Wastewater pretreatment reportCITY OF DUBUQUE, IOWA
MEMORANDUM
January 12, 2000
TO:
FROM:
SUBJECT:
The Honorable Mayor and City Council Members
Michael C. Van Milligen, City Manager
1999 Pretreatment Compliance Inspection Report
Water Pollution Control Plant Manager Paul Horsfall has provided information
relative to the 1999 Pretreatment Compliance Inspection Report compiled by the
United States Environmental Protection Agency,
Michael C. Van Milligen
MCVM/dd
Attachment
CC:
Barry Lindahl, Corporation Counsel
Tim Moerman, Assistant City Manager
CITY OF 'DUBUQUE, IOWA
MEMORANDUM
January 11, 2000
TO: Michael Van Millig~f~,~ger
FROM: Paul J. Horsfall, ~[~Clt 19[anager
SLrBJECT: 1999 Pretreatment Compliance Inspection Report
INTRODUCTION
The purpose of this memorandum is to comment on the September 23, 1999, report on
pretreatment compliance.
DISCUSSION
On September 23, 1999, a Pretreatment Compliance Inspection was conducted by Patti
Marshall, Pretreatment Coordinator, EPA Region VII.
The Pretreatment Compliance Inspection (PC/) report concludes that the City of Dubuque
is doing a commendable job implementing its pretreatment program with the need for
some minor language restructuring in the issued permits and with the 90ty day
compliance report for new industries. The most significant point is the need to complete
the review of the city's local limits and confirm that these limits are in a form that would
allow adequate enforcement to protect the operation of the Water Pollution Control Plant.
Local limits are those restrictions placed on discharges of chemicals into the sewer
system or any substance that may have a detrimental affect on the Water Pollution
Control Plant. These limits may be calculated on the basis of the combined discharge of
an entire municipality as measured at the Water Pollution Control Plant, Maximum
Allowable Headworks Limits (MAHL), or as allocated to various industries throughout
the community in the form ora wasteload allocation.
The current local limits, as expressed in the sewer use ordinance, have been in place since
the acceptance of the City's "Industrial Pretreatment Program" by the State of Iowa and
the Federal EPA in 1985. The strategy used by the City of Dubuque for expressing local
limits in the form of MAHL was and is a common practice.
As pretreatment programs matured, it became apparent to the USEPA and State agencies
that the use of MAHL's weakened enforcement actions against non-compliant users. The
discussion of the current local limits in the "PCI" report points out the need to review
these limits and have them expressed in a form that is more conducive for appropriate
enforcement action, if needed, to protect the Water Pollution Control Plant. It should not
be inferred that at anytime has the Water Pollution Control Plant been endangered or has
done something wrong with the use of MAHL's but rather that an alternate method would
provide for greater protection and ease of enforcement.
Water Pollution Control Plant staff has completed major portions of the review of local
limits and expects the work to be completed in 6-8 weeks. The new local limits will then
be submitted to the Iowa DNR for review, comment and acceptance. Upon acceptance
by the Iowa DNR the City's sewer use ordinance will be updated to reflect the new local
limits.
The remaining comments concerning permit 1/mits, sampling frequency and Total Toxic
Organics (TTO's) will be completed throughout the next six month period. The permit
language will be addressed as renewal permits are issued to the various industries. The
new industrial waste survey will be completed in three months. The language used in the
90ty day compliance report has been corrected and T.T.O reports will be required for
industry on a six month basis rather than a yearly basis.
ACTION STEP
This memorandum requires no action but is meant for your information.
THOMAS J. VILSACK,
GOVERNOR
SALLYJ. PEDERSON,
LT. GOVERNOR
DEPARTMENT OF NATURAL RESOURCES
PAUL W. JOHNSON, DIRECTOR
Field Office #1
909 West Main St. - Suite #4
Manchester, Iowa 52057
Phone: 3191927-2640
Fax: 3191927-2075
December 15, 1999
City of Dubuque
Cit~Hall
13~and Central
Dubuque, lA 52001
A-i-I'ENTION: Mayor and Council
RE: Pretraatment Compliance Inspection
Facility No. 31-26-0-01
We have enclosed the inspection report prepared by EPA for the Industrial Pretreatment
Compliance Inspection that took place on September 23, 1999 and a copy for your wastewater
operator.
