vxEPA
            Unitud Status
            Environmental Protection
            Agency
            Office of Water
            Enforcement and Permits
            Washington, DC 20460
July 1986
            Water
Pretreatment Compliance
Inspection and Audit Manual
for Approval Authorities

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          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                         WASHINGTON. D.C. 20460
                                                        OFFICE OF
                                                         WATER
MEMORANDUM

SUBJECT:  Pretreatment Compliance Inspections and Audits

              4i#<^S.2&Zr-—
FROM:     Jam^ff T*. Elder, Director
          Office of Water Enforcement and Permits (EN-335)

TO:       Users of the Pretreatment Compliance Inspection (PCI)
          and Audit Manual for Approval Authorities

     This manual provides Approval Authorities with information
and material on audits and inspections of approved local POTW
pretreatment programs.  The manual should assist Approval Authorities
in providing effective oversight of approved pretreatment programs
under their jurisdiction.

     The PCI and audit procedures are consolidated in this manual
because the preparation and follow-up steps for the two activities
are similar.  Separate checklists for conducting PCIs and audits
are included in the manual.  The audit checklist addresses all
materials contained in the PCI checklist, although some audit
questions seek more detailed information.

     Audits and PCIs are complementary means of achieving effective
pretreatment program oversight.  Audits,  which are more comprehensive
and resource-intensive than PCIs, are most useful when conducted
approximately one year after program approval and again during the
POTW1s five-year permit term, preferably close to the time of
permit reissuance for the approved POTW.   Initial audits allow
for identification of any problems the POTW may have in implementing
its program.  Where appropriate, follow-up guidance or assistance
(including contractor assistance in some cases) may be provided
by the Approval Authority to the POTW.  In cases where the POTW
has failed to implement important aspects of its program, the
audit may also provide an opportunity to determine whether enforce-
ment action against the POTW is needed.  Audits performed just
prior to permit reissuance provide the Approval Authority with a
good opportunity to determine whether any modifications need to
be made to the pretreatment conditions in the POTW's NPDES permit
to address any deficiencies in the local program (e.g., to provide
greater detail on performance expectations for local permit
issuance or compliance inspections for lUs, to prescribe
methodologies for developing or assessing the need for local
limits,  etc.)

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                               -2-
     PCIs are less resource-intensive than audits.  The PCI focuses
on the POTW1s compliance monitoring and enforcement activities.
Optimally, PCIs should be performed annually during the interim
years between audits as part of routine NPDES municipal inspections.
PCIs should be included in the compliance inspection plans developed
between Regions and States.

     I hope that you will find this manual to be a useful tool
for ensuring that your approved local pretreatment programs are
being implemented in accordance with the requirements of the
General Pretreatment Regulations (40 CFR Part 403).

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PRETREATMENT COMPLIANCE INSPECTION AND AUDIT
      MANUAL FOR APPROVAL AUTHORITIES
  Office of Water Enforcement and Permits
                 July 1986
    U.S. Environmental Protection Agency
              401 M. St. S.W.
          Washington, D. C.  20460

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                             TABLE OF CONTENTS


                                                                       Page

1.    INTRODUCTION	   1-1

      1.1  PRETREATMENT COMPLIANCE INSPECTION (PCI)	   1-1

      1.2  AUDIT	.-.   1-1

      1.3  ORGANIZATION OF THE GUIDANCE MANUAL	   1-2

      1.4  PCI AND AUDIT SCHEDULING AND COORDINATION	   1-3

      1.5  RESOURCE REQUIREMENTS	   1-3

      1.6  STRATEGIC PLANNING AND MANAGEMENT SYSTEM (SPMS)
           COMMITMENTS	   1-3

      1.7  SOURCES OF ADDITIONAL INFORMATION	   1-4

2.    OVERVIEW AND BACKGROUND	   2-1

      2.1  PRETREATMENT PROGRAM AUTHORITY	   2-1

      2.2  FEDERAL REQUIREMENTS	   2-1

           2.2.1  Federal Categorical Pretreatment Standards	   2-2
           2.2.2  Prohibited Discharge Standards and Local Limits...   2-2
           2.2.3  Overview of State Regulations	   2-6

      2.3  CONTROL AUTHORITY REQUIREMENTS AND RESPONSIBILITIES	   2-7

           2.3.1  Industrial Waste Survey	   2-7
           2.3.2  Industrial User Monitoring and Enforcement	   2-8
           2.3.3  Recordkeeping and Reporting Requirements	   2-9

3.    PCI AND AUDIT PROCEDURES	   3-1

      3.1  INTRODUCTION	   3-1

      3.2  PREPARATION	   3-1

           3.2.1  Review of the Control Authority's Program Status..   3-1
           3.2.2  Development of an Audit or Inspection Plan	   3-2
           3.2.3  Notification to the Control Authority	   3-2
           3.2.4  Equipment Preparation	   3-3
           3.2.5  Coordination with Region and State	   3-3

      3.3  ENTRY PROCEDURES	   3-3

           3.3.1  Arrival	   3-3
           3.3.2  Presentation of Credentials	   3-3
           3.3.3  Consent	   3-3
           3.3.4  Problems with Entry or Consent	   3-3

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                                                                         Page

     3.4   OPENING CONFERENCE	   3-4

     3.5   DOCUMENTATION		   3-4

     3.6   TOUR OF THE POTW (Optional)	   3-4

     3.7   VISITS TO LOCAL INDUSTRIES (Optional)	   3-5

     3.8   CLOSING CONFERENCE	   3-6

     3.9   REPORT PREPARATION	   3-6

           3.9.1  Schedule for Report Submission	   3-8

     3.10  DATA ENTRY INTO PCS	   3-8

     3.11  FOLLOW-UP RESPONSE TO THE CONTROL AUTHORITY	   3-8

           3.11.1  PCI	   3-8
           3.11.2  Audit	   3-8

4.   PRETREATMENT COMPLIANCE INSPECTION (PCI) CHECKLIST	   4-1

     4.1   CONTROL AUTHORITY BACKGROUND INFORMATION	   4-2

           4.1.1  General Control Authority Information	   4-2

     4.2   COMPLIANCE MONITORING AND ENFORCEMENT PROCEDURES -
           CONTROL AUTHORITY PERSONNEL RESPONSE	   4-4

           4.2.1  Control Authority Pretreatnent Program Overview	   4-4
           4.2.2  Control Authority Pretreatment Program
                   Modifications	   4-4
           4.2.3  Control Authority Inspection and Monitoring of
                   Industrial Users (life)	   4-6
           4.2.4  Control Mechanism Evaluation	   4-8
           4.2.5  Enforcement Procedures	   4-10
           4.2.6  Conpliance Tracking	   4-12

     4.3   COMPLIANCE MONITORING AND ENFORCEMENT - IU FILE
           EVALUATION	   4-14

           4.3.1  File Contents	   4-16
           4.3.2  Control Mechanism Evaluation	   4-16
           4.3.3  IU Conpliance Evaluation	   4-18
           4.3.4  IU Self-Monitoring Evaluation	   4-18
           4.'3.5  Control Authority Enforcement Initiatives	   4-18
           4.3.6  Narrative Comments	   4-21

     4.4   SUMMARY EVALUATION OF CONTROL AUTHORITY PRETREATMENT
           PROGRAM	   4-22

     4.5   SUPPORTING DOCUMENTATION	   4-22

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                               TABLE OF CONTENTS
                                  (CONTINUED)
                                                                         Page

5.   PRETREATMENT PROGRAM AUDIT CHECKLIST	  5-1

     5.1   INTRODUCTION	  5-1

     5.2   OVERVIEW OF THE AUDIT CHECKLIST	  5-1

           5.2.1   Checklist Cover Page	  5-1
           5.2.2   Section I:  Control Authority Background
                    Information	  5-1
           5.2.3   Section II:   POTW Pretreatment Program Fact
                    Sheet	  5-1
           5.2.4   Section III:  Legal Authority and Control
                    Mechanism	  5-2
           5.2.5   Section IV:   Application  of  Pretreatment
                    Standards	  5-2
           5.2.6   Section. V:  Compliance Monitoring	  5-2
           5.2.7   Section VI:   Enforcement	  5-2
           5.2.8   Section VII:  Data Management and Public
                    Participation	  5-2
           5.2.9   Section VIII:  Program Resources	  5-2
           5.2.10  Section IX:   POTW File Review	  5-3
           5.2.11  Section X:  Evaluation and Summary	  5-3
           5.2.12  Supporting Documentation	  5-4

     5.3   AUDIT CHECKLIST


                                     TABLE

     2.1  INDUSTRIES SUBJECT TO CATEGORICAL  PRETREATMENT STANDARDS	  2-3
                                   APPENDICES


 APPENDIX A - EPA MEMORANDA FROM J. WILLIAM JORDAN AND MARTHA PROTHRO
              Instructions For Completing Form  3560-3

 APPENDIX B - SAMPLE  FOLLOW-UP LETTER TO THE CONTROL AUTHORITY

 APPENDIX C - POTW PRETREATMENT PROGRAM FACT SHEET

 APPENDIX D - NPDES COMPLIANCE INSPECTION REPORT  FORM  3560-3
                                     111

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                                 1.  INTRODUCTION

     The pretreatraent compliance inspection  (PCI)  and the pretreatment program
audit have been established to allow on-site review of pretreatment programs
in approved publicly owned treatment works  (POTWs).   The intent of this manual
is to provide guidance  to EPA Regions and State personnel whr are responsible
for conducting PCIs an•'- audics.

1.1  PRETREATMENT COMPLIANCE INSPECTION  (PCI)

     The PCI will expand the scope of existing municipal NPDES inspections  to
include an evaluation of the approved POTW pretreatment program.  The PCI is
designed to verify the  compliance status of the POTW  and focuses primarily  on
the compliance monitoring and enforcement activities  of the POTW.  It also
attempts to ascertain whether there have been changes to the approved program
which have not been reviewed by  the Approval Authority.  The PCI should
normally be conducted as an adjunct to other NPDES inspections to conserve
travel costs and staff  time.  Additionally, consolidation allows the inspector
to more easily integrate information about all areas  of the POTW's operations.
PCIs are compatible with the following NPDES inspections:

     0 Compliance Evaluation Inspections (CEI)
     0 Compliance Sampling Inspections (CSI)
     0 Performance Audit Inspections (PAI)
     0 Diagnostic Inspections, and
     0 Other nonroutine types of inspections such  as  toxics sampling and
       biomonitoring inspections.

     While not included in the PCI checklist, the  EPA Region or State may
include additional activities with the PCI.  These activities may include but
are not limited to the following:

     0 Industrial User Inspection Overview - The inspector may overview the
       POTW's industrial inspection and/or sampling procedures.
     0 Sampling Inspections - The inspector may actually sample industrial
       users within the POTW directly to determine compliance with
       pretreatment standards.
     0 QA/QC Procedure Inspections - The inspector can review either the POTW
       or industrial user (IU) or both to assess the  adequacy of quality
       assurance and quality control analytical procedures at the laboratory.

     This Manual, along with a PCI Workshop (offered  by EPA to Regions and
States), provides basic guidance to conduct a PCI.

1.2  AUDIT

     POTW pretreatment program audits are also performed as a means of
evaluating pretreatment program  implementation.  The  audit is a comprehensive
review of all elements of an approved POTW pretreatment program.  The audit
addresses all materials contained in the basic PCI although audit questions
are in some instances worded differently, and seek more detailed information.
The audit includes a review of the following elements of the POTW's program:
                                      1-1

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     0 Changes to the pretreatment program since approval
     0 Legal authority and control mechanism
     0 Application of pretreatment standards (categorical pretreatment
       standards and local limits)
     0 Compliance monitoring and enforcement efforts
     0 Data management and public participation
     0 Program resources.

     In most instances, the audit is an independent activity which will not
be conducted with an NPDES inspection.  Also, the audit is generally performed
by program office personnel rather than an inspector.  While the results of
the PCI or audit may be the basis for enforcement activity, the audit is also
designed to provide guidance and technical assistance to the Control Authority
and to assess the need for modifications to the approved pretreatment program.
Consequently, the audit is designed to answer the following questions:

     0 Is the POTW complying with existing requirements in its permit,
       approved program, and the General Pretreatment Regulations?

     0 Are any changes that the POTW is proposing to make in its program
       appropriate and should such changes be officially incorporated via
       program/permit modification?

     0 Are elements of the previously approved program proving to be deficient
       through experiences in implementation, and should changes in the
       approved program be required via the NPDES permit?

     0 Can the POTW benefit from specific and available resources which the
       Approval Authority can provide such as guidance documents, computer
       programs, etc.?

     0 What follow-up actions on the part of the POTW are recommended to
       improve the effectiveness of the existing program?

1.3  ORGANIZATION OF THE GUIDANCE MANUAL

     This Manual is organized into five chapters:

     0 Chapter One; Introduction provides a definition of the PCI and the
       audit; describes the organization of the Manual and addresses the
       issues of scheduling,  resource requirements and Strategic Planning
       and Management System (SPMS) commitments.

