Iowa Department of Natural Resources
-
STATE OF
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DEPARTMENT OF NATURAL RESOURCES
..
THOMAS J. VI LSACK, GOVERNOR
SALLYJ. PEDERSON, LT. GOVERNOR
LYLE W. ASELL, INTERIM DIRECTOR
Field Office #1
909 West Main St. - Suite #4
Manchester, Iowa 52057
Phone: 319/927-2640
Fax: 319/927-2075
October 12, 2000
Citx of Dubuque
131 & Central
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 wastewater operator.
You will find the inspection report self-explanatory. We encourage you to make every
effort to comply with the recommendations.
Should you have any questions, do not hesitate to write or call this office.
Sincerely,
ENVIRONMENTAL PROTECTION DIVISION
~C>1~~
Ron Stellick
Environmental Specialist
Encs.
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cc: Wastewater Assistant Plant Manager - Jon Brown
DNR - Wastewater Section - Des Moines
Paul Marshall - U.S. EPA, Region 7, 901 North 5th Street, Kansas
City, KS 66101
WALLACE STATE OFFICE BUILDING / DES MOINES, IOWA 50319
515-281-5145 TDD 515-242-5967 FAX 515-281-8895 WWW.STATE.IA.US/ONR
ENVIRONMENTAL PROTECTION DIVISION
MICHAEL VALDE, ADMINISTRATOR
INVESTIGATION DATE
IOWA DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Field Office 1
909 West Main, Manchester, Iowa 52057
Phone: (319) 927-2640 FAX: (319) 927-2075
REPORT OF INVESTIGATION
CURRENT: 9-18-00
LAST: 9-23-99
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 Manager/Pretreatment Coordinator
Distribution: Field Office: Central Office: Inspected Facility:
Paul Marshall, U.S. EPA, 901 North 5th Street, Kansas Cit , KS 66101
AUTHENTICATION
INSPECTOR: (Z)~ 4 ~c:..-r I'd -11'- C'-
Doug A. Hawker, Environmental Specialist
REVIEWER: ~bY1 ~~ 10-/0/-00
on Stellick, Environmental Specialist
File Name: DubuquePTpciOO.doc
DATE:
On September 18, 2000 I performed an Industrial Pretreatment Compliance Inspection (PCI) of the City of Dubuque's
Industrial Pretreatment Program. Below are observations made and comments received during the course of this inspection.
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.
OBSERV A TIONS/RECOMMENDA TIONS:
1. Dubuque is currently working on a program modification by reassessing Local Limits. Revised local limits have been
calculated, submitted to the DNR Central Office for review, returned by DNR with comments, and are currently in the
City's possession. The City needs to respond to DNR's comments and get the revised Local Limits resubmitted as quickly
as possible. Problems with the City's current Local Limits were discussed in detail during last year's PCI that was
conducted by EPA personnel. To date, the City has not fully addressed EPA's concerns in this matter.
2. Currently, Dubuque does not receive any hauled waste from outlying jurisdictions. However, the City was approached
earlier this year by an out of town SIU regarding the possibility of hauling industrial wastes to the Dubuque WWTP. At this
time it appears doubtful that this situation will develop any further.
3. The City does accept waste hauled by local septage haulers. Such waste is introduced to the WWTP through a
designated manhole within the confines of the WWTP. During the past year, the City has changed the method of
charging these haulers for this service. The City now charges the haulers per 100 gallons of wastewater as opposed to
the old method of charging per load. This has raised the cost for the haulers somewhat, but has not caused any obvious
problems to date.
ENVIRONMENTAL PROTECTION DIVISION
MICHAEL VALDE, ADMINISTRATOR
4. The City's last formal Industrial Waste Survey (IWS) took place in 1991. The City is currently working on'a new IWS and
Mr. Brown noted that the new survey will be completed before the end of 2000. To date, the city has not identified any
new SIU.