You will find the inspection report self-explanatory. We encourage you to make every effort to
comply with the recommendations. The inspection found that the City's Pretreatment Program is
in faidy good shape. There were several small items, however, that need to be addressed during
the next few months. These items are discussed within the text of this report.
Should you have any questions; do not hesitate to wdte or call this office:
Sincerely,
ENVIRONMENTAL PROTECTION DIVISION
Doug A. Hawker
Environmental Specialist
Encs,
cc: Wastewater Supt. - Paul Horsfall
DNR - Wastewater Section - Des Moines
Paul Marshall - U.S. EPA, 901 North 5th Street, Kansas City, KS 66101
WALLACE STATE OFFICE BUILDING / D ES MOINES, IOWA 50319 / 515- 281-5145 / TDD 515-242-5967
Pretreatment Compliance Inspection
City of Dubuque
FY 1999
On September 23, 1999, a Pretreatment Compliance Inspection was conducted by Paul
Marshall, Pretreatment Coordinator, EPA Region VII. Representing the city was Jonathan
Brown, Assistant Plant Manager, who is responsible for all Pretreatment implementation
activities. A chectdist was used to ensure evaluation of all important elements of program
implementation. A copy of the checklist is attached to support the record of the inspection.
Introduction
Dubuque spent the better part of the 1990's upgrading its pure oxygen activated sludge
wastewater treatment plant. This project was accomplished in three phases, the last of which was
completed in 1997. Since completion, the city has had only two NPDES permit violations and
these were due to the unusually wet weather this last spring.
Significant Industrial Users
Flow into the wastewater treatment plant is roughly 30% from industrial sources.
However, the great majority of the flow comes from four industries that generate compatible
pollutants through the production of food products or derivatives. Because of the large hydraulic
loads from these four facilities the city terms these their "wet" industries.
The city regulates 17 Significant Industrial Users (SIUs) through its Pretreatment
program, six of which are subject to federal Categorical standards. One ofthese, Eagle Door
and Window, was added last year when it installed a chromate conversion coating operation.
The industry filed a permit application, which the city accepted as a Baseline Monitoring
Report. The industry later filed a 90 day compliance report, as iequired. A review of the 90 day
compliance report indicated that the certification statement could stand to be strengthened. The
purpose of the 90 day compliance report is to acquire from the industry an affirmative
commitment of consistent compliance, which if not possible, would be accomplished via an
attached compliance schedule. The form that the city uses for the report poses the question of
whether compliance can be maintained but does not provide for an answer. Furthermore, if the
answer were to be "no" there is no mention of the required submission of a compliance schedule.
Fortanately, Eagle Door has installed a BAT level wastewater treatment system and the sampling
data supplied in the 90 day compliance report indicated that they should be able to maintain
compliance.
IDNR conducted last year's Pretreatment inspection and suggested that the city perform a
formal Industrial Waste Survey, since the last one had been done in 1991. In response, the city
has prepared a questionnaire which it stated would be mailed within the very near future.
Sludge Disposal
The city incinerates its sludge and consequently has very lenient sludge disposal limits.
However, the city intends to perform a study that will look at other methods of disposai to see if
getting away from incineration would be cost effective. In so doing, the Pretreatment program
will be responsible for meeting the limits established by the 503 sludge regulations.
Local Limits
The city performed a headworks analysis in 1983 as part of its Pretreatment Program
development but adopted the limits in a manner that would be impractical to implement. The
analysis determined the Maximum Allowable Headworks Loading (MAHL), that is, the mass
that could be received at the plant from all sources. This mass was converted to a concentration
using the plant design flow. These concentrations were then adopted in the city's Sewer Use
Ordinance (SUO) with the statement that no one shall discharge any of the pollutants which in
combination with other discharges would cause the concentration at the introduction to the
treatment plant to exceed the posted limits. This leaves the limits essentially unenforceable.
