specify sampling frequency:
State applicability of civil or criminal penalties: ,/ Reserve right to revoke permit:
Stipulate reporting frequency:
Properly require records rete~on:
Specify limited transferability:
Result of this review from the last PCI/audit: ACCEPTABLE
1TI.D. Industrial Inspection Evaluation
72. Do the Industrial Inspection reports contain:
Iqame of Company contact:
Date of inspection: ./ Verification of wastewater flow rates:
Time of inspection:
Descxiplion of manufacturing process:
Description of t~atment process, if any:
Evaluation of IU's monitoring methods:
Verification of psedaction rates that would affect production based standard:
14-
I]I.E~ Slug Discharge Control Procedures
73. If the POTW has required the submittal of a Slug Control Plan does it contain: [DSS: 403.S(t)(2)(v)]
A description of discharge practices including non-routine batch discharges
__ A description of stored chemicals
Procedures for immediate notification of slug discharges with written followmp notification
__ Procedures necessary to prevent adverse effects at the POTW's treatment plant:
inspection and rnaint~nane, e of storage areas
handling and transfer of materials
loading ant[ unloading operations
control of plant site nmoff
worker mining
building of'containment structures
measures for the control of toxic organics
measures for emergency response
74. COMMENTS Alt
Iff. F. Industrial User File Review Checklists
Following are worksheets to aid in the assessment of the nature of the oversight activities and
compliance status ofthe POTW's Significant Industrial Users. When reviewing SIU files priority should
be placed on Categoric~ industries that either have a history of violations or that appear to be in
compliance but have not installed that prescribed BAT technology to consistently meet discharge limits.
While only three pages are provided the reviewer is encouraged to copy and add additional review pages
for larger POTWs~
15
Industry Name: ~:le~
Principal Potlutuuts: /~e,,~, r, u4d.t No. of Employees:
A. Does the file system for ~ industrial user contain:
Permit application
Current Permit
Correct limits in Permit
Correspondence/meeling notes/phone log
Moat recent inspection report
Evaluation for need for Slug control
Compliance status determination
POTW sampling results
Self-monitoring reports
Enforcement documentation
Solvent Management Plan
Correct application of the CWF
Slug Control Plan
B. Did the industry discharge any slug loads or spills to the POTW in the past 12 months?
[403.12(f)] N o
Immediate nofix~ication by the IU
POTW response
Follow-up written nolifi~alion
Effect on the plant
C. rn the last complete calendar year how many times did the POTW:
Sample the IU ~4 Inspect the IU
D. Were all regulated pollutants analyzed by the POTW at least once in the most recem calendar year?
E. If the industry is subject to Categorical Standards did its self-monitoring reports contain analysis for all
regulated pollutants at least once during every six month period during the last full calendar year?
F. Frequency in the IU's control mechanism for: Self-monitoring I/~ Reporting
Mechanism7
H. Did the POTW identify all IU violations from:
FO Self-monitoring __
POTW Compliance monitoring __
I. Was the IU's compliance status (i.e. SNC, Infrequent noncompliance, Consistent compliance) determined
properly? -}~$ - C~r~}e.~/~ ~ ~);,~ea
J. Complete the following table for all violations in the last 12 months. (~ tim information has already been
provided in Question 85, please indicate).
Date of Date of ERP
Date of POTW POTW Required POTW
Violation Violalion Knowledge Response Response Response
16
Principal Pollutants: 14c*.,-t r~f~la
A. Does the fiIe system for the industrial user contain:
No. of Employees: I I{~
Permit application
Current Permit
Correct limits in Permit
Correspondenee/meeting notes/phone log __
Most recent inspection report
Evaluation for need for Slug control
Compliance status determination
./ POTW sampling results
.2 Self-monltoring reports(~tf,~ d.J-.. '"'fT)
r//0 Enforcement docnmeutation
1418 Solvent Management Plan
/v//I Correct application of the CWF
~/~ Slug Control Plan
B. Did the industry dkqeharge any slug loads or spills to the POTW in the past 12 months?
[403.12(01 [qO
Immediate notification by the 1U __ Follow-up written notification
I __ POTW response Effect on the plant
C, In the last complete calendar year how many times did the POTW:
Sample the IU ~ Inspect the 1U I
D. Were all regulated pollutants analyzed by the POTW at least once in the most recent calendar year?
E. If the indusU2r is subject to Categorical Standards did its self-monitoring reports conts/n analysis for all
regulated pollutants at least once during every six month period during the last fifll calendar year?.
F. Frequency in the IU's control mechanism for: Self-monitoring I / ~n Reporting
--(7/, ,, ..~,) --
G. D~.d th~ industty comply with the s~ling and ~epo~i~ ffeqt~ncy ~eqni~ments of fts Control
IU Self-monitoring __ POTW Compliance monitoring __
I. Was the IU's compliance status (i.e. SNC, Infrequent noncompliance, Consistent compliance) determined
properly? ~ ~ Q*'"3 ;~+~- C~-~[o ],~,,*t
J. Complete the following table for all violations in the last 12 months. (ff this i~fonnation has already been
provided in Question 85, please indicate).
Date of Date of ERP
Date of POTW POTW Required POTW
Violation Violation Knowledge Response Response Response
17¸