5. The City's current industrial base consists of six categorical SIU's and 11 non-categorical SIU's, Farmland Foods has
been dropped off the list of SIU's due to it's closing during the past year. This facility was one of the City's major "wet"
industries and was responsible for a considerable amount of the Dubuque WWTP's loading. A new industry (Gold Label
Meats, a subsidiary of John Morrell) will soon reopen this packing plant, but will not resume any of the "kill" operations. It
is anticipated that future industrial loads from this facility will be much less then had been received from Farmland Foods.
Gold Label Meats will be included in the City's list of SIU's once it comes back on line.
6. As noted in last year's EPA inspection, the City must have their SIU's recertify their solvent management plans once each
6 months in order for the SIU's to continue to use the certification statement in lieu of monitoring for total toxic organics
(TTO) each year. Currently, Dubuque has each industry recertify once per year during the City's annual inspection. The
City needs to correct this aspect of their approved Pretreatment Program as soon as possible.
7. 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.
8. 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. This is a rather unique method of regulating the town's
SIU's when compared to the methodology used by the other pretreatment Cities in Northeast Iowa.
9, Overall, it appears that the compliance record of Dubuque's SIU's has remained good throughout 1999 and the first half of
2000. Only three industries were determined to be in infrequent non-compliance during each of the past three 6-month
reporting periods. There have not been any instances of Significant Non-Compliance by any industry for the past couple
of years. In 1999, the City of Dubuque sent out one notice of violation (NOV) to a categorical industry (AIH) and a total of
73 NOV's among ten of the city's non-categorical industries.
10. The two SIU's in most need of attention by the City are SKW and Inland Protein.
CONCLUSIONS AND RECOMMENDATIONS:
Dubuque continues to implement a very fine industrial pretreatment program. The program has matured over the years and has
relatively few areas of significant concern. As noted in the text of this report, it is important that the City complete the 2000
Industrial Waste Survey. The City's revised local limits must be submitted to the DNR Central Office (Steve Williams) for final
approval. The City needs to make sure all industries presently using the certification statement in lieu of TTO testing recertify
their solvent management plans twice per year as opposed to once per year as is presently being done.
The time and cooperation of Mr. Jonathon Brown during the course of this inspection was appreciated.
. .
PCI
Pretreatment Compliance Inspection
Date(s): '1-/8~oo FY 2000
POTW: CITY OF DUBUQUE Date of last PCI/ Audit:
Address: 13TH AND CENTRAL 09/23/99
DUBUQUE
IOWA 52001 NPDES Permit No.:
IA 0044458
Contact: JONATHAN BROWN State Permit No.:
Title: ASST. PLANT MANAGER 31-26-0-01
Phone: 319-589-4176 Expiration Date:
Fax: 319-589-4179 07/14/03
Participants
POTW: ...:r 00'1 Bro,",,", Inspectors: ::i)r; ~ ,IJ. Ho..wte-
Period covered by this PCI/Audit: Co-/evtd.o." /99C:;
POTW Information
Total for ALL Treatment Plants (MGD)
Design Daily Ave.
15
Actual Daily Ave.
10
Design Peak:
34
% Industrial Flow:
30
Number of Plants:
1
% Combined Sewers:
NONE
Type of Treatment at Principal Plant:
02 AS
Sludge Disposal Method:
INCINERA nON
Quantity (dry/tonsN):
4200
Receiving Stream:
MISSISSIPPI R.
./
----------------- ---"l
I
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MAY 1 f)
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I, I
PART I: PROGRAM BACKGROUND INFORMATION
LA. Approved Modifications to the Original Program
1.