There are other problems with local limits left in this form. The city does not routinely
sample its influent to determine the metals levels present. Consequently, it can not know if its
local limits are ever being violated. Furthermore, if they did sample and fmd violations there
would be no way of knowing who was the cause. Moreover, if an investigation were to be made
to find the source, what level of discharge would the city look for? In addition, the General
Pretreatment Regulations at 403.4 require that permits issued to Categorical SIUs contain the
more stringent of either the Categorical standard or the local limit. In the form that the city has
adopted its limits numerous conversions using various industrial flows, and knowledge of the
flows and types present at the sampling point, must be employed before a comparison to
Categorical standards can be made. To date the city has not yet done this because the form of
their local limits makes it overly difficult.
The city recently re-evaluated its local limits as part of the NPDES permit re-application
requirement to do so, and submitted them to IDNR for comment. The limits sent to IDNR were
reviewed as part of this PCI and found to be in the same format as the 1983 limits: they were
presented in terms of MAHLs. These limits, therefore, would suffer from the same shortcomings
as their existing limits, that is, they would be essentially unenforceable and not be directly
2
comparable to Categorical standards. To take the calculations a step further a spreadsheet
developed by the Region for evaluating local limits was demonstrated using the data from the
city's analysis. This spreadsheet was left with the city for further evaluation.
Critical to the city's calculations is determining what environmental factors it should
apply as part of the analysis. Specifically, constraints on metals influent loadings will never be
governed by sludge incineration limits. However, if the city wants to always be in the position of
being able to land apply its sludge, then it must use the land application limits of the 503
regulations, which will certalniy affect the metals loadings it can accept.
Permits
The city issues permits having a duration of three years. A typical permit was reViewed
to determine if it conformed to the standard that EPA has set for a well written control
mechanism. For the most part, the city's permits contain all of the required and recommended
elements, although most of the recommended ones are contained by reference to the city's Sewer
Use Ordinance.
A few irregularities, however, were found. For instance, the Categorical lead limit for
Key City Plating was wrong. The facility is subject to the Etectroplating Categorical standards
and must meet lead limits of 0.6 and 0.4 for daily maximum and four day average, respectively.
In addition, an alternative to sampling for TTOs is provided allowing for certification of
compliance in lieu of sampling. However, for those industries that opt to sample the permit only
specifies sampling once per year instead of twice, as required by the regulations.
All of the permits reviewed contained limits identified as maximums and averages.
However, the defmition for average was defined as the average of four consecutive days. The
concept of a four day average, though, applies only to facilities subject to the Electroplating Point
Source Category. The city will need to change the definition of average for all of its non-
Electroplating facilities to identify that these are monthly averages.
The city als0 needs to be aware that a four day average is determined not over four
consecutive calendar days, but four consecutive sampling days. Thus an industry required to
sample the regulatory minimum of once every six months would have a four days of sampling,
and thus a four day average, once every two years.
Finally, the permit for Eagle Window and Door contained a limit for flow. There is no
Categorical limit for flow, nor is the Metal Finishing standard a mass-based standard. The city
indicated that they are not hydraulically overloaded so consequently there is no need to limit flow
from this industry. Therefore, unless the city intends to enforce any violations of flow it is
recommended that this limit be removed.
Inspection and Sampling
The city performs all self-monitoring for its industries. Monitoring frequencies exceed
the regulatory minimum. The two facilities that perform electroplating on site are sampled once
per quarter for four consecutive days. Other facilities subject to the Metal Finishing standard are
sampled once per quarter. This is a good practice because it is the two platers that would likely
be a source of pollutants.
Key City Plating discharges less than 10,000 gallons per day and consequently is subject
to a reduced list of pollutants under the Electroplating regulations. In fact, the pollutants that it is
most likely to discharge are not regulated by the standard, although the city monitors for them
anyway, recognizing that they are "pollutants of concern." The city has found elevated levels of
zinc, nickel, and chromium at times which may be affected by local limits based on sludge
contamination (see Local Limits, above), however, probably not to the degree that management
practices wouldn't control the discharge.
The city samples its four wet industries every production day.