     0 Chapter Two;  Overview describes the National Pretreatment Program and
       provides general information relating to the principal responsibilities
       of POTWs, otherwise known as Control Authorities.

     0 Chapter Three;  PCI and Audit Procedures discusses those elements of
       the PCI and audit that differ from other NPDBS inspection procedures—
       including specific aspects of preinspection preparation, entry, opening
       conference, documentation, closing conference, inspection report, and
       follow-up responses to the Control Authority.
                                      1-2

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      0 Chapter Four;   PCI Checklist provides  narrative guidance  to  the  user
       of  the checklist.  An explanation  of the  questions  in  the checklist
       appears on the  left-hand page  (even-numbered) with  the checklist
       itself on the right-hand page  (odd-numbered).

      0 Chapter Five;   Audit Checklist provides an overview of the audit
       checklist and contains the checklist itself.

1.4   PCI AND AUDIT SCHEDULING AND COORDINATION

      The PCI will generally be scheduled  as an adjunct to  a planned NPDES
inspection.  This will usually avoid the  need for scheduling  separate visits
to the same POTW facility.  Types of inspections that can  be  coordinated with
a PCI include the Compliance Evaluation Inspection  (CEI),  the Compliance
Sampling Inspection (CSI), the Performance Audit Inspection (PAI), Diagnostic
Inspections and other  nonroutine municipal inspections.  These inspections
are performed by EPA or States in accordance with a Compliance Inspection
Plan  arrived at between EPA Regions and States.

     Audits should be  performed initially within one year  of  POTW pretreatment
program approval and at the time of NPDES permit reissuance (once every five
years).  The nnore concise PCI would be performed during intervening years.
These are the minimum  scheduling requirements for PCIs and audits.  Each may
be conducted more frequently if circumstances so require.

1.5  RESOURCE REQUIREMENTS

     The average audit is estimated to require between six and ten person-days.
Normally, two people will spend two days  on-site, although more  personnel may
be needed to cover all elements of an audit for a large POTW.  The average
PCI is estimated to require two person-days with approximately one-half day on
site.  The balance of  the time required includes pre-inspection  preparation
time and follow-up report preparation.  Travel costs should normally be
considered incidental  to the NPDES municipal inspection.

1.6  STRATEGIC PLANNING AND MANAGEMENT SYSTEM (SPMS) COMMITMENTS

     The Agency has established SPMS commitments for Regions  and States to
conduct PCIs and audits.  Although an audit generally covers  everything in
the PCI checklist/ the activity should not be counted as both a  PCI and an
audit.  EPA Headquarters will track commitments for Regions and  States  based
on retrievals from the Permit Compliance  System  (PCS).  Instructions on PCI
and audit entry codes  and other procedures were outlined in the  August  5,
1985 memorandum from J. William Jordan, and the August 30  and December  16,
1985 memorandum from Martha G. Prothro (See Appendix A.)

     Training workshops will be provided  to assist EPA Regions and States
with PCIs and audits.   Regions should accompany State personnel  on initial
inspections and audits and provide only periodic review after the Regions are
satisfied with State performance.
                                     1-3

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1.7  SOURCES OF ADDITIONAL INFORMATION

     This document assumes that the reader has some knowledge of the National
Pretreatment Program or has attended a PCI or audit training workshop.
Additional sources of pretreatment program information and inspection guidance
can be found in the following documents:

     0 "Guidance Manual for POTW Pretreatment Program Development," Office of
        Water Enforcement and Permits, U.S. Environmental Protection Agency.
        October 1983.

     0 "Procedures Manual for Reviewing a POTW Pretreatment Program Submission",
        Office of Water Enforcement and Permits,  U.S. Environmental Protection
        Agency. October 1983.

     0 "NPDES Compliance Inspection Manual", Office of Water Enforcement and
        Permits (EN-338), U.S. Environmental Protection Agency. June 1984.
                                    1-4

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                          2.  OVERVIEW AND BACKGROUND
2.1  PRETREATMENT PROGRAM AUTHORITY

     The Clean Water Act requires EPA to restore and maintain the chemical,
physical, and biological integrity of the Nation's waters.  The principal
regulatory tool for reducing pollutant discharges is the National Pollutant
Discharge Elimination System (NPDES).  The requirements of the National
Pretreatment Program are administered through the NPDES program.  The NPDES
permit places requirements and standards on Control Authorities, including
the requirement for developing and inplementing a local pretreatment program.

     The goal of EPA's National Pretreatment Program is to protect POTWs and
the environment from adverse impacts that may occur when hazardous or toxic
wastes are discharged into a sewage treatment system.  This protection is
achieved mainly through the regulation of nondomestic users of POTWs that
discharge toxic wastes or unusually high concentrations of conventional
wastes.

     EPA has promulgated the General Pretreatment Regulations in 40 CFR Part
403.  These regulations use the terms "Approval Authority" and "Control
Authority" in reference to the different agencies that have responsibility
for pretreatment programs.

     Approval Authorities are EPA Regional Offices or States to whom EPA has
delegated pretreatment approval authority responsibilities.  Approval
Authorities must (1) oversee local pretreatment programs to determine whether
Control Authorities are properly inplementing and enforcing their pretreatment
program requirements; (2) ensure that Control Authorities and industrial users
comply with applicable local pretreatment standards and requirements; (3)
evaluate the progress of pretreatment programs and identify any aspects of
pretreatment programs that need improvements, and (4) serve as Control
Authorities where no approved POTW programs exist.

     Control Authorities are the agencies that must develop local pretreatment
programs; directly apply and enforce Federal, State, and local pretreatment
standards for industrial users; and conply with Federal, State, and local
standards and requirements.  When a pretreatment program is approved, the
POTW becomes the Control Authority.  If the POTW does not have an approved
program or is not required to develop one, the Approval Authority (either the
approved State or EPA Region) acts as Control Authority.  Approximately 1,400
POTWs are currently required to develop and implement a local pretreatment
program.

2.2  FEDERAL REQUIREMENTS

     The General Pretreatment Regulations (40 CFR Part 403) specify the basic
requirements for the development and implementation of the Federal program.
The regulations address the various legal, procedural, technical, and adminis-
trative requirements and responsibilities for participating Federal, State,
and local governments.  The sections that follow will discuss the more specific
aspects of the regulations.
                                      2-1

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2.2.1  Federal Categorical Pretreatment Standards

     Federal Categorical Pretreatment Standards have been or are being
established for specific categories of industries.  Any industrial user
falling within one or more of these industrial categories nust meet, at a
minimum, numerical limits for certain pollutants that are typically present
in the waste discharges from those industries.  Categorical pretreatment
standards are technology based standards and may be expressed as maximum
concentrations or production based, depending on the industrial category.
They may be superceded only by more stringent State or local limitations
where additional protection is necessary to comply with other limitations or
site-specific factors (i.e., water quality standards or sludge disposal
requirements).  The current status of the various Categorical Pretreatment
Standards is shown in Table 2.1.

     Categorical Pretreatment Standards may be modified for a particular
industrial discharger for any of the following reasons if proper documentation
is prepared and the request for modification is approved by the Approval
Authority (EPA or approved State):

     0 Net/Gross Adjustment - Upon request of the industrial user and if
       certain conditions are met, the applicable standard can be adjusted to
       reflect allowance for a pollutant(s) in the industrial user's intake
       water.

     0 Removal Credit - A Control Authority may apply for authorization to
       revise pollutant discharge limits in categorical pretreatment standards
       to reflect removal of such pollutants by the POTW treatment plant.
       However, EPA's removal credit regulation has been invalidated by an
       April 1986 court ruling.  Thus, until further court or regulatory
       action restores the Agency's ability to provide removal credits, no
       such credits are available.

     0 Fundamentally Different Factors (FDF) Variance - An PDF variance may
       be requested by an industrial user, a Control Authority, or other
       interested person.  The FDF variance is designed to compensate for
       those situations where factors relating to an individual facility are
       fundamentally different from factors as they were considered by EPA in
       establishing a categorical standard.  A standard may be subsequently
       raised or lowered given the nature of the variance request.

2.2.2  Prohibited Discharge Standards and Local Limits

     Section 403.5 of the General Pretreatment Regulations contains the
requirements for both Prohibited Discharge Standards and locally developed
limits.  These limits apply to both categorical and noncategorical industries
and are in addition to the Federal Categorical Pretreatment Standards already
discussed.  (EPA has authority to enforce Prohibited Discharge Standards and
locally developed limits, if necessary.)
                                      2-2

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                                                             (Revised 4-22-86)

                                      TABLE 2-1

               INDUSTRIES SUBJECT TO CATEGORICAL PRETREATMENT STANDARDS

                                  FINAL REGULATIONS
Industry Category

Timber Products Processing
Electroplat ing 2
Iron & Steel
Inorganic Chemicals^
  Certain Subparts
  Phase I
  Phase II
Petroleum Refining
Pulp & Paper Mills
Builders' Paper & Board Mills
Steam Electric Power Generating
Leather Tanning & Finishing
Porcelain Enameling
Coil Coating (Phase I)
  -Steel Basis Material
  - Galvanized Basis Material
  - Aluminum Basis Material
Electrical & Electronic
  Components (Phase I)
    -Semi conductors
    -Electronic Crystals
Metal Finishing
Copper Forming
Pharmeoeuticals
Coil Coating  (Phase II)
(Ca making)
Electrical & Electronic
  Components  (Phase II)
    -Cathode Ray Tube
    -Luminescent Materials
Nonferrous Metals Manufacturing
  Phase I
  Phase II
Battery Manufacturing
Nonferrous Metals Forming
  and Metal Powders
Pesticide Chemicals
Metal Molding and Casting
Date Issued                        PSES1
In Federal        Effective      Compliance
 Register           Date            Date

  1-26-81         3-30-81         1-26-84
  1-28-81         3-30-81         4-27-84
                              (Nonintegrated)
                                  6-30-84
                               (Integrated)
  7-15-83         8-29-83         7-15-86 (TTO)
  5-27-82         7-10-82         7-10-85

  7-20-77                         7-20-80
  6-29-82         8-12-82         6-29-85
  8-22-84         10-5-84         8-22-87
  10-18-82        12-01-82        12-01-85
  11-18-82        1-03-83         7-01-84
  11-18-82        1-03-83         7-01-84
  11-19-82        1-02-83         7-01-84
  11-23-82        1-06-83         11-25-85
  11-24-82        1-07-83         11-25-85
  12-01-82        1-17-83         12-01-85
  4-08-83         5-19-83         7-01-84
                                  ll-08-85(As)
  7-15-83         8-29-83         6-30-84 (Part 443 TTO)
                                  7-10-85 (Part 420 TTO)
                                  2-15-86 (Final)
  8-15-83         9-26-83         8-15-86
  10-27-83        12-12-83        10-27-86
  11-17-83        1-02-84         11-17-86

  12-14-83        1-27-84         7-14-87
  3-08-84         4-23-84         3-09-87 (Subparts A-M)
  9-20-85         11-04-85        9-20-88 (Subparts N-AE)
  3-09-84         4-23-84         3-09-87
  8-23-85         10-7-85         8-23-88

  10-4-85         11-18-85        11-18-88
  10-30-85        12-13-85        10-31-88
                                            2-3

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                                                             (Revised 02-03-86)
                              TABLE 2.1  (Continued)

             INDUSTRIES SUBJECT TO" CATEGORICAL PRETREATMENT STANDARDS

                               PROPOSED REGULATIONS
      Industry Category

Organic Chemicals and Plastics
  and Synthetic Fibers

Plastics Molding and Forming
  (Phthalates)
 Date Issued In
Federal Register

   3-21-83
   (4-86)
   Scheduled
Promulgation Date

      3-86
     (7-87)
      - Pretreatment Standards for Existing Sources.

^Existing job shop electroplaters and independent printed circuit board manufacturers
 must comply with only the electroplating regulations.  All other electroplating
 subcategories are now covered by both the electroplating and metal finishing
 standards.

•'Final compliance date for Subparts A,B,L,AL,AR,BA, and BC is July 20, 1980.  The
 compliance date for Subparts AJ,AU,BL,BM,BN, and BO, except for discharges from
 copper sulfate or nickel sulfate manufacturing operations, is August 22, 1987.
 The compliance date for discharges from copper sulfate and nickel sulfate manu-
 facturing operations and for all Subparts in Part 415 not previously specified
 is June 29, 1985.
                                       2-4

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Prohibited Discharge  Standards

     Prohibited Discharge Standards apply  to all  nondomestic sources  introducing
pollutants into a POTW whether or not the  source  is subject to other  Federal,
State, or local pretreatinent standards or  requirements.

     Prohibited Discharge Standards include general prohibitions and  specific
prohibitions, as described below:

     0 General Prohibitions - Section 403.5(a) generally states that  pollutants
       introduced into a POTW by a nondomestic source shall not pass  through
       the POTW or  interfere with operation or performance of the works.
       This requirement is generic in nature but  becomes very important in
       relation to  locally developed limits, described later in this  section.
       In short, local limits are developed by Control Authorities to ensure
       that the general prohibitions are met by industrial users.