Date of last NPDES permit modification:
--o6,'02/'J3
7//tf/78
Date NPDES Permit originally modified
to require implementation [PTIM]:
2. Approved Pretreatment Program modifications:
REQUIRED APPROVAL
MODIFICATIONS DATE
PIRT SUO Revisions 05/13/93
List of SIUs [403.8(f)(6)] 03/01/92
Enforcement Res onse Plan 09/15/94
DSS SUO Revisions 05/13/93
LOCAL LIMITS 1983
OTHER APPROVED
MODIFICATIONS
09/29/83
09/29/83
APPROVAL
DATE
3. Is the POTW presently working on any program modifications?
Co;,./:",,,,-<: :"'jt 0 teo..s:ie SS' L CtA I L; '" ;fs
4. Does the POTW have any program modifications currently being reviewed by the Approval Authority?
No - Bv..f loe",1 Jim.tS ~a.lIe bet!" rell;e.,.Jecl. ana (>''f'e c....'f'..t-vlfy be.n,) ("~od;f-(d.
. nlS< mtd h be Se-r.t b<Ht i", SIe.vr. /,../.J/.-c.......s f'v-r J.;J, ,-ev,'e-....J.
II LB. Approved Program Contents II
5. Authority to enforce Pretreatment Standards contained in:
ART. 2, DIY 6, CH 44
6. Date enacted or adopted: 08/15/93
7. Approved Control Mechanism: PERMITS
Note: Italicized question numbers indicate that the question is data base supported.
2
8. What is the frequency required by the approved program/modifications for:
Non-categorical
Activity Sills Categorical
Sills.
POTW sam lin of: DAILY l-4N
POTW ins ection of: IN IN
Sill self-monitorin NA NA
NA NA
* For Categorical pollutants
9. What types of enforcement options are available through the approved program:
Y Notice of Yiolation (NOY)
Y Administrative Order (AO)
Y Show Cause Hearin
Y Establishment of Com liance Schedules
Y Revocation of Permit
Y In'unctive Relief
Y Fines; Maximum $lOOO/da /violation
N Criminal Penalties
Y Termination of Service
10. COMMENTS:
N~d fa ~et t'ell,'sul IDcc./ 1.....:+, tlo..f..... bC<.cJ 11'1 10 Stwe W..II.''''....{ f';r.- rtv"W~
3
PART II: INTERVIEW QUESTIONS
II.A. Legal Authority and Jurisdiction
11. Have any Pretreatment modifications been made to the Sewer Use Ordinance since the last PCII Audit
that have not been approved by the Approval Authority.
No
12. List by name and location any SIU s 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?
N/A
15. COMMENTS Ho..vt bOe-v- "-ffnl",",l-eA r~fl by AN-. 0"'+ oJ fol-J\'\ SXlA .-ejo..rd''''jt-J.e
fosS,'b:rf; c,( ho..",I'''J :..c\.lAsh;....1 w,,-~t..s +1) t-k" c.'}" - }.Iv !t,....1J..e.r a.cf"f!\oJ ",:1 17...) f<Me_
Yo.-btJ...\1l.,.t n.s /N.1t 'f,(ocGed ,
II. B. Control Mechanism
16. General Information:
T e: PERMITS
Issued to Noncategorical SIUs? [DSS: 403.8(f)(2)(i)]
YES
Duration: 3 YEARS
17. Do all SIUs have current (unexpired) control mechanisms? {NOCM} Y'e s
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} N / A
4
H.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 IMO
P6vc,.....e Seeto..:)e hc-v-.lu's - N" ,''''J.....sf...c.1 w.1.stc
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 _ y\'\ 0.... " 0 Ie.
22. Are all applicable Categorical standards and Local Limits applied to IUs whose wastes are hauled to the
POTW?
No SilA's hC\....., WGl.s+eSto ft..eC:J7 "",f it's fo.-",t "V" f,'VVle.
23. Describe the method used to apply local limits to hauled waste.
N/A
24. COMMENTS:
No..,J c.\....o..rj '''5 j-l.e sef+"~< ~c.."" l..,-J fer JDO j ",J/r..J of wG.sha->G\.te.-v- (;5 offered
10 f"" lo...&..
Ha.s r/1-,'se4 tLe [osfj h... He. LAIA.JerJ.