The city documents all of its inspections using a form that it developed. Because the city
performs all self-monitoring for its industries, it uses the inspection as an opportunity to have
industries subject to TTO requirements sign certification statements. However, since it only
inspects once per year and the certification statement must be submitted no less than twice per
year by regulation, the city will need to make provisions for the submission of an additional
certification statement.
Enforcement
At the end of each month the city compiles all sampling data from its wet industries and
forwards them to the respective industry. All violations are clearly marked as it is the city's
intention for this report to serve as a Notice of Violation. The city stated that any monthly
average violations would be addressed with a separate mailing primarily because a monthly
average violation would really be serious given that up to 31 samples can comprise a monthly
average.
The city correctly determines the compliance status of each of its industries at the end of
each six-month reporting period. This ensures that a facility that is in Significant Noncompliance
is addressed with an appropriate enforcement action in a timely maane~. A record of the
determination is kept in each industry's file, making it easy to compile for the annual report that
it submits to IDNR.
In calendar year 1998, the city issued one NOV to a Categorical industry and 18 NOVs to
4
its non-Categorical industries. There has been very little need for enforcement actions beyond
the NOV because the city has not had any industries in Significant Noncompliance for over three
years.
Conclusion
Overall the city is doing a commendable job implementing its Pretreatment program, as
evidenced by the lack of SNC from any industries over the past few years. However, some loose
ends remain to be tied up. Specifically, the city needs to complete its local limits analysis and
have the limits in a form that allows it to compare local limits to Categorical standards.
In addition, some of the permit language needs to be corrected, this, however, should not
be burdensome as many of the permits come due in 2000.
PCI
Pretreatment Compliance Inspection
Date(s): ff
~ g~/ /f?? FY 1999
POTW: CITY OF DUBUQUE Date of last PCI/Audit:
Address: 13TH AND CENTRAL 08/05/98
DUBUQUE
IOWA 52001 NPDES Permit No.:
IA 0044458
Contact: JONATHAN BROWN State Permit No.:
Title: ASST. PLANT MANAGER 31-26-0-01
Phone: 319-5894176 Expiration Date:
Fax: 319-589-4179 07/14/03
POTW:~ ~-~
Participants
Inspect°rs:~-~cc~
Period covered by this PCI/Audit:
POTW Information
Total for ALL Treatment Plants (MGD)
Design Dally Ave. Actual Daily Ave. Design Peak: % Industrial Flow:
1~ [3.3cl 10 34 30
Number of Plants: % Combined Sewers: Type of Treatment at Principal Plant:
1 NONE 02 AS
Sludge Disposal Method: Quantity (dry/tons/Y): Receiving Stream:
INCINERATION 4200 MISSISSIPPI R.
PART I: PROGRAM BACKGROUND INFORMATION
I.A. Approved Modification~ to the Original Program
1,
Date of last NPDES permit modification: Date of original Program approval: 09/29/83
_~0f:g0:H93~t ~_ Date NPDES Permit originally
7//5~/~ modified to require implementation
[PTIM]: 09/29/83
2. 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?
4. Does the POTW have any program modifications currently being reviewed by the Approval Authority*
I.B. Approved Program Contents
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
8. What is the frequency required by the approved program/modifications for:
Non-
Activity categorical Categorical
SIUs SIUs~
POTW sampling of: DAILY 1-4/Y
POTW inspection of: 1/Y 1/Y
SIU self-monitoring: NA NA
SIU reporting: NA NA
9. What types of enforcement options are available through the approved program:
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
10. COMMENTS:
3
PART II: INTERVIEW QUESTIONS
II.A. Legal Authority and Jurisdiction
1 t. Have any Pretreatment modifications been made to the Sewer Use Ordinance since the last PCI/Audit
that have not been approved by the Approval Authority.
12. List by name and location any SIUs that discharge to the POTW from outlying jurisdictions.
NA
Indicate which of the above are not 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 has 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
Issued to Noncategorical SIUs? [Dss: 403.8(0(2)0)]
YES
17. Do all SIUs have current (unexpired) control mechanisms? {NOCM} ~'~
182 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} /xJ~:}
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
2J. 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
to the POTW?