     0 Specific Prohibitions - Section 403.5(b) states that the following
       pollutants shall not be introduced  into any POTW:

       - Pollutants that create a fire or explosion hazard in the POTW

       - Pollutants that will cause corrosive structural damage to the POIW,
         but in no case discharges with pH lower  than 5.0, unless the system
         is specifically designed to accommodate  such discharges

       - Solid or viscous pollutants in amounts that will cause obstruction
         to the flow  in the POTW, resulting in interference

       - Any pollutant, including oxygen-demanding pollutants (BOD, etc.)
         released in  a discharge at a flow rate and/or pollutant concentration
         that will cause interference with the POTW

       - Heat in amounts that will inhibit biological activity in the POTW
         resulting in interference, but in no case heat in such quantities
         that the temperature at the POTW treatment plant exceeds 40°C (104°F),
         unless the Approval Authority, upon request of the POTW, approves
         alternative  temperature limits.

Again, some of the items above are generic in nature and are more clearly
defined by technically based local limits.

Local Limits

     Local limits are the mechanism by which general and prohibited discharge
standards are applied in a technically based, defensible manner for individual
non-domestic users of the POTW system.  Generally, these standards consist of
                                     2-5

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numerical limits on the discharge of toxic metals, cyanide, 8005, phenols,
oil and grease, and toxic organics.  They are normally expressed as maximum
limitations and usually apply at the point where the industry discharges to
the POTW collection system.  Some Control Authorities, however, have both
average and maximum values and apply them at the end of industrial processes.
The basic philosophy behind locally derived limits is to prevent discharges
that contain pollutants which interfere with treatment plant unit processes,
which pass through the treatment plant and adversely affect NPDES permit
compliance and receiving water quality, and which contaminate sludge to levels
that minimize disposal options.

     In some cases, locally derived numeric limits will be more stringent than
Categorical Pretreatment Standards, because the limits, based on local,
site-specific conditions, are necessary to protect the POTW from interference
and pass through.  The Control Authority is required to enforce the most
stringent pretreatment standard against an industrial user.  In order for a
single maximum local limit to replace a maximum daily and a monthly average
(or 4-day) categorical standard, the local limit nust be more stringent than
both values.  If the single maximum local limit is more stringent than the
daily maximum contained in a categorical standard but less stringent than the
applicable long-term average (4-day or monthly average), then the POTW must
enforce the local limit and the long-term average (4-day or monthly).  It is
also important to realize that local limits are normally applicable at end of
pipe while categorical standards apply to the end of a specific (regulated)
industrial process.  Therefore, it may be necessary to enforce both limits
using different monitoring points.  Alternatively, the categorical standard
may be adjusted to apply at the end of pipe by performing a mass balance
which accounts for dilution flows.

2.2.3  Overview of State Regulations

     In certain instances, States have enacted State-wide or POTW-specific
regulations that can directly or indirectly affect the pretreatment require-
ments with which an industry must comply.  Examples of these situations are
discussed below:

     0 Sludge Disposal Regulations - Many States have sludge disposal
       regulations that may affect an industrial user in one or two ways:

       - Restrictions on POTW Sludge - If State regulations limit the type
         and quantity of certain pollutants that may be present in a POTW's
         sludge for the disposal option practiced by the municipality, local
         limits for the industry may be necessary in order to maintain an
         acceptable sludge quality.

       - Restrictions on Industrial Sludge - An industry may generate a
         sludge as a byproduct of their pretreatment system.  State  (and
         Federal) regulations may then apply to the allowable storage,
         transport, and disposal options available to the industry.
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      0 Water Quality  Limitations  - Sane  States  are  issuing  NPDES  permits  to
       POIWs that  contain  limitations  for toxic pollutants  (especially toxic
       metals).  These  NPDES  limits for  toxic pollutants  are usually based on
       achievement or maintenance of water quality  standards that have been
       calculated  for the  water body into which the POTW  discharges.   As  with
       the  sludge  disposal regulations,  the Control Authority may develop
       local limits for industries to  control the industrial input of  those
       pollutants  and thereby comply with its NPDES limitations.

 2.3   CONTROL AUTHORITY  REQUIREMENTS AND  RESPONSIBILITIES

      A POTW that receives  pretreatment program  approval becomes the Control
Authority and  is responsible  for:

      0 Applying pretreatment  standards and other requirements to  industrial
       users

      0 Performing  routine  industrial user monitoring

      0 Taking  appropriate  compliance and enforcement action in cases of
       noncompliance

      0 Ensuring industrial user compliance.

      The major components  of  a Control Authority's  pretreatment program are
discussed below.

2.3.1  Industrial Waste Survey

     The industrial comtunity must  be  accurately identified by the Control
Authority.  The Industrial Waste Survey  (IWS) is generally  used to identify
and characterize industrial discharges to the POTW  treatment plant.  The  IWS
is typically conducted during program  development.   The four activities that
generally comprise  the IWS include:

      0 Conpiling a master  list of potential industrial users (lUs) located  in
       the  POTW service area.

      0 Surveying each of these industries, usually  by means of a  questionnaire,
       to collect  the necessary information (i.e.,  the type of industry and
       the  quality  and quantity of  the wastewater discharge).

      0 Conducting on-site  industrial inspections to obtain  complete and
       accurate information.

      0 Summarizing  the data for use in developing the pretreatment program.
       This information includes:   the number of industrial users to be
       regulated,  types of industries, pollutants discharged, and volume  of
       waste discharged to the POTW system.
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An irnportant corponent of effective pretreatment program implementation is the
periodic updating of the IWS information by the Control Authority to identify
new industrial discharges or changes in existing industrial discharges.

2.3.2  Industrial User Monitoring and Enforcement

     Compliance monitoring by the Control Authority is essential for the
implementation of the pretreatment program.  Information collected during
industrial monitoring activities provides the basis for compliance and enforce-
ment activities taken by the Control Authority against industrial users who
are found to be in violation of pretreatment standards and requirements.

     Control Authority compliance activities include monitoring discharges/
receiving and reviewing industrial self-monitoring reports, and conducting
on-site inspections of industrial facilities.  The goals of the Control
Authority compliance activities are the following:

     0 Ensure industrial compliance with Federal categorical pretreatment
       standards

     0 Ensure industrial compliance with local discharge limitations, local
       ordinances, and industrial user permit provisions

     0 Ensure tnat required Federal and local self-monitoring and reporting
       requirements are being met

     0 Maintain accurate knowledge of industrial processes and their potential
       impact on the POTW.

     Control Authority compliance monitoring falls into two general categories:

     0 Monitoring lUs and Their Wastewaters - This is achieved by inspections,
       sampling, and flow measurement.  Sample collection and flow measurement
       must be performed with proper procedures if the results of the monitoring
       program are to be valid or useful for purposes of compliance and
       enforcement activities.  Industrial user monitoring is generally
       performed by the Control Authority and the industry (self-monitoring).

     0 Monitoring the PCTW Treatment Plant - The Control Authority determines
       impacts of industrial discharges on the POTO including assessment of
       potential pass through or interference with treatment plant operations
       or sludge disposal.  This evaluation is supported by the results
       obtained from PCTW influent, effluent, and sludge sampling and analysis.
       This data is critical to the development and continual re-evaluation
       of the local limits and their ability to protect the PCTW treatment
       plant.
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     The Control Authority has primary responsibility for taking appropriate
enforcement action against industrial users who fail to comply with pretreatitent
standards and requirements.  General types of enforcement mechanisms fall
into two categories:

     0 Informal Actions

       - Informal notice to industrial user (e.g., telephone call or meeting)

       - Written notice of violation

       - Establishment of a compliance schedule

     0 Formal Actions

       - Fines

       - Civil suits

       - Criminal suits

       - Revocation of permit

       - Termination of Service.

2.3.3  Recordkeeping and Reporting Requirements

     The Control Authority and industrial users have several recordkeeping
and reporting responsibilities.  The major requirements for each are described
in this section.

Notification to IU

     The Control Authority must notify its industrial users of their obligation
to comply with federal and local pretreatment standards.  The notification
should include:

     0 A list of the applicable pretreatment standards and requirements.

     0 A requirement for industrial users to sample their discharge(s) and
       analyze for those pollutants known or suspected to be in waste streams
       that are limited by a standard.  These results must be reported to the
       Control Authority.

     0 A statement that requires industrial users to submit compliance schedules
       if they are not currently in compliance.

     0 A specific deadline date for the submission of all information.
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     These requirements are usually set forth in an appropriate control
mechanism such as a permit or other form of legally binding agreement between
the Control Authority and industrial user.  The Control Authority should also
notify the lUs through written communications when various reports are due.
These reports include compliance schedule progress reports, final compliance
reports, self-monitoring reports, or other required submissions.

Control Authority Reports to Approval Authority

     The Control Authority may be required to submit an annual report to the
Approval Authority which may contain the following information.

     0 Status of IU compliance

     0 Identification of enforcement actions taken against significant
       violators

     0 Status of general pretreatment program management.

     These types of reporting requirements and the information to be included
in each report will typically be specified in the NPDES permit where the POTW
has a local program.  These reports (normally required at least annually) will
usually provide important background information to the inspector performing
the PCI.

Industrial User Reporting Requirements

     The Federal regulations require industrial users subject to categorical
pretreatment standards to submit various reports to the Control Authority.
The Control Authority is responsible for reviewing, evaluating, and responding
to these reports.  These reports include:

     0 Baseline Monitoring Reports (BMRs)
     0 Compliance Schedule Progress Reports
     0 Final 90-Day Compliance Reports
     0 Periodic Compliance Reports
     0 Notices of Slug Loading.

Baseline Monitoring Reports (BMRs).  As a first step in applying pretreatment
standards, the Control Authority must have basic data about its industrial
dischargers that are subject to the standards.  This includes information
describing the industry's operation, discharge flow, pollutant type and
concentration, whether the IU is in compliance with applicable regulations
and, if not, what the IU plans to do to come into compliance within the
required time period.  The General Pretreatment Regulations, in 40 CFR Part
403.12(b), require every industrial user subject to a Categorical Pretreatment
Standard to submit this information in a report within 180 days after the
effective date of the applicable standard; this report is commonly referred
to as the baseline monitoring report (BMR).  The BMR must contain the following
information:
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      0  Name and address of the facility,  and names of the operator and owners

      0  List of environmental control permits held by the industrial user

      0  Description of  operations,  including the average  rate of production,
        SIC  codes,  and  a schematic  process diagram indicating discharge points

      0  Flow and pollutant  measurements

      0  Certification by an authorized representative of  the  industry of
        whether applicable  pretreatment standards are being met,  and if not, a
        description of  the  additional operation  and maintenance  (O&M) or
        pretreatment facilities that  are needed  to comply with the  standards

      0  A schedule  by which the industrial user  will provide  the additional
        O&M  or  pretreatment needed  to comply with the applicable pretreatment
        standards.

If an industrial user  has  already  submitted this information during IWS
activities  or  in a permit  application and this  information is still current,
it need not be resubmitted in  the  BMR.  The Control Authority may  also require
noncategorical IDs (which  must meet  local standards instead  of  categorical
standards)  to  submit a similar report, as the information would be useful to
the Control Authority.
Compliance Schedule Progress Reports.  An IU that is not  in compliance with
discharge standards and other limitations as indicated  in its BMR must develop
and submit a compliance schedule of actions enabling it to meet the applicable
discharge limitations. . Section 403.12(c) of the General  Pretreatment Regula-
tions describes the conditions for industrial users required to submit
compliance schedules.

90-Day Compliance Reporcs.  This report specifies whether or not the ID has
achieved compliance with the applicable Categorical Pretreatment Standard.
As specified in Section 403.12(d) of the General Pretreatment Regulations,
this report is required from the industry within ninety days following the
compliance date of the standard and must include:

     0 Sampling data for all regulated pollutants

     0 Flow measurements for regulated wastewaters

     0 Statement of compliance

     0 Where necessary, a statement as to whether additional changes or
       equipment is needed to obtain compliance.
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Semi-Annual Compliance Reports.  Section 403.12(e) of the General Pretreatment
Regulations requires industrial users subject to categorical standards to
report the results of self-monitoring of their regulated waste discharges to
the Control Authority at least semi-annually, usually during the months of
June and December unless otherwise specified by the Control Authority.  The
reports must indicate the type and concentration of pollutants and include a
record of estimated or measured average daily flows.

Notices of Slug Loading.  Industrial users are required  [40 CFR 403.12(f)] to
notify the POTW immediately of any slug loading (e.g., spill, pretreatment
system malfunction, etc.) from the user to the POIW.  Immediate notification
is usually by telephone, and a written follow-up report is usually required
within five calendar days.
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                      3.  PCI AND AUDIT PROCEDURES


3.1  INTRODUCTION

     This Chapter provides guidance for those responsible for conducting pretreat-
ment audits and PCI-*.   In particular, the purpose of this chapter is to highlight
for the auditor or inspector those general procedures that will result in a
well-organized and thorough review.  The basic procedural elements are similar
for an audit and a PCI, consisting of:

        Preparation
        Conducting the audit/PCI
        Documentation and report preparation
        Follow-up response to Control Authority
        Data entry into PCS.