.D. Industrial User Characterization
25. How often does the POTW update its Industrial Waste Survey (IWS) to identify new SIUs or changes
to wastewater discharges?
a. When was the last formal update: 1991
C",,,-,e,...t't be.'....j clcmt. a..",,&. w;1t be COI'>'\(Jefed bcf,rt f-~ f:.Md.. of ZtJaa
C ;f, ha.$ Vlor
~Je"t,reJ 0-"''1 \'Ie"", S IlA s + tl. f'
f 0. n.) ."",e
5
26. What is the POTW's current industrial base?
Current Industrial User T e
Last
Reported
Fo......rn 1cv...tJ. r: "t"ls ~ ttJ ~11
d Jro ff~d 0 r f SIIA I:sf
( N ~'l1 - Cat.) .. ~ 1'11.'d - ~ ()"t!I>
I.c
II
16
13'v-t G"ld Lc..be I trIq"ts
(5o~" )ncotlV w. It SOl/YI C..,.,t
b a.c t . '" Ct.) a", S j Lt,
17
Total all Sills {SIUS}
ILE. 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?
:2.. 155 v ,'01...+.' 0"5 :'" et;.'7 Sfr......j l(71)1) A'-^e to l't.ceSS/llf ro.,.."'S _ No, SI/.A. fro/'/-e-..s
a. Were any of the numerical NPDES violations, identified above, a result of interference or pass
through? No
1. Was the interference traceable to an industrial user? NIl!
2. Was action taken that led to elimination within 90 days of the interference or pass through?
{SNC} N / A
3. Was the responsible industry placed on an enforceable compliance schedule within 90 days
of discovery? {SNC} If not, why? N I fi
29. How many times per year does the POTW regularly sample its PRINCIPAL plant for the following?
Parameter Influent Effluent Sludge
Metals jt' $i ~4
Toxic Organics 1 1 1
Biomonitoring
TCLP
6
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 to be mg/l unless
otherwise noted). {EVLL} {ADLL}
I 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 10&0 100 I
PHENOLS 2.5
Comments:
N 0 c\-o-l'\~ tJ fh;-s fClst 1 e{l.. or.
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?
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 403.15? NO
36. COMMENTS: None..
7
II.F. Standards and Requirements for Industrial Users
Sh.'dl7 v,Se Cd. Stt\.",do..rds.
38. Has the POTW notified its ills of possible RCRA obligations? [40 CFR403.8(f)(2)] YES
37. Does the POTW compare local limits against federal Categorical standards and apply the most stringent
standards to Categorical ills? [403.4] No ..
39. Does the POTW allow Categorical users to use Solvent Management Plans/certification or surrogate test
procedures to meet TTO requirements? Ve 5 _ I
NeeJ tv hM<- Si lAs
Soil/&- t l'Y\ o-YlLlJW1~ t
recut:!! -fJ,e.'r
fJ~j 1/ (p /YIl1'>1fLs.
ILG. POTW Compliance Monitoring and Inspections
Activity
Non-categorical
Sills
Categorical
Sills.
POTW sam lin of:
Sill self-monitorin
300/Y
IN
NA
NA
l-4/Q
IN
NA
D....:'7 r}~",
Y"'fc..n,..e"..lln\
POTW ins ection of:
NA 11m - '-/
V I r. ow
* For Categorical pollutaots
41. List exceptions:
42. List those Sills that were not sampled by the POTW within the last 12 months. [DSS: 403.8(f)(2)(v)]
No
43. List those Sills that were not inspected within the last 12 months. [DSS: 403.8(f)(2)(v)]
No
44. How many industries were neither sampled nor inspected within the last 12 months. [DSS: 403.8(f)(2)(v)]
{NOIN}{RNC/SNC}
N () v-e
45. Does the POTW sample its Sills for all regulated pollutants at least once annually? [403.8(f)(2)(v)]
Y~5
8
method, metals: TIME COMPOSITE
Sam lin method, CN: GRAB
Sam lin method, O&G: GRAB
Do in-house anal ical methods conform to 40 CFR art 136? YES
YES
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(f)(2)(v)] Yes
a. Describe the method used by the POTW to evaluate the need for a slug control plan.