23. Describe the method used to apply local limits to hauled waste.
24. COMMENTS:
II.D. Industrial User Characterization
25. How often does the POTW update its Industrial Waste Survey (BVS) to identify new SIUs or changes
to wastewater discharges?
a. When was the last formal update: 1991
5
26. What is the POTW's current industrial base?
Last
Current Industrial User Type Reported
Categorical SIUs
& {cius}
Il
Total all SIUs
F'/ {SIUS} 16
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 list).
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
through?
1. Was the interference traceable to 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
of discovery? {SNC} If not, why?
29. How many times per year does the POTW regularly sample its PRINCIPAL plant for the following?
Parameter
Metals
Toxic Organics
Biomonitoring
TCLP
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 tile block. (Values assumed to be
mg/l unless otherwise noted).. {EYLL} {ADLL}
POLLUTANT DAILY MAX POLLUTANT DAILY MAX
ARSENIC .04 LEAD .20
CADMIUM .01 MERCURY .01
CHROMIUM .7 NICKEL · 1
COPPER .2 SILVER .1
CYANIDE 5.0 ZINC .5
TOLUENE 500 O&G 100
PHENOLS 2.5
Comments:
31. Are the POTW's BOD and TSS limits technically derived (ie. based on plant capacity)?
~/YES
32. Are BOD and TSS violations treated as violations of technically based local limits?
.t~YES
33. If there 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. [403.18]
35. Has the POTW granted any Net/Gross allowances under 403.157 NO
36. COMMENTS:
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 IUs? [403.4]
38. Has the POTW notified its IUs of possible RCRA obligations? [4o CFR 403.8(0(2)] YES
39. Does the POTW allow Categorical users to use Solvent Management Plans/certification or surrogate
test procedures to meet TTO requirements?
II.G. POTW Compliance Monitoring and Inspections
40. What is the current frequency for:
Non-
Activity categorical Categorical
SIUs SIUs'
POTW sampling of: 300/Y 1-4/Q
POTW inspection of: 1/Y 1/Y
SIU self-monitoring: NA
SIU reporting: NA
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)]
44. How many industries were neither sampled nor inspected within the last 12 months. [DSS: 403.8(t)(2)(v)]
{NOIN} {RNC/SNC} k.)~w-'-~
45. Does the POTW sample its SIUs for all regulated pollutants at least once annually? [403.8(f)(2)(v)]
8
46. Sample/Analysis Procedures:
Chain-of-Custody always used?: .YES
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 part 1367 YES
Sampling method, metals: TIME COMPOSITE
47. How does the POTW document its industrial user inspections? INSP. FORM
48. Does the POTW evaluate all SIUs at least every two years to 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 standard at least twice per year? I403.I2¢)] ,g)/~ (~/oTa~
50. Were any Baseline Monitoring Reports or 90 day Compliance Reports due within the past 12
months? If so, from whom? Were the reports submitted?
51. Are IUs required to report spills, slug discharges, etc. to the POT~V? [403.12(0]
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 submit results within 30 days following a violation as per
403.12(g)(2)? t,3 th
II.I. Data Management
54. Are files/records computerized? YES
a. Does the POTW use EPA's PCME software package?
55. Are all records maintained for at least 3 years? [403.12(o)]
NO
56. Are program records available to the public as required by 40 CFR 403.14(b)? ~ ~' ~
57. Does the POTW have provisions to address confidential business information? [403.14(a)]
58. How is compliance status calculated? Describe the procedure used in determining Significant
Noncompliance (eg. are mo. avg. violations considered as well as daily max?).
II.J. Program Resources
59. What percent of the Pretreatment Coordinator's time is spent on pretreatment?
60. What computer programs does the POTW use for:
Wordprocessing: WORDPERFECT, WORD
Spreadsheet: EXCEL
Database: ACCESS
61. Does the POTW believe its annual budget adequate for implementation? yg,~>~
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 III: FILE AND RECORDS REVIEW
Following is a table containing the. POTW's Significant Industrial User inventory regulated by its Pretreatment
Program. Please veri~ that all information in the table is correct and current. For those industries no longer
regulated draw a line through the entry. 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 pretreatment progrmn.