Each of these elements  is discussed below in relation to both the audit and the
PCI.  Although a PCI is usually performed in conjunction with an NPDES inspection,
the PCI includes some additional components and procedures which are not covered
in other NPDES guidance.  These are highlighted in the discussion below.

3.2  PREPARATION

     Preplanning is necessary to ensure that the audit or inspection is properly
focused and is conducted smoothly and efficiently.  This planning should include
the following:

     0  Review of the Control Authority's program status and background information,
     0  Development of an audit/inspection plan,
     0  Notification to the Control Authority (optional, but recomended),
     0  Equipment preparation, and
     0  Coordination with Region and State.

3.2.1  Review of the Control Authority's Program Status

     Collection and analysis of readily available background information on the
Control Authority will aid in the effective planning and overall success of the
PCI or audit.  Materials obtained from Approval Authority files such as the
original pretreatment program application, PO1W compliance history, annual reports,
pretreatment program fact sheet, previous audit or PCI results, etc., will enable
the reviewer to became familiar with the Control Authority's program.  Reviewing
the pretreatment program status and background information will allow Approval
Authority personnel to identify any key issues before the site visit and to
utilize the time spent during the site visit efficiently by requesting only
updates or verification of previously-submitted information.

     Appendix C contains a fact sheet which can be used to summarize background info:
nation that should be available to the auditor or inspector prior to conducting the
site visit.  This information may be located throughout Approval Authority files or
may already be summarized in a similar format as the result of a previous audit or
PCI.  Completion of a fact sheet in preparation for an audit is strongly recomended.
A fact sheet has been incorporated in the audit checklist as Section II.  The fact
sheet should be updated each time that an audit is performed.  For a PCI, on the
other hand, the inspector should limit preparation to review of an already-completed
fact sheet, if possible.  The use of a fact sheet facilitates a comparison of the

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POTW's approved program requirements with the POTW's operating practices.  The
fact sheet summarizes the commitments made by the POTW in its approved program
submission and any pretreatnent requirements in the POTW's permit or other enforce-
able documents.  Thus, the fact sheet provides a basis for determining Aether
the POTW is implementing its pretreatment program as approved.

3.2.2  Development of an Audit or Inspection Plan

     This manual sets forth recommended procedures and checklists for conducting
the PCI or audit.  Should it be necessary for the auditor or inspector to deviate
from the suggested approach, development of a written plan is recommended.  The
plan should define the objectives of the activity, the tasks required to fulfill
the objectives, and the schedule.  For example, sampling of the POTW treatment
plant or selected lUs will not be a regular part of an audit or PCI, but may be
necessary in some cases to verify such things as POTW compliance with sludge
disposal regulations or IU compliance with applicable discharge limitations.  An
audit/inspection plan generally addresses the following items:

     *  Objectives

        -  What is the purpose of the audit or inspection (i.e., investigative,
           enforcement action support, or problem identification or correction)?

        -  What is to be accomplished (e.g., area of the Control Authority's
           program to be evaluated or specific concerns to be addressed)?

     •  Tasks

        -  What information must be collected to fulfill the objectives?

        -  What tasks are to be completed?

     0  Procedures

        -  What procedures are to be used?

        -  Will the audit/PCI require special procedures?

     0  Resources

        -  What will be the time requirements and order of activities?

        -  What will be the milestones?

     *  Coordination

        -  What coordination with laboratories or other regulatory agencies is
           required?

These issues are addressed by this guidance for the suggested approach.

3.2.3  Notification to the Control Authority

     Notification is recommended so Control Authority personnel are available at
the time of the audit or inspection.  However, Approval Authorities may find prior
notification less advantageous for PCIs than for audits.  Notification, if pro-
vided, should be written.  The inspector/auditor should request that the infor-

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nation necessary for the evaluation be compiled or developed prior to the site
visit.  Information that may be requested includes a list of all significant
industrial users (SlUs) that are currently in nonccnpliance, the duration of
noncompliance and description of the action(s) the POTW has taken against each
IU to secure ccnpliance.

     In addition, the notification should request information regarding on-sita
safety requirements in the event a facility inspection or sampling is performed
during the visit/ especially when an IU will be sampled.

3.2.4  Equipment Preparation

     Sane safety equipment may be required at certain industries.  In general,
only safety glasses will be needed, but in some instances hard hats and/'  - safety
shoes may also be necessary.  The Control Authority inspection personnel should
know what equipment will be required and either the POTW or the industry may have
equipment available for the use of the inspection team.

     In most cases, safety and sampling equipment will not be required unless the
review of the program status or background information indicates a need for
sampling of the POTW or selected lite.  In the event sampling is necessary, the
appropriate equipment should be prepared according to the particular sampling
needs.  Consult the standard procedures in the EPA NPDES Ccnpliance Inspection
Manual for more specific information.

3.2.5  Coordination with Region and State

     Regardless of whether the State or EPA is the Approval Authority, both
parties may wish to be present at the audit/PCI.  Adequate time and notification
should always be given to encourage both State and EPA staff participation.  When
the State is the Approval Authority, the State should play the lead role in
conducting the audit/PCI.  Regions should accorpany State personnel on initial
audits/PCIs and provide only periodic review after the Regions are satisfied with
the States' performance.

3.3  EOTRf PROCEDURES

3.3.1  Arrival

     Arrival at the facility should be during normal working hours unless
circumstances require otherwise.  The pretreatment program contact should be
located imrtiedia-tely upon arrival.  If the review team is at the Control
Authority to perform other NPDES inspections, each program contact or official
should be informed of the team's arrival.

3.3.2  Presentation of Credentials

     When the pretreatment program contact has been located, the review team
members should be introduced and present their credentials.  In the case of a PCI,
the credentials must be presented to the pretreatnent program contact, even if
the inspector has already done so in the context of another NPDES inspection
conducted at the Control Authority that same day.

3.3.3  Consent

     For a PCI, specific consent to conduct the PCI should be obtained from the
oaretreatment program contact in order to avoid possible confusion between the
various inspections conducted at the Control Authority.

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3.3.4  Problems with Entry or Cbnsent

     The auditor/inspector should respond to problems with entry or consent in
the iranner detailed in NPDES inspection guidance.

3.4  OPENING CONFERENCE

     Once credentials have-been presented and legal entry has been established,
the review team can proceed to outline the audit/inspection plans with the pre-
treatment program contact.  The opening conference should include discussion of
the purpose of the visit, the authorities under which the audit/inspection is
being conducted, and the procedures that will be followed.  In addition to the
information that is normally discussed with facility officials during the opening
conference of an NPDES inspection, the PCI inspector should discuss any considera-
tions unique to a PCI.  This conference should include at least an overview of
the checklist, the reviewer's intent to review files of specific lUs, and any
other elenents necessary to make the determinations required by the checklist and
the audit/PCI plan.

3.5  DOCUMENTATION

     Documentation is a general term referring to all print and mechanical media
produced, copied, or taken to provide evidence of suspected violations or to support
the conclusions of the audit/inspection.  Types of documentation include the
completed audit or PCI checklist, field notebook, statements, photographs, drawings
and naps, printed natter, mechanical recordings, and copies of permits and records.
All PCI documentation should be obtained in the same manner as other NPCES inspections.

     The auditor/inspector should provide strong documentary support of discrepancies
uncovered during an audit/inspection.  Documentation serves to "freeze" the actual
conditions existing at the time of the audit or inspection so that evidence may be
examined objectively at a later date by permits and compliance personnel.

     The basis of all documentation relating to the POTW's pretreatment program is
the checklist which provides accurate and inclusive documentation of all pretreat-
ment activities.  It will form the documentary basis for all determinations made
by the reviewer.  The reviewer should document the source(s) of the response to
each question in the checklist.

3.6  TOUR OF THE POTW (Optional)

     Since an audit (or, in some cases, a PCI) may be conducted independently of
an NPDES inspection, the review team may wish to tour the treatment plant to
observe plant operations and identify any visible effects of industrial discharges
on unit processes.  During the tour, the team should:

     *  Evaluate laboratory capabilities

     *  Note any unusual wastewater characteristics or plant operations which
        could be the result of industrial discharges, such as:

        -  Unusual odor

        -  Unusual discoloration

        -  Excessive/unusual corrosion of equipment, structures

        -  Excessive oil and grease

        -  Biological upsets (excessive foaming, sludge bulking, excessive
           trickling filter sloughing, low gas production in digesters)

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        -  By-passing of slug loads/accidental discharges of toxic or high
           strength wastes

     0  Note any processes/equipment not on-line, and causes

     0  Note sampling points.

     If unusual conditions are noted which are not representative of normal, well-
run operations, the team should:

     °  Photograph the unusual conditions (if possible)

     0  Discuss observations with POTW staff

     0  Determine the history and cause of the unusual condition(s)

     0  If industrial discharges are the suspected cause, attempt to identify the
        specific industry(ies)

        -  Determine if industry is in compliance with discharge limits and
           requirements

     0  Discuss corrective measures, if needed

     "  Note recommendations for follow-up (possibly schedule an NPDES inspection).

3.7  VISITS TO LOCAL INDUSTRIES (Optional)

     Accompanying POTW staff on a visit to a local industry is a valuable source
of information about the POTW's inspection procedures and its knowledge of its
lUs.  It is important to converse with POTW staff actually involved in IU inspec-
tions,  rather than the pretreatment program director.  If an IU is selected for
a visit, it is recommended that the lU's file be reviewed during the PCI/audit
in order to determine whether the information contained in the files is consistent
with the observations made during the IU visit.  The industry visits may be used
to:

  0  Evaluate POTW procedures for:

        -  Site inspection

        -  Sampling of industrial process wastestreams

        -  Gaining access to an industrial site

        -  Documenting a sampling event

  0  Evaluate POTW inspectors'

        -  Knowledge of categorical standards, the location of regulated process
           lines, and industrial compliance status

        -  Relationship with industry officials

        -  Safety precautions


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  0  Provide support to the POTW's requests for submission of industrial reports
     and compliance with discharge standards

  c  Inform industries of EPA's or the State's continued oversight role in
     the pretreatment program.

     The procedures for industry visits are flexible.  They may be conducted in
a very structured manner, and directed toward specific problems, or the Approval
Authority may wish to simply set ground rules and then follow the POTW inspector's
lead.  They may also simply evaluate the communication between the POTW and the
industry.  The approach must be determined on a case-by-case basis.  The approach
should be discussed with the POTW personnel prior to the IU visit.

3.8  CLOSING CONFERENCE

     Control Authority personnel are usually anxious to discuss the findings of
the audit/inspection prior to the review team's departure.  A closing meeting or
conference should be held for the presentation and discussion of preliminary
findings.  This closing meeting is also an ideal time for final questions and
details to be resolved.  The inspector/auditor should be prepared to discuss
general follow-up procedures (transmittal of findings to Approval Authority
personnel, etc.) that will occur.  The final meeting should be used as an
opportunity to request the conpilation of data or information that was not
available at the time of the visit.  Closing conference discussion should be
guided by rules established by the Regional Administrator or State Director
regarding permittee contacts in the Region/State.

3.9  REPORT PREPARATION

     The adequacy of follow-up to correct problems or deficiencies noted during a
PCI or audit depends in large part on the report package prepared by the inspector.
The material must be organized and arranged in a manner that will allow compliance
and permits personnel to make maximum use of the information.

     The objective of the report is to organize and coordinate all relevant
information and evidence in a comprehensive, usable manner.  To meet this objective,
information in an audit or inspection report must be:

     "  Accurate.  All information must be factual and based on sound inspection
        practices.  Observations should be the verifiable result of firsthand
        knowledge.

     0  Relevant.  Information should be pertinent to the subject of the report.

     *  Comprehensive.  Suspected violations should be substantiated by as much
        factual, relevant information as is feasible to gather.

     0  Coordinated.  All information pertinent to the subject should be organized
        into a complete package.  Documentary support (e.g., photographs,
        statements, sample documentation, etc.) accompanying the report should be
        clearly referenced to the checklist so that anyone reading the report
        will get a complete, clear overview of the situation.

     Although specific information requirements for an audit or inspection report
will vary, most reports will contain the same basic elements:


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      c  Ccrtpleted Form  3560-3  (or equivalent)

      0  Copy of completed checklist

      0  Supplementary narrative information

      e  Documentary support.

Form  3560-3.  The NPDES Compliance Inspection Report Form 3560-3 (see Appendix D)
is a  standard cover sheet that is completed after an  NPDES inspection and
incorporated into the final inspection report.  This form accommodates a pre-
treatmant code to indicate that an audit or PCI was performed.  This form or its
equivalent must be prepared to provide for data entry into PCS.  Instructions
for completing this form are contained in memoranda from J. William Jordan and
Martha G. Prothro which are found in Appendix A.

PCI and Audit Checklists.  The checklists are provided in Chapters 4 and 5.  Each
checklist gives a detailed item-by-item discussion of the information that must
be considered when planning and conducting a PCI or audit.  The checklist will
aid the reviewer in performing the PCI or audit and will serve as the basic
documentation of results.