T~( "wet" ;...Ii"'.rtr:~ ~ hcw't. 51",-, Co...hl ~I..."s.
- Co. ~t:)oy,\ <of S I ,^'s ~t:.v. b~e'" de fultf:...{A net tb t1e~J Sc f's
II.H. IV 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? [403.12(e)] N b I.. .
<) - ec"l.<se -tile C.I, d<>{'s 411 ikt re'k;r~4 V>'O'k:f~"','J
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? /lfl) -
NLl hew SIl,\'.l ,'" 1999-
51. Are IUs required to report spills, slug discharges, etc. to the POTW? [403.12(f)] ~S
52.
Are IUs required to report violations within 24 hours of knowledge of the violation? [403.12(g)(2)]
NIA $'"Ht 11.. c,~ 400 aI( 17... a.."~s,'s, ,'t KI1NJ .f l/,'ol".f.h.J 6th 1;., SJIA d ,)<'$.
Are IUs required to resample and submit results within 30 days following a violation as per
403.12(g)(2)?
NIp, - Sc.w.e ~(c.soY\
53.
11.1. Data Management
54. Are files/records computerized? YES
a. Does the POTW use EP A's PCME software package? NO
55. Are all records maintained for at least 3 years? [403.12(0)] ~s
56. Are program records available to the public as required by 40 CFR 403 .14(b)? Yes
57. Does the POTW have provisions to address confidential business information? [403. 14(a)]
Yes
9
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?).
lAses Sert",.l.Shu\ H...\ c-l--h",,,,+,'(c.1l1 fc.bv.\a.ks v.>keth(, ''''Crl:t'''''~''j ,..'s..ltJ Me .-'" 0,- 0",1- ot (e''''fl.'c'",ce.
II.J. Program Resources
59. What percent of the Pretreatment Coordinator's time is spent on pretreatment? 15-20%
60. What computer pro ams does the POTW use for:
WORD ? 7
,
S readsheet:
EXCEL '97
.
ACCESS 'J 7
Database:
61. Does the POTW believe its annual budget adequate for implementation? ~J _ Bt~ f 0 fW" t-,,,,) f~:..~ 7J. .-VI
a. If not, is the level of money available for pretreatment less than that in the approved program or
approved modification?
ILK. Special Questions
62. Are there any issues that the POTW would like to discuss?
NoV\e d +h:s j;"",e.
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 verify 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 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 pretreatment 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 ilK" 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
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 noncompiiance 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.
SNC,S
SNC,R
SNC,M
SNC,C
LAST INSPECTION:
Date of the last inspection performed by the POTW.
11
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III.B. Significant Industrial User Com liance 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} N OI1e...
64. List b name, those industries current!
Indus Name
Date Schedule Issued Com liance Deadline How Administered'
f.)
. 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).
N Ol1e
66. If an industry has been deleted from the list of Significant Industrial Users list by name below and
provide the reason. f(;.pn/o..,d, FOoAS 1'5)" He ff'O(esJ of be......j deftfd alAl fo g,;'r sh<<ft;"'j duoJv'\.
6"MLl>-kt tflo?4tJ C'~I"fo-. w:\\ be sto-rt;'J "'r ;Yl L()7JO I
67. For those industries in skc within the last 12 months complete the following table for all written
enforcement actions.