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 pretmatment program. For example,
if an industry is subject to Metal Finishing regulations because it performs zinc and chromium plating indicate with
"ZnCrPL" or a similar abbreviation.
TMT:
If the facility treats its wastestream(s) indicate "Y." If no treatment is provided indicate "N."
TYPE:
Indicate the type of pretreatment system (if applicable) the industry has. Suggested abbreviations: "precip"
for precipitation/clarification; "precp/flt" for precipitation followed by filtration; "DAF" for dissolved air flotation;
etc.
REG FLOW:
Provide the industry's average daily flow for its regulated processes in gallons per day. The abbreviation "K"
stands for 1000.
TOT FLOW:
Provide the average daily total plant flow in gallons per day.
CWF:
Indicate if the industry uses the Combined Wastestream Formula to determine compliance with categorical
standards. "Y" = yes, "N" = no.
COMPLIANCE STATUS FOR THE 6 MO PERIOD ENDING:
For the six month periods listed, indicate if the industry's compliance status. 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 m 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 did 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.
11
III.B. 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?
{PSNC}
64. List by name, those industries currently on a compliance schedule. Complete the table below.
Industry Name IDate Schedule Issue~ Compliance DeadHne [How Administered*
eg. Administrative Order, Permit, etc.
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
provide the reason.
67. For those industries in SNC within the last 12 months complete the following table for all written
enforcement actions.
IU Name Violation Date of Date of Enforcement ERP required
POTW Action Action action
knowledge
13
68. Provide the total number of NOVs, Administrative actions, Judicial referrals, and criminal
prosecutions that occurred in the last twelve months. {FENF} {JUDI}
69. Were all actions taken by tbe POTW within 30 days of knowledge of a violation? {RNC/SNC}
70. Did all industries in SNC either return 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. Control Mechanism Evaluation
71. Do the POTWs control mechanisms: Permittee:
REQUIRED [DSS: 403.8(f)(1)(iii)] SUGGESTED PROVISIONS
Specify duration (no > 5 yrs.): // Cite the POTW's legal authority:
Contain the correct discharge limits: ~ Identify TTO alternatives, if applicable:
Specify sample type for IU self monitoring: t./"- Require notification within 24 hrs of a violation:
Adequately identify sampling location: ~-~ Require resample/report in 30 days of violation:
Specify sampling frequency: ~ Specify right of entry:
State applicability of civil or criminal penalties: b../' Reserve right to revoke permit:
Stipulate reporting frequency: t~ Specify immediate slug load notification:
Properly require records retention: ~// Require submission of all sampling results:
Specify limited transferability:
Result of this review from the last PCI/audit: ACCEPTABLE
III.D. Industrial Inspection Evaluation
72. Do the Industrial Inspection reports contain:
Name of Company contact: ~ Evaluation of IlJ's monitoring procedures:
Date of inspection: ~ Verification of wastewater flow rates:
Time of inspection: ~
Determination of applicability of the CWF:
Description of manufacturing process: f Description of the chemical storage area:
Description of treatment process, if any: P/ identification of potential spill conditions:
Evaluation of IU's monitoring methods: ~
Verification of production rates that would affect production based standard:
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III.E. Slug Discharge Control Procedures
73. If the POTW has required the submittal of a Slug Control Plan does it contain: [DSS: 403.8(f)(2)(v)l
__ A description of discharge practices including non-routine batch discharges
__ A description of stored chemicals
Procedures for immediate notification of slug discharges with written follow-up notification
__ Procedures necessary to prevent adverse effects at the POTW's treatment plant:
__ inspection and maintenance of storage areas
__ handling and transfer of materials
__ loading and unloading operations
control of plant site runoff
__ worker training
building of containment structures
__ measures for the control of toxic organics
__ measures for emergency response
74. COMMENTS
I III.F. Industrial User File Review Checklists
Following are worksheets to aid in the assessment of the nature of the oversight activities and
compliance status of the POTW's Significant Industrial Users. When reviewing SIU files priority should
be placed on Categorical industries that either have a history of violations or that appear to be in
compliance but have not installed that prescribed BAiT 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.
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