Supplementary Narrative Information.  Supplementary narrative information will
generally be included on the checklist.  When a narrative report is necessary to
describe results more fully/ the contents of the supplemental report should focus
on supporting or explaining the findings in the checklist and may include
recommendations for follow-up actions.

Documentary Support.  All documentation that is produced or collected to provide
evidence of suspected violations should be included as a part of the checklist.
Types of documentation  include statements, photographs, drawings and maps, printed
natter, mechanical recordings, and copies of permits and records.  A specific
example of important documentation might be a series of repeated violations as
documented in an industrial user's file, yet a complete lack of any compliance
action by the POTW.  Copies of the monitoring results will document that the
repeated violations existed and the absence of any documented follow-up action
by the POTW will indicate the Control Authority's neglect.

"3.9.1  Schedule for Report Submission

     The report containing the results of the PCI or audit should be submitted to
the appropriate permits and compliance personnel.  A complete report should be
submitted within 30 days if sampling was not performed during the site visit.
Where sampling was included as part of either the audit/PCI or the NPDES
portion of the inspection, a complete report should be submitted within 45 days.

3.10  DATA ENTRy. IOTO PCS

     As indicated previously, the PCI or audit report must include Form 3560-3
and the information must be entered into PCS to receive credit in the Strategic
Planning and Management System (SPMS).  If the State enters data into PCS directly,
a form equivalent to Form 3560-3 may be used if it at least contains the same
data elements as Form 3560-3.  In either case, data entry of information related
to the PCI/audit should be completed within 90 days of the date of the event.
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3.11  FDLLOW-UP RESPONSE TO TOE CONTROL AUTHORITY

3.11.1  PCI

     After the compliance evaluation or enforcement office receives the complete
PCI report from the inspector, that office should review the PCI report to determine:
1) whether the PCI identified violations of applicable pretreatment regulations and
pretreatment-related NPDES permit requirements, and 2) whether other deficiencies
exist which are not in violation of pretreatment regulations or NPDES permit re-
quirements but render the Control Authority's pretreatment program less effective.

     Unless violations or deficiencies are noted during the PCI which are considered
to be of such significance that formal enforcement action should be undertaken
against the Control Authority, compliance personnel should forward to the Control
Authority a copy of Section IV (Summary Evaluation Section) of the completed PCI
checklist and a letter listing the Control Authority's violations or deficiencies
(if any) noted during the PCI.  The compliance person and the inspector should
jointly review Section IV of the completed PCI checklist and the follow-up letter
prior to mailing.

     The follow-up letter -should clearly distinguish between violations of
regulatory and/or permit requirements as compared to deficiencies which should
be remedied to improve pretreatment program iitplementation.  This follow-up
letter should request that the Control Authority submit a written description-of
proposed corrective actions within 15 days of receipt of the letter.  Appendix B
presents a sample of such a follow-up letter.

     Hswever, if the PCI does reveal significant violations which warrant formal
enforcement action against the Control Authority, it is strongly reccmrended that
neither the follow-up letter as described above nor the summary evaluation be
sent to the Control Authority.  Instead, a formal enforcement approach (e.g.,
Administrative Order, warning letter, Consent Agreement, etc.) should be followed.

     Upon review of the information contained in the PCI report, compliance personnel
may identify a need to obtain additional information from the Control Authority
by such means as 308 letters, audits, additional NPDES inspections, etc., before
making a decision regarding the need for enforcement action.  In such instances,
a follow-up response to the Control Authority beyond requests for additional
information may be withheld at the discretion of compliance personnel, pending
the receipt of such additional information.

3.11.2  Audit

     As with the PCI, a letter transmitting the findings and recommendations of
the audit should be sent to the Control Authority.  It should be sent to the POTW
manager (e.g., Director of Public Works), mayor or city manager with a copy sent
to the local pretreatment contact.  The letter should clearly distinguish between
violations of regulatory and/or permit requirements as compared to deficiencies
which should be remedied to render the Control Authority's pretreatment program
more effective.  The sample follow-up letter in Appendix B is equally applicable
to a PCI or an audit.

     When it is sent to the POTW, the transmittal letter may be accompanied by a
completed copy of the audit checklist and/or a narrative report.  The narrative
report would critically evaluate each element of the program as it was assessed
in the checklist, based on both the program as it was approved and the effectiveness
of the element as it has been implemented.  The Approval Authority has flexibility


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in deciding whether to send the entire checklist, just the sunrrary and evaluation
portion of the checklist, or a narrative report to the POTW.  In many cases, a
letter to the POIW containing the audit findings and recommendations may be sufficient.

     Depending on the findings and observations, other follow-up activities nay
be necessary, such as:

     0  Issue an administrative order requiring the POTW to respond to the audit
        findings within a definite time period

     0  Modify the NPDES permit to include a compliance schedule containing
        specific conditions and requirements

     *  Modify the approved program

     *  Schedule future audits or pretreatment compliance inspections to determine
        if audit findings have been implemented

     *  Initiate enforcement action against the POTW and/or industrial users.

     There is a need for close coordination between pretreatment auditors and
pretreatment corpliance inspectors to avoid duplication of efforts.  Because of the
subjectivity inherent in any review, auditors and inspectors should work very
closely together and discuss their findings before an official report is forwarded
to the POTW, particularly when separate visits are planned by each in the same
year.  Every attenpt should be made to avoid the possibility of conflicting
reports being filed which would be misleading to the POTO as well as potentially
adversely affecting any enforcement action.
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            4.  PRETREATMENT COMPLIANCE INSPECTION (PCI) CHECKLIST


     The PCI checklist was developed primarily to assist NPDES inspectors in
performing the inspection,- but- will also serve as the documentation for PCI
findings.  The checklist is organized into four sections:

     0 Control Authority Background Information
     0 Evaluation of Compliance Monitoring and Enforcement - Control Authority
       Personnel Response
     0 Evaluation of Compliance Monitoring and Enforcement - IU File Review
     0 Summary Evaluation.

Overall, the checklist questions are designed to be self-explanatory, which
is particularly helpful to NPDES inspectors who are just being introduced to
the PCI.  The first Section represents a summary of background information.
The second Section of the checklist relies upon Control Authority personnel
responses which would be given to the NPDES inspector during an informal
interview.  The third Section of the checklist is completed based on an
intensive review of selected industrial user files.  The focus of Section II
is to evaluate a Control Authority's efforts to determine and ensure industrial
user compliance with pretreatment standards and requirements and to ascertain
the level of information which management has about the pretreatment program.
The file review found in Section III provides the opportunity to verify
information provided during the interview and to assess the effectiveness of
the procedures used to manage the pretreatment program.  The file review
covers:

     0 Industrial user inspection frequency
     0 Control Authority sampling of industrial user effluents
     0 Status of IU permits or other control mechanisms
     0 Industrial user self-monitoring and reporting frequency
     0 Nature and frequency of violations
     0 Type and effectiveness of Control Authority compliance actions
     0 Overall adequacy of Control Authority files and documentation.

The fourth Section of the PCI checklist represents a summary evaluation which
the inspector will complete in conjunction with EPA Regional or State pretreat-
ment program staff.  It includes needed follow-up actions which are identified
as either required or recommended.

     The inspector should have a basic knowledge of the Control Authority's
approved program and NPDES permit requirements relating to pretreatment prior
to conducting the PCI.  Additionally, the inspector should be aware of the
Control Authority's treatment facilities and compliance history.  The sources
of this background information will include EPA and State files, the Control
Authority's pretreatment program submission, annual reports, previous audits
or PCIs, etc.  In most cases, important background information should have
been extracted from these various sources and summarized on a "Fact Sheet",
particularly in those cases where a pretreatment program audit has been
previously performed.  The "Fact Sheet" has been recommended for completion
prior to the first pretreatment program audit and should be updated on
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subsequent audits.  It can also be updated as a result of a PCI at the
discretion of the Region or State.  If the "Fact Sheet" has not been completed
previously, the inspector nay wish to complete it prior to conducting the
PCI.  Appendix C of this guidance contains the "Fact Sheet" which can be used
to record specific information about the Control Authority.

     In the following pages, the discussion of the intent and use of the PCI
checklist appears on the left hand pages (even numbered) with the corresponding
portion of the checklist appearing on the right hand pages (odd numbered).
4.1   CONTROL AUTHORITY BACKGROUND INFORMATION

     Section I of the PCI checklist summarizes key information about the
Control Authority and its pretreatment program. Section I should be completed
before the inspection using information from the POTW program file and/or
the Fact Sheet which may have been prepared previously.  The information should
then be confirmed during the conference. Additionally, the inspector should
consult pretreatment program personnel to determine if the scope or focus
of the PCI should be modified to address specific compliance questions.


4.1.1  GENERAL CONTROL AUTHORITY INFORMATION

     Part A summarizes background information about the Control Authority,
including NPDES permit information, previous audits or PCIs and the Control
Authority's pretreatment program contact.  Where applicable, the NPDES
permit language and Approval Authority enforcement documents (administrative
order, consent decree, etc.) would be attached to the completed PCI checklist.
                                      4-2

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     CONTROL AUTHORITY PRETREATMENT COMPLIANCE INSPECTION (PCI) CHECKLIST
         Date(s) of PCI:
         Inspector(s) Name(s):
         Control Authority Representatives:
SECTION I:  CONTROL AUTHORITY BACKGROUND INFORMATION

        A.  General Control Authority Information

            1.  Control Authority Name: 	

            2.  Mailing Address:  	
            3.  Is the Control Authority currently operating under any consent
                decree, administrative order or other enforcement action that
                specifies pretreatment requirements or affects the Control
                Authority's pretreatment program?  Yes 	No	
                If yes, attach a copy.

            4.  Date of last PCI/Audit: 	   Circle Type:  PCI  Audit

            5.  Date of last Control Authority Report to Approval Authority:

            6.  Pretreatment Contact Name:  	

                                    Title:  	

                                Telephone:  	
Section I Completed By:  	  Date:
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4.2  COMPLIANCE MONITORING AND ENFORCEMENT PROCEDURES—CONTROL AUTHORITY
     PERSONNEL RESPONSE


     Sections II and III of the PCI checklist primarily deal with the Control
Authority's application of pretreatment standards and evaluation of the
Control Authority's compliance and enforcement activities.  Section II is
completed from direct responses by Control Authority personnel, while Section
III will entail a detailed review of selected industrial user files to evaluate
the effectiveness and appropriateness of the Control Authority's:

     0 Control mechanisms
     0 Inspection and monitoring procedures
     0 Compliance and enforcement procedures.

4.2.1  Control Authority Pretreatnient Program Overview

     The inspector will obtain background information about the Control
Authority's pretreatment program in Part A, prior to discussion about the
Control Authority's compliance monitoring and enforcement program.  If the
Approval Authority desires more detailed information about the Control
Authority's program, the "Fact Sheet" in Appendix C may be used and verified
during this preliminary discussion.

4.2.2  Control Authority Pretreatment Program Modifications

     Part B requires the inspector to inquire about any significant changes
made to the Control Authority's pretreatment program since approval (or the
last PCI or audit, whichever occurred last).  The inspector should briefly
describe these changes on a separate sheet and indicate on the checklist if
the proposed changes were submitted to the Approval Authority for approval.
Please note that the inspector should advise the Control Authority that all
program modifications must be submitted to the Approval Authority for approval.
Listed below are some examples of changes which a Control Authority might
make to its approved program:

     0 Legal Authority
       - modified sewer use ordinance
       - incorporation of new jurisdictions/interjurisdictional agreements

     0 Control Mechanism Modification
       - modified provisions of IU permits

     0 Local Limits
       - revision of existing local limits

     0 Resources
       - change in personnel commitments
       - budget reallocations.
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SECTION II.  COMPLIANCE MONITORING AND ENFORCEMEOT—CONTROL AUTHORITY
             PERSONNEL RESPONSE
    A.  Control.Authority Pretreatment Program Overview

        1.  Hew many industrial users (lUs) are currently identified by
            the Control Authority in each of the following groups?

            	  industries subject to categorical pretreatment standards
            	  significant* noncategorical industrial users
                    other noncategorical industrial users
                    TOTAL
        2.  The Control Authority has defined "significant" industrial user
            to mean:
        3.  Approximately what percent of the total wastewater flow to the
            POTW treatment plant(s)  is from the industrial users? 	
        4.   During the past year,  has the Control Authority experienced
            any sludge contamination or problems in the collection system
            or at the treatment plant created by discharges from nondomestic
            sources?
            Yes	  No	
            If yes,  describe:  	  	  	
    B.   Control Authority Pretreatment Program Modifications

        1.   Has the Control Authority made any changes to its
            pretreatment program from that stated in its approved
            pretreatment program submission,  since the last PCI or audit?
            (Check below those program elements that have changed
            and briefly describe each on a separate sheet.)