IV Name Violation Date of Date of Enforcement ERP required
POTW Action Action action
knowledge
1\/ III
tV / N
13
68. Provide the total number of NO V s, Administrative actions, Judicial referrals, and criminal prosecutions
that occurred in the last twelve months. {FENF}{JUDI}, C,,+. N OV ~ (filII) 'V\ 199'1
Jf) r)lTh-('t:l.f. /\/ovJ (73 tot,,' v:"ld:..,s)
69. Were all actions taken by the POTW within 30 days of knowledge of a violation? {RNC/SNC}
Yes
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}
No j01cl"'sfr.~s ;., SNC
IILC. Control Mechanism Evaluation
71. Do the POTWs control mechanisms:
REQUIRED [DSS: 403.8(f)(1)(iii)]
Contain the correct dischar e limits:
location:
of civil or criminal enalties:
Properly require records retention:
S ecif limited transferabilit : .;
Permittee:
SUGGESTED PROVISIONS
,;
I
.;
.;
"
.;
I
I
.;
I
.;
.;
.;
/
I
I
Identif ITO alternatives, if a licable:
Re uire notification within 24 hrs of a violation:
Re uire submission of all sam lin results:
Result of this review from the last PCVaudit: ACCEPTABLE
III.D. Industrial Inspection Evaluation
72. Do the Industrial Ins
orts contain:
Name of Com an contact:
Date of ins ection:
Time of ins ection:
Descri tion ofmanufacturin rocess:
Evaluation of IV's monitorin methods:
,;
Evaluation of IV's monitorin rocedures:
rv/11
.;
{
..;
Verification of wastewater flow rates:
l
I
Descri tion of the chemical stora e area:
.;
.;
"
N/A
Verification of roduction rates that would affect roduction based standard:
N/A
No ClVF \.o.Jed. by Q",y S lLo\
14
.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)]
../ A description of discharge practices including non-routine batch discharges
.; A description of stored chemicals
I Procedures for immediate notification of slug discharges with written follow-up notification
I Procedures necessary to prevent adverse effects at the POTW's treatment plant:
/ inspection and maintenance of storage areas
,/ handling and transfer of materials
I loading and unloading operations
I control of plant site runoff
/ worker training
,/ building of containment structures
I measures for the control of toxic organics
-I measures for emergency response
74. COMMENTS I",lo."t\. Pr.te..~ scf I'lec-Js SOI",e ,''''''frol/(.I>n"..fs
fill "lNer V1lJY1- Co.t. S I u. 's kexvl SC P ~
IILF. 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 SID 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 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
r-
Industry Name: t. Cljle W ''''d 0.... t D"c.-
Principal Pollutants: Ch."'......'"
Products: AI",,,,.,,,,,,,, W".,dow5 ..... ])o..r fy......o
No. of Employees: 12 cJ The a,,,I..t,4
S.le
A. Does the file system for the industrial user contain:
~ Permit application
~ Current Permit
~ Correct limits in Permit
~ Correspondence/meeting notes/phone log
-L- Most recent inspection report
~ Evaluation for need for Slug control
---'-- Compliance status determination
~ POTW sampling results
~ Self-monitoring reports -1M "'11'<1 F... C<i""'fl.......t~ f,'rfolH
~ Enforcement documentation. 1'1. ",'vl~ t.'.~ I "f tl..,'s fit" f
~ Solvent Management Plan
~ Correct application of the CWF
.J!JL 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 v
_ Immediate notification by the IV
_ POTW response
_ Follow-up written notification
_ Effect on the plant
Sample the IV ~
C. In the last complete calendar year how many times did the POTW:
Inspect the IV ~
D. Were all regulated pollutants analyzed by the POTW at least once in the most recent calendar year?
Yes
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?
Yes
F. Frequency in the IV's control mechanism for: Self-monitoring ~ Reporting I Z ({I.w 0.,.1.,)
G. Did the industry comply with the sampling and reporting frequency requirements of its Control Mechanism?
H. Did the POTW identify all IV violations from: No V.'o 10.. +,-~"" j
IV Self-monitoring _
POTW Compliance monitoring _
I. Was the IV's compliance status (i.e. SNC, Infrequent noncompliance, Consistent compliance) determined
properly? C
c...... fl.-",,, ct
J. Complete the following table for all violations in the last 12 months. (If this information has already been provided in
Question 85, please indicate).
Violation
Date of
Violation
Date of
POTW
Knowledge
Nu v;olC;.1;o"s
Date of
POTW
Response
ERP
Required
Response
POTW
Response
16
Industry Name: SKIV B,'osyste,"s
Principal Pollutants: BuP. TS 5
Products: G~IG.t;~
No. of Employees: S 3
A. Does the file system for the industrial user contain:
~ Permit application -L POTW sampling results
~ Current Permit ~ Self-monitoring reports (F 10")
~ Correct limits in Permit -I Enforcement documentation
~ Correspondence/meeting notes/phone log JY.!.JJ...- Solvent Management Plan
~ Most recent inspection report ~ Correct application of the CWF
N/A Evaluation for need for Slug control " ~ Slug Control Plan
~ Compliance status determination "- /l-..e
v.... ')"".Ij.o5... (l(1""<!' ~ Ivw G""(
B. Did the industry discharge any slug loads or spills to the POTW in the past 12 months?
[403.12(0]
N//J
- NI:l
_ Immediate notification by the ill
_ POTW response
_ Follow-up written notification
_ Effect on the plant
C. In the last complete calendar year how many times did the POTW:
Sample the ill ~
InspecttheIlJ ~
D. Were all regulated pollutants analyzed by the POTW at least once in the most recent calendar year?
Yes
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?
Yes
F. Frequency in the IUs control mechanism for: Self-monitoring ~ Reporting lL!!lJ/IDw)
G. Did the industry comply with the sampling and reporting frequency requirements of its Control Mechanism?
Yes
H. Did the POTW identify all ill violations from:
ill Self-monitoring ~
POTW Compliance monitoring ~
I. Was the ill's compliance status (i.e. SNC, Infrequent noncompliance, Consistent compliance) determined
properly?
i t'\ I r~1o.e.l I1IJ'l1 - CD,... (JJ. ......q
J. Complete the following table for all violations in the last 12 months. (If this information has already been provided in
Question 85, please indicate).
Date of
Violation
Date of
POTW
Knowledge
Date of
POTW
Response
ERP
Required
Response
POTW
Response
Violation
S'e.. a. tt c. cL..1'ti fa"fV( INL,yk
17
PRTSM99.xls
SKW PRETREATMENT VIOLATION SUMMARY JAN-JUN 1999
pH BOD TSS sampling events
JAN 0 0 0 30
FEB 1 0 0 28
MAR 0 0 0 31
APR 0 0 0 30
MAY 0 0 0 31
JUN 0 0 0 30
sub-total 1 0 0 180
total 1
JUL-DEC 1999
JUL 0 0 0 12
AUG 0 0 0 31
SEP 0 2 2 29
OCT 1 0 0 31
NOV-t 1 5 2 29
DEC 1 2 1 27
sub-total 3 9 5 159
total 17
1999 TOTAL 4 9 5 339
VIOLATIONS 18
sum $ $8,526.26
Page 1
SKW, Inc. Monthly Charge Summary December, 1999
Industrial Pretreatment Program Charge Detail:
Lab Charges: Number Test Fee Charge
of Tests
BOD: 27 $7.50 $202.50
TSS: 27 $5.00 $135.00
pH: 27 $1.00 $27.00
COD: 27 $0.00 $0.00
Soluble BOD: 27 $7.50 $202.50
G and 0: 12 $20.00 $240.00
Pick Up: 27 $3.00 $81.00
Total Lab Charges: $888.00
Lab Charges: $888.00
IPP Flow Charges: $172.15
TotallPP Charges: $1,060.15
Invoice Detail:
Flow: Discountable: $4,087.02 12% ($490) $3,596.58
Non-Discountable: $0.00
BOD: Discountable: $20,536.34 12% ($2,464) $18,071.98
Non-Discountable: $895.46
TSS: Discountable: $8,887.40 12% ($1,066) $7,820.91
Non-Discountable: $173.71
pH: Non-Discountable: $100.00
IPP Charges: $1,060.15
Total Discount:
($4,021)
Total SKW, Inc Invoice: $31,718.80
Non-Discountable FLOW, BOD,TSS and pH charges are determined by
the extent of violation with the current Industrial Pretreatment
agreement. A Non-Discountable charge for these items is considered a
notice of violation of this agreement:
Page 2