                                                           Submitted for
            Program Element Changed                          Approval
                                                           Yes        No
            	 Legal Authority
            	 Control Mechanism Implementation
            	 Local Limits
            	 Inspection and Monitoring Program
            	 Enforcement Program
                     Resources
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4.2.3  Control Authority Inspection and Sampling of Industrial Users  (lUs)

     The General Pretreatment Regulations  [40 CFR Part 403.8(f)(2)(v)] require
Control Authorities to carry out inspection and sarrpling procedures to determine
whether lUs are in compliance or nonconpliance with applicable pretreatanent
standards and requirements.  Control Authority inspections and sanpling serve
specific/ individual purposes.  Sanpling, and flow measurement if necessary/
are used to determine if an industry is in compliance with pollutant  limita-
tions at a given time.  A properly conducted industrial inspection should
include a review of records and the treatment facility and provides a different
assessment for the Control Authority such as:

     0 Determination of industrial process changes that may impact pollutant
       load
     8 Review of IU monitoring records
     0 Operational status of pretreatment equipment
     0 Evaluation of the potential for spills
     0 Development of a working rapport with the IU.

This portion of the checklist evaluates whether the Control Authority has
performed inspection and sanpling at each Significant Industrial User (SIU)
consistent with its approved progam and/or NPDES permit and whether it has
inspected and sampled at least once a year.  (EPA recommends that each SIU be
inspected and sampled at least once a year.)  Industries whose discharge is
likely to interfere with treatment plant operations or ones with a poor
compliance history should be on more frequent inspection and sampling schedules
than those SIUs that discharge compatible wastes or demonstrate continued
compliance.
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C.  Control Authority Inspection and Monitoring of Industrial Users

    1.  Was each categorical and noncategorical significant industrial
        user inspected by the Control Authority:

        a) At least once in the past year?    	Yes     No
        b) In accordance with the frequency required
           in the NPDES permit or approved program?
                                              	Yes 	No

    2.  Was each categorical and noncategorical significant industrial
        user sampled by the Control Authority:

        a) At least once in the past year?   	Yes     No
        b) In accordance with the frequency required
           in the NPDES permit or approved program?
                                             	Yes 	No

    3.  What percentage of SIUs were not sampled or inspected at
        least once in the past year?

        Total Number of SIUs	   Saitpled	  Inspected	
        [At the discretion of the Approval Authority and the NPDES
        inspector, the names of significant industrial users that have
        not been sampled and inspected within the last year can be
        attached to this PCI.]

    4.  Does the Control Authority's basic inspection of an industrial
        user consist of:

        0 Inspection of the manufacturing facilities?    	 Yes  	 No
        0 Inspection of the pretreatment facilities?     	 Yes  	 No
        0 Inspection of chemical storage areas?          	 Yes  	 No
        0 Inspection of chemical spill prevention areas? 	 Yes  	 No
        0 Inspection of hazardous waste storage areas?   	 Yes  	 No
        0 Inspection of the sampling procedures?         	 Yes  	 No
        0 Inspection of laboratory procedures?           	 Yes  	 No
        0 Inspection of the monitoring records?          	 Yes  	 No

    5.  Are categorical lUs required to perform sampling and submit
        self-monitoring reports as follows:

        a) At least twice per year?   	Yes 	No
        b) In accordance with the frequency in the approved program or
           NPDES permit?              	Yes 	No

    6.  Are significant noncategorical lUs required to perform sampling
        and submit self-monitoring reports?  	Yes   	No

        What is the range of sampling frequencies?
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4.2.4  Control Mechanism Evaluation


      Section 403.8(f)(2)(iii) of the General Pretreatment Regulations requires
Control Authorities to have the legal authority to control each Ill's discharge
through some type of "control mechanism."  The most commonly used type of
control mechanism is the industrial user permit, although the Control Authority
may choose to use some other mechanism such as a contract or an ordinance.
Like the NPDES permit, the IU permit is tailored to each industrial user and
specifies pretreatment standards and requirements with which the IU must
comply.  This portion of the checklist examines whether all significant
industrial users (SIUs) are covered by a control mechanism and whether the
Control Authority has incorporated Categorical Pretreatment Standards as they
are promulgated. In Section III, the file review, the inspector will actually
examine the control mechanism to see whether it covers the essential elements.
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D.  Control Mechanism Evaluation

1.  Is each significant industrial user covered by an existing,
    unexpired permit-, contract, or other control mechanism?
    	Yes	 No

2.  If not, what percent of the SIUs are not covered by a control
    mechanism?  	

    Briefly explain why all SIUs are not covered by a control
    mechanism:
3.  Are SIU permits modified to reflect changes to the Categorical
    Pretreatment Standards and the General Pretreatroent Regulations
    within three months of the change?
           Yes         No
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4.2.5  Enforcement Procedures

     In the event of IU noncoropliance, the Control Authority must take necessary
action to bring an IU back into compliance within the shortest possible time
frame.  Generally, this portion evaluates whether the Control Authority does
the following:

     0 Has reviewed IU self-monitoring reports to determine compliance
       status
     0 Has a current knowledge of the compliance status of all lUs
     0 Has taken effective enforcement action/ and
     0 Has established an enforcement response guide.

     The Control Authority must have procedures to review all data that
relates to the compliance of its lUs.  This review must compare information
from self-monitoring, inspection, and compliance schedule progress reports to
the appropriate requirements.  The Control Authority must know when reports
are due, what monitoring is required, and what results are acceptable.  The
inspector does not need to know all of these details, but he does need to
determine whether the appropriate Control Authority personnel know and
understand these requirements.

     The Control Authority should have procedures for responding to IU
violations.  The "Pretreatment Compliance Monitoring and Enforcement Guidance"
recommends that the Control Authority develop an enforcement response guide
which identifies the possible enforcement responses for a particular violation.
While all Control Authorities may not yet have developed such a document, the
Control Authority should have developed an approach to determining appropriate
enforcement response which provides for escalation when compliance is not
achieved.

     This checklist uses the definition of "significant noncompliance"
identified in the "Pretreatment Compliance Monitoring and Enforcement Guidance"
as the basis for measuring performance.  That definition has not yet been
finally adopted, but a final definition will be in place by the beginning of
FY 1987.  Where the Region/State currently uses a different definition for
identifying that noncompliance which is considered to be significant, the
NPDES inspector may apply the Regional/State definition.
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E.  Enforcement Procedures

1.  Does the Control Authority routinely evaluate SIU self-monitoring
    reports and compare results to the applicable pretreatment
    standards and pretreatment conditions contained in the control
    mechanism?  	Yes  	No

2.  Approximately what percentage of all IDs which needed to install
    pretreatment technologies to meet applicable pretreatroent
    standards have done so?	    %

3.  Indicate the percent of SIUs that are in significant noncompliance
    (SNC) with the following at the time of the PCI:

    0  Applicable Pretreatment Standards           	
    0  Self-Monitoring Requirements                	
    0  Reporting Requirements                      	
4.  Approximately what percent of all the SIUs were subject to any
    kind of enforcement action during the last 12
    months? 	

5.  What types of enforcement actions (informal and formal) has the
    Control Authority used?

    Type of Action                       Type of Action Used
    Verbal warning
    Written notice or letter of violation
    Issue compliance schedule
    Revoke permit
    Consent decree
    Civil penalties (fines)
    Criminal penalties
    Termination of service
    Other (Specify)  	

6.  Of those SIUs identified as being in significant noncompliance
    in the last annual report, identify all SIUs who have not returned
    to compliance as of the time of the inspection, how long since
    they were first identified as being in significant noncompliance,
    what enforcement actions have been taken to return these SIUs
    to compliance, and when such actions were taken.  (If the annual
    report did not include such a list, identify all SIUs now in
    significant noncompliance, the period of time since they were
    identified as in significant noncompliance, the enforcement actions
    which have been taken, and when those actions were taken.)

7.  Does the control authority have procedures that define the appropriate
    enforcement response and time frames to initiate the response for
    different types and patterns of IU violations.
    	Yes	No  (If yes, attach a copy.)

8.  Has the control authority published the annual list of
    significant violators. 	 Yes 	 No  (If yes, obtain a copy.)
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4.2.6  Compliance Tracking

     Part F of Section II is intended to determine if the Control Authority
has mechanisms in place -to regularly track and document the compliance status
of its industrial users.
                                     4-12

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       F.   Compliance Tracking

            1.  Does the Control Authority maintain an individual record or
                file on each significant industrial user which includes
                conplianee information (i.e./ monitoring data, IU reports,
                notices of violation, etc.)?
                	Yes   	No

            2.  Does the Control Authority maintain a management system
                (manual or computerized) to track IU compliance status?
                       Yes          No
Section II Completed By:	  Date:
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4.3  COMPLIANCE MONITORING AND ENFORCEMENT - IU FILE EVALUATION

     This Section of the PCI checklist will help the inspector to evaluate
the validity of the data developed thus far in the inspection by verifying
whether or not the prescribed procedures have been followed in the case of a
particular industrial user. The inspector will select a random but represen-
tative number of significant industrial user files to perform this evaluation.
The inspector should review at least five SIU files or 10 percent of the total
number of SIU files.  At least two of the files reviewed should be for cate-
gorical IUs and at least 2 should be SIUs identified as being in significant
noncompliance.  In the case of large Control Authorities, review of 10 SIU
files will probably be adequate instead of 10 percent.  Conversely, for small
Control Authorities there may be less than five SIUs; in this case, it is
suggested that all the SIU files be reviewed.

     Complete and current industrial user files should at least contain
copies of the following information:

     0 IU permit application
     0 Fully executed and current IU discharge permit or other appropriate
       control document
     0 IU reports (i.e., baseline monitoring report)
     0 On-site inspection reports
     0 Monitoring results (both Control Authority and IU self-monitoring)
     0 Compliance schedule, if applicable
     0 Telephone log
     0 All correspondence between the Control Authority and IU, including
       notices of violations, enforcement actions, etc.

     From this information, the inspector can assess the adequacy of the
Control Authority's monitoring program, assess the compliance of selected
industrial users and determine if the Control Authority's pretreatment program
is being effective in identifying noncompliance and achieving IU compliance.
This file review will allow the inspector to:

     0 Evaluate the Control Authority's control mechanism

     0 Determine if pretreatment standards are being properly applied to
       IUs

     0 Assess the Control Authority's monitoring and inspection program
       (i.e., frequency, completeness, documentation)

     0 Determine whether the Control Authority is responding to noncompliance
       on a timely basis.

     0 Assess the compliance of specific IUs with applicable pretreatment
       standards

     0 Evaluate the Control Authority's overall recordkeeping system, and

     0 Collect documentation on IU noncompliance or situations where the
       Control Authority is not exercising adequate compliance/enforcement
       response.


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     The checklist provides the inspector with specific questions to determine
the adequacy of the Control Authority's activities as demonstrated by  the
industrial user files.  If the SIU files do not document a Control Authority's
monitoring and inspection activities, it is possible that the Control  Authority's
efforts might be misrepresented by the files.  This will not normally  be the
case, but may be an area for discussion in the close-out interview.  This
Section allows the inspector to record his findings on 5 IU files.  Additional
copies of this Section of the checklist may be used whore more than five
files will be reviewed.  Appropriate narrative comments should be recorded on
the supplemental comment sheet with the industry name and address.
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4.3.1  File Contents

     The Control Authority must maintain complete and accurate files on each
SIU to effectively track and document compliance history.  At all times
Control Authority personnel must have ready access to well-organized
information.  For each selected SIU file, the NPDES inspector should find each
of the items shown on the checklist in Part A.
4.3.2  Control Mechanism Evaluation

     Each SIU permit or other control mechanism should contain requirements
that are tailored to the SIU.  The NPDES inspector will evaluate the control
mechanism and determine whether it contains most of the essential elements of
an effective control mechanism.
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SECTION III:  COMPLIANCE MONITORING AND ENFORCEMENT - IU FILE EVALUATION

     The inspector should select a representative number of significant
     industrial user files to perform the file evaluation.  The inspector
     should review at least five SIU files or 10 percent of the total number
     of significant industrial-users.  At least 2 of the files reviewed
     should be for categorical lUs and at least 2 should be SIUs identified
     as being in significant noncompliance.  In the case of large Control
     Authorities, review of 10 SIU files will probably be adequate instead
     of 10 percent.  Evaluate the contents to determine if the appropriate
     response to each of the following questions is yes (mark with an "X")
     or none or no (mark with an "0").  Numerical responses are also required
     in some cases.  Appropriate narrative comments should be recorded in
     Section F.

FILE EVALUATION CRITERIA               File 1  File 2  File 3  File 4  File 5

A.  File Contents

  1.  Does the IU file contain:

     a) Completed IWS questionnaire?

     b) IU permit application?
     c) IU reports (BMR, 90 day
         report, etc.)?

     d) Discharge permit?

     e) Sampling results?

     f) Chain of custody forms?

     g) IU self-monitoring results?

     h) Correspondence?

     i) Telephone log?

     j) Inspection Report(s>?

     k) Is the IU in Compliance?

B.  Control Mechanism Evaluation

   1. Is the IU discharge permit,
      contract, etc. current
       (unexpired)?

   2. Does it contain applicable
      discharge limitations?

   3. Are types of samples  (grab or
      composite) for self-monitoring
      specified?
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4.3.3  IU Compliance Evaluation

     The review of an IU file will allow the inspector to evaluate the frequency
of the Control Authority's inspection and sanpling efforts over the past
year.  The inspector will also determine if all the pollutant parameters
specified in the control mechanism were evaluated during the Control Authority's
sampling events and whether the type of samples used (i.e., grab, composite)
are appropriate and will reflect the discharge characteristics.  The inspector
will also evaluate whether there is adequate documentation in the inspection
and sampling reports to support enforcement actions.  The purpose of these
questions is to determine if the Control Authority is undertaking the necessary
activities to determine IU compliance.

4.3.4  IU Self-Monitoring Evaluation

     Part D of this section of the checklist requires the inspector to
determine if monitoring reports were submitted to the Control Authority by
the industrial user and to determine if the proper parameters were evaluated.
Unless specifically required by the IU permit or other control mechanism, only
categorical industrial users are required by the General Pretreatment Regula-
tions to submit semiannual periodic compliance reports.  The control mechanism
should be reviewed by the inspector, specifically for IU self-monitoring and
reporting requirements, to determine if all the required reports have been
submitted during the past year.

4.3.5  Control Authority Enforcement Initiatives

     The NPDES inspector must review the monitoring records to identify
violations of pretreatment standards.  Where such violations exist, the
inspector should note how quickly the Control Authority took action.  The
Control Authority should always notify an IU of a violation of a pretreatment
standard or requirement.  This notice should preferably be in writing but may
be verbal as long as an adequate record of the notification exists.  The
inspector also should determine if the enforcement response was escalated by
the Control Authority if noneompliance continued or recurred until compliance
was achieved.

4.3.6  Narrative Comments

     The last page of Section III allows the inspector to identify the actual
files that were reviewed and record any appropriate comments that arise during
the file evaluation.
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FILE EVALUATION CRITERIA               File 1  File 2  File 3  File 4  File 5



B.   Control Mechanism Evaluation (Cont.)

   4. Is sample locatiorv(s) identified?

   5. Are applicable IU self-monitoring
      and reporting requirements
      specified?
C.   IU Compliance Evaluation

   1. Within the last twelve months:

    a) How many inspections of this
       IU were performed by the Control
       Authority?
    b) How many Control Authority
       sampling visits were performed?

   2.  Were all the parameters
       specified in the control
       mechanism evaluated?

   3.  Will the type of samples used
       accurately reflect discharge
       characteristics?

   4.  Does the IU inspection report
       have adequate documentation
       to support potential enforce-
       ment actions?  Did it include
       the following:

    a) Date and time of inspection?

    b) Name of company official
       contacted?

    c) Verification of production
       and flow rates, if needed?

    d) Problems with pretreatment
       facilities?

    e) Problems with monitoring
       equipment and techniques?

    f) Identification of sources
       and types of wastewater
       (regulated, unregulated,
        dilution flow, etc.)?
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                                      File 1  File 2  File 3  File 4  File 5
   5. Did the sampling report for
      the IU include:

    a) Sampling methods -used?

    b) Wastewater flow at time of
       sampling?

    c) Sample custody procedures?

    d) Determination of results
       for all parameters?
D.   IU Self-Monitoring Evaluation

   1. Did the IU report on all
      required parameters in the
      control mechanism?

   2. Did the IU comply with the
      reporting frequency required
      in the control mechanism?
      sampling frequency?

E.   Control Authority Enforcement
     Initiatives

   1. Did the Control Authority
      identify all IU violations:

    a) in Control Authority
       monitoring results?

    b) in IU self-monitoring results?

   2. Was the IU notified of all
      violations?

   3. Was follow-up compliance/
      enforcement action taken
      by the Control Authority?

   4. Did the Control Authority's
      action result in the IU
      achieving compliance within
      three months?
                                     4-20

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 F.   Narrative Garments

 FILE 1
 Industry Name 	
 Industry Address 	
 Type of  Industry 	
 Comments:
File/ID No.
IU Flow:
SIC:
FILE 2
Industry Name 	
Industry Address
Type of Industry
Comments:
File/ID Mo.
IU Flow:
SIC:
FILE 3
Industry Name 	
Industry Address
Type of Industry
Comments:
File/ID No.
IU Flow:
SIC:
FILE 4
Industry Name 	
Industry Address
Type of Industry
Comments:
File/ID No.
IU Flow:
SIC:
FILE 5
Industry Name 	
Industry Address
Type of Industry
Comments:
File/ID No.
IU Flow:
SIC:
Section III Completed By:
               Date:
                                     4-21

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4.4   SUMMARY EVALUATION OF CONTROL AUTHORITY PRETREATMENT PROGRAM

     The summary evaluation checklist  is provided as a mechanism for  the
inspector to record and evaluate his/her observations as well as a convenient
means for transmitting information back to  the Control Authority.  The  format
allows the inspector to -evaluate the facts  collected and to make judgments
about the adequacy of the Control Authority's pretreatment program.   Since
the NPDES inspector .is normally a fact finder and may not  have a complete
understanding of the pretreatment program,  the summary evaluation should be
reviewed by program personnel and concurred in before it is sent to the
Control Authority. There may be some situations  in which the Approval Authority
may choose not to transmit this summary evaluation to the  Control Authority.
In particular, this might be the case where an enforcement action is  contem-
plated and transmission of this information might hinder the case.

4.5  SUPPORTING DOCUMENTATION

     During the course of the PCI, the Inspector is asked  to collect
information which will be attached to the completed PCI checklist.  As  a
reminder to the Inspector, an Attachment Cover Sheet is included that can be
checked-off as information is collected during the PCI.  If the  Control
Authority is notified of the inspection in  advance, the inspector may wish to
request this documentation at that time.
                                     4-22

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SECTION IV:  SUMMARY EVALUATION OF CONTROL AUTHORITY PRETREATMENT PROGRAM

     A.  Control Authority Monitoring and Inspection

         Is the Control Authority's monitoring program adequate to accurately
         identify SIU noncompliance consistently?
          	Yes  	No

         Explain: 	
     B.  IU Self-Monitoring

         Does the Control Authority receive regular (at least semiannual)
         self-monitoring reports from its categorical industrial users?
         	Yes  	No

         Explain: 	
     C.   Control Mechanisms

         Has the Control Authority administered pretreatment standards and
         requirements through an effective permit system or other control
         mechanism?  	Yes  	No

         Explain: 	
     D.   Control Authority Enforcement

         When violations occur,  does the Control Authority routinely notify
         the SIU of the violation and escalate the enforcement response if
         violations continue?
         	Yes  	No

         Explain: 	
         Do the Control Authority's enforcement actions usually result in SIU
         ccnpliance within three months?  	Yes  	No

         Explain:  	
                                     4-23

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         Does the Control Authority have a good understanding of the
         compliance status of all its SIUs at any given point in
         tine?  _      Yes         No

         Explain:
     E. Follow Up Actions:

         Record any recommendations for follow-up activity with the Control
         Authority below.  Distinguish between those actions by the Control
         Authority which are required to comply with pretreabnent requirements
         and those which are recommended to improve the effectiveness of the
         pretreatment program.

     F.  Other Findings

         Do the findings of the PCI support the statements made in the Control
         Authority's last annual report to the Approval Authority?
         	Yes  	No

         Explain: 	
         Record any other pertinent findings from the PCI below:
Note:  The inspector should attach necessary documentation to this completed
       checklist as requested throughout the PCI checklist.
                   Inspector Signature(s)                      Date of Report
                                     4-24

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                    DOCUMENTATION
                         FOR
     PRETREATMENT COMPLIANCE INSPECTION CHECKLIST
Example of any enforcement action (i.e., administrative order)
Containing pretreatment findings or requirements (I.A.)
Description of significant changes to the Control Authority's
pretreatment program (II.B.)
Names of lUs that have not been sampled or inspected within the
last year (II.C.) - OPTIONAL
List of SIUs not in compliance, duration of noncompliance, and
type of action taken by the Control Authority (II.E.)
Control Authority procedures that define appropriate enforcement
response for IU violations (II.E.)
Annual list of significant violators (II.E.)
Other documentation (i.e., copies of Control Authority file
information to support Inspector findings.  List the additional
supporting documentation below).
                         4-25

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                     5.  PRETREATMENT PROGRAM AUDIT CHECKLIST

5.1  INTRODUCTION

       A checklist has been prepared to assist with the performance of
  pretreatmsnt audits.  The recommended checklist is both detailed and com-
  prehensive since audits represent a relatively new activity,  and the Agency
  wants to ensure that:

       o  Audits are complete.

       o  Audits accomplish the desired objectives.

  The audit checklist is contained in section 5.3 of this chapter.  It contains
  ten sections, each of which is discussed below.

5.2  OVERVIEW OF THE AUDIT CHECKLIST

5.2.1  Checklist Cover Page

       The cover page is used to record the date of the on-site inspection, the
  audit participants, and the name of a principal reviewer.   The principal reviewer
  would be the primary person whose judgement is involved in completion of the
  checklist.  This person nust necessarily be a representative  of the Approval
  Authority.

5.2.2  Section I;  Control Authority Background Information

       This section of the checklist sumrrarizes general information about the POTW,
  its wastewater treatment facilities, and the results of the last audit or PCI.
  The section is purposefully brief because detailed information about the Control
  Authority is often already on file and available to the auditor.  Because the
  auditor nust know the general characteristics of the POTW treatment plant(s),
  particularly when evaluating local limits, a section requiring information on
  each treatment plant is included.  Once Section I has been completed as part
  of the first audit, it will always be available for future audits and PCIs and
  will require only minor updating.

5.2.3  Section II;  POTW Pretreatment Program Efect Sheet

       The fact sheet summarizes the POTW's approved pretreatment program
  requirements.  It should be completed prior to the on-site audit.  The
  approved program requirements may be contained in several documents, including
  the NPDES permit, the original pretreatment program submission, enforcement
  orders, and letters sent by the Approval Authority to the POTW officially
  acknowledging or approving program modifications.  Part A of the fact sheet
  is an inventory of all such documents comprising the approved pretreatment
  program.  The rest of the fact sheet provides a description of the approved
  program and is completed based on the documents listed in Part A.  The fact
  sheet will help the auditor to determine whether the PCTW is implementing its
  pretreatment program as approved.  The fact sheet should be updated before
  each audit or PCI if there have been any changes in the approved program
  requirements.
                                    5-1

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5.2.4  section III;  Legal Authority and Control Mechanism

       This section of the checklist evaluates the POTW's basic legal authority
 and mechanisms to effectively control users within and outside its primary
 jurisdiction.  Regardless of the fact that the POTW's legal authority was re-
 viewed during program approval, the POTW's sewer use ordinance, regulations,
 etc., may need to be reevaluated, as approved control mechanisms when implemented
 sometimes prove to be ineffective.  This reevaluation is particularly important
 during the first audit.

5.2.5  Section IV:  Application of Pretreatment Standards

       This portion of the checklist solicits an in-depth evaluation of:

       o  The POTW's efforts to identify, characterize, and notify industrial users

       o  The POTW's application of categorical pretreatment standards and local
          limits to its industrial users

       o  The technical basis for the POTW's local limits

       o  The effectiveness of the pretreatment standards to prevent
          interference, pass through, and sludge contamination.

       The auditor should (Determine whether the POTW has sound procedures for
  notifying users, updating the industrial waste survey, and administering the
  control mechanism.  Deficiencies in these areas may indicate that the POTW
  should develop formal, written procedures.  In addition, it is important that a
  detailed review of IU permits (or other control mechanisms) be carried out to
  ensure they are correctly written.  If limits are not correctly applied in the
  permits, the POTW may be falsely reporting IU compliance.  Permit application forms
  and other relevant forms should also be examined.

5.2.6  Section V;  Compliance Monitoring

       Section V of the checklist summarizes the results of discussions with POTW
  personnel about their compliance monitoring activities, such as POTW monitoring
  and inspection frequencies, inspection procedures, sampling protocol, and IU
  self-monitoring requirements.  Since Section V relies primarily on extemporaneous
  POTW personnel responses, this section also gives a good evaluation of the POTW's
  depth of understanding of its industrial community.

5.2.7  Section VI;  Enforcement

       This portion of the checklist summarizes the results of discussions with POTW
  personnel about their enforcement procedures.  It evaluates the POTW's compliance
  tracking system and enforcement management strategy.  The section generally asks
  for the POTW's response to instances of IU noncompliance, the names of significant
  users that the POTW has determined are not in compliance, and the types of
  enforcement actions used by the POTW.

5.2.8  Section VII;  Data Management and Public Participation

       Section VII evaluates the POTW's efforts to effectively manage data and
  involve the public, where appropriate.
                                      5-2

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5.2.9  Section VIII;  Program Ftesources

       This section assists the reviewer in determining if the POTW has adequate
  personnel, equipment, and funding to operate the pretreatnent program.  Differences
  between the current resource and funding levels and those levels that are required
  by the approved program are noted.  The reviewer is also asked to make judgements
  about the adequacy of tfie current resources.

5.2.10  Section IXr  POTW File Review

       The file review portion of the checklist will evaluate many of the same pre-
  treatment program elements discussed in Sections V and VI, except it will rely
  on a different source of information.  Industrial user files will be reviewed
  to determine the extent to which the POTW is conducting compliance monitoring
  and taking enforcement actions.

       This file review will allow the reviewer to:

       o  Evaluate the POTW's control mechanism

       o  Determine if categorical pretreatment standards are being applied properly

       o  Assess the POTW's monitoring and inspection program (i.e., frequency,
          completeness, documentation)

       o  Predict the overall compliance rate of lUs with pretreatment standards

       a  Evaluate the POTW's overall recordkeeping system.

       The checklist contains specific questions to determine the adequacy of the
  POTW's activities as demonstrated by the industrial user files.  This section of
  the checklist allows the reviewer to record findings on five IU files.  Additional
  copies of this section of the checklist may be used where it is necessary to
  review mare than five IU files.  Appropriate narrative comments may be recorded
  on the supplemental comment sheet with the industry name and address.

5.2.11  Section X;  Evaluation and Summary

       Section X contains several questions which prompt the auditor to evaluate
  the information collected in the checklist Sections III through IX on each POTW
  pretreatment program element.  Several items require the auditor to provide a
  yes/no answer about the adequacy of these elements.  The auditor should use his/
  her best professional judgement for these items, basing this judgement en the
  effectiveness of the program as it has been implemented.  This section of the
  checklist also contains several questions designed to address the POTW's compliance
  with the requirements of the General Pretreatment Regulations.  Citations to
  specific regulatory provisions are provided and the auditor can indicate whether
  or not the POTW meets each basic provision.

       Finally, Section X enables the auditor to summarize the key findings of
  the audit and to recommend follow-up actions on the part of the POTW.  It is
  important that the audit summary distinguish between those actions the POTW is
                                      5-3

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  required to take based on the General Pretreatment Regulations, the terms of its
  NPDES permit, or its approved program and those actions which are recommended to
  the POW as good practices to improve its program.  Accordingly, space is provided
  for the auditor to identify areas in which the POTW's pretreatment program does
  not fully ccnply with either regulatory, NPDES permit, or approved program re-
  quirements and to suggest necessary corrective actions.  An example would be,
  "POTW is not enforcing TTO standards for metal finishers.  Required Action:
  Immediately notify lUs of noncompliance and notify Approval Authority of plans
  and schedule tor appropriate enforcement response."  Space is also provided to
  address needs for improvements in the pretreatment program's adequacy and
  effectiveness.  Each program area which is not adequately implemented and the
  recommended POTW actions to correct the deficiencies may be noted by the auditor.
  An example is, "The POTW's enforcement procedures and policies vary on a case-by-
  case basis and are not based on a documented enforcement management strategy.
  Suggested Action:  Develop a formal, written enforcement response strategy to use
  as a consistent guide for enforcement activities and submit to Approval Authority
  for review."

       Section X of the checklist is useful in preparing the audit findings and
  recommendations which are sent to the POTW.  It aids the auditor to distinguish
  between regulatory or permit requirements and program effectiveness issues.  This
  distinction between findings of POTW noncompliance and other reccnmendations for
  program improvements should be followed in the letter that is sent to the POIW
  containing the audit conclusions.

5.5.12  Supporting Documentation for Audit Checklist

       During the course of the audit, the auditor is asked to collect information
  which will be attached to the completed checklist.  As a reminder to the auditor,
  an attachnent cover sheet is included that can be checked off as information is
  collected during the audit.  If the Control Authority is notified of the audit in
  advance,  the auditor may wish to request this documentation ahead of time.

5.3  AUDIT CHECKLIST

       The complete checklist for performing POTW pretreatment program audits follows.
                                       5-4

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                     POTW PRETREATMENT PROGRAM AUDIT CHECKLIST
CHECKLIST CONTENTS:

	 Section I:
	 Section II:
	 Section III:
	 Section IV:
	 Section V:
	 Section VI:
	 Section VII:
	 Section VIII:
	 Section IX:
	Section X:
     Attachments:
Control Authority Background Information
POTW Pretreatment Program Fact Sheet
Legal Authority and Control Mechanism
Application of Pretreatnent Standards
Compliance Monitoring
Enforcement
Data Management and Public Participation
Program Resources
POTW File Review
Evaluation and Summary
Supporting Documentation for Audit Checklist
POTW NAME:
DATE(S) OF ONSITE REVIEW:
                          Title
                       Organization
Phone Number
   (Principal Reviewer)
                                   5-5

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                POTW PRETREATMENT PROGRAM AUDIT CHECKLIST


SECTION I:  CONTROL AUTHORITY BACKGROUND INFORMATION

INSTRUCTIONS:  Complete background information prior to on-sita audit.

A.  General Information:

       1)  Name of Permittee:  	

       2)  teiiling Address:    	
       3)  Pretreatment Contact Name:

                                Title:

                            Telephone:
       4)  Frequency of POTW pretreatment program reporting to Approval
           Authority (e.g., annually, quarterly):  	
       5)  tote of last POTW pretreatment program report:
       6)  Date of last PCI/Auditi  	  Circle type:  PCI     Audit

       7)  Comments on results of last PCI/Audit and last pretreatment program
           report:
       8)  Number of treatment plants:
                NPDES permit number(s)                 Plant name(s)
                                       5-6

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SECTION I:  CONTROL AUTHORITY BACKGROUND INFORMATION  (Continued)

B:  POTW Treatment Plant Information

(Complete this section for each treatment plant operated under NPDES permit
by the POTW)

       1)  Name of Treatment Plant:	

       2)  Location Address:  	_______^_        	
       3)  NPDES Permit Number:  	   Expiration Date:  	

       4)  POTW Treatment Plant Wastewater Flow

           Design Daily Average (Dry Weather):	mgd
           Actual Daily Average (Dry Weather):	 mgd
           Design Peak:  	 mgd

       5)  Sewer System:     	%  Separate	% Combined

       6)  Percent Industrial Flow:  	 %

       7)  Level of Treatment:                  8)  Type of Process(es):

            Primary              	        	
            Secondary	        	
            Tertiary             	        	
       9)   Method of Sludge Disposal:         10)  Quantity of Sludge:

            	 Land Application     	 dry tons/yr.
            	 Incineration         	dry tons/yr.
            	Landfill             	dry tons/yr.
            	 Public Distribution  	 dry tons/yr.
            	 Other (specify)      	 dry tons/yr.
      11)  Receiving Stream Name:

      12)  Stream Classification:
      13)  301(h) Waiver Applied for: 	Yes 	No, Granted: 	Yes 	No
           Date of Application:
           Date Approved or Denied:
      14)  If the treatment plant is not in regular compliance with its NPDES
           permit, list the parameters commonly violated and the suspected
           cause(s):

              Parameters Violated                     Cause(s)
Section I Completed By:  	   Date:
                 Title:  	  Telephone:
                                       5-7

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                    POTW PRETREATMENT PROGRAM AUDIT CHECKLIST

 SECTION II:  POTW PRETREATMENT PROGRAM FACT SHEET

 INSTRUCTIONS:  Complete entire Fact Sheet prior to on-site audit.  Parts B
                thru H should be completed based on the approved program
                documents identified in Part A.

A.  Inventory of Documents Comprising the Approved Pretreatment Program

     1)  Original Pretreatment Program Submission Approval Date:  	
     2)  Does NPDES permit contain pretreatment requirements or conditions?
          	Yes 	No

         If yes, attach a copy of NPDES pretreatment conditions (e.g.,
         reporting requirements, implementation requirements, etc.).

    3)  List in chronological order all program modification requests.  Indicate
        whether request was contained in a letter, annual report, or other,
        and Aether request was approved, denied, or not yet acted upon.

        Date of        Vhere       Brief Description of    Approval Authority
        Request      Contained      Nature of Request       Response and Date
    4)  Is the POTW currently operating under any consent decree, administrative
        order or other document which contains pretreatment program requirements?
        	Yes 	No

        If yes, attach copy.

B.  Legal Authority and Control Mechanism

    1)  POTW authority to implement and enforce pretreatment standards and
        requirements is contained in (cite legal authority):


        Date Enacted/Adopted  	
    2}  Are all Industrial Users  (IDs) located within the jurisdictional boundaries
        of the POTW?  	Yes   	No

        If no, what type of legal agreement provides the authority to enforce
        pretreatment standards in outlying jurisdictions?

        	 interjurisdictional agreement
        	 contracts with lUs
                         other (describe):
                                      5-8

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SECTION II:  POTW PRETREATMENT PROGRAM FACT SHEET  (Ccntinued)

    3)  If a multijurisdictional situation exists, do the approved program
        documents specify who should have lead responsibility for carrying out
        each aspect of the pretreatment program in the outlying jurisdiction?
        	Yes  	No	N/A

        If yes, identify who undertakes the following (POIW or outlying jurisdiction):

        establishing local limits
        issuing IU control documents
        receiving reports (BMRs, etc.T
        sampling and analysis 	
        inspections of lUs 	
        compliance tracking 	
        enforcement
        pretreatment program administration
    4)  Vfriat IU control mechanisms are intended to be used by the POIW?
        	 permits
        	 contracts
        	 orders
        	 sewer use ordinance (SUO) only
                          other (describe):                     	
    5)  According to the approved program documents, approximately how many
        IU permits or other control documents were intended to be issued by
        the POTW7  	

    6)  How often are the control documents intended to be reissued? 	

C.  Industrial User Characterization

     1)  How many TUs were identified in each of the following groups?

         	 categorical lUs
         	 significant* noncategorical lUs
         	 other regulated** noncategorical IUs
         	 other nondomestic users
                          TOTAL
         *The POTW has defined "significant" IU to mean:
        ** By "other regulated" IUs is meant IUs that the POTW surcharges,
           inspects, controls through a permit, or otherwise regulates, but
           which are not considered significant for purposes of the pretreat-
           ment program.

           The POTWs "other regulated" IUs include:	
     2)  Does the POIW intend to update its industrial waste survey
         (IWS)?    	  Yes	Uto   How often?  	
                                      5-9

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SECTION II:  PCHW PRETREATMEOT PROGRAM FACT SHEET (Continued)

D.  Local Limits

     1)  Does the program submission indicate historical problems caused by
         IU discharges?
         	 inhibition/upset (describe) 	
         	 pass through (describe) 	
         	 sludge (describe) 	
                      other (describe)   	
     2)  Attach a copy of the local limits contained in the approved program
         submission  	attached
                     	 no local limits exist

     3)  How were the local limits derived?
                   technical basis (describe) 	  	  	
                   preexisting in ordinance/ basis unknown
                   other (describe) 	
     4)  Does the POTW's NPDES permit(s) contain limits or monitoring require-
         ments for any toxic/priority pollutants?  	Yes  	No

         If yes, list pollutants:  	
         If yes, how many analyses per year for:

                       Influent   Effluent    Sludge

         metals        _^^__^   	   _____
         organics      	   	   	
         bicmonitoring            	
         EP toxicity                         	
E.   Standards and Requirements for Industrial Users

      1)  Do the approved program documents indicate that the POTW has lUs
          subject to any of the following requirements (indicate approximate
          number, if known):
                                              Yes   No     Approximate
                                                           Number
         a.  combined wastestream formula     	   	    	
         b.  production-based categorical     	   	    	
             standards
         c.  total toxic organic (TTO)        	   	    	
             limits
         d.  solvent management plans         	   	    	

      2)  Does the POTW have approval to grant removal credits to categorical
          lUs?  	Yes	No  If yes, list parameters: 	

      3)  Does the POTW have a spill prevention and control plan to address
          toxic discharges from lUs?  	Yes	No

      4)  Does the program include procedures for accepting hazardous wastes by
          truck, rail, or dedicated pipeline?  	Yes	No	N/A


                                       5-10

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 SECTION II:   POTW PRETREATMENT PROGRAM FACT SHEET  (Continued)

       5)   Does  the program include procedures for notifying His of Resource
           Conservation and Recovery Act (RCRA) obligations?  	 Yes 	 No

 F.  Compliance  Monitoring

    1)   Does  the  program submission establish a proposed frequency for
         conducting:
                                        Minimum Frequency (times/yr/IU)

                                      Categorical    Significant Noncategorical
        	 onsite  IU inspections  	  	
        	 POTW monitoring  of lUs 	  	,
        	self-monitoring  by lUs 	  	
        	reporting by IDs      	  	

 G.  Biforcement

    1)  Check those compliance/enforcement options that are available to
        the POTW  in the event  of IU noncompliance:

        	 notice or letter of violation
        	 establishment of IU compliance schedule
        	 revocation of permit
        	 injunctive relief
        _____________ fines; maximum amounti  $     /day/violation
        	criminal penalties
                        termination of service
   2)  Does the program submission highlight any particular lUs as being
       problem dischargers?

            IU Name                                 Reason
H.  POTW Resources

    1)  How many full-time equivalents (FTEs) will be committed to the
        POTW's pretreatnent program?  	FTEs
        (An FTE is sometimes referred to as a man-year.  For example, two
        persons working half-time all year are equivalent to one FTE.)

    2)  Which of the following equipment is to be available for
        pretreatment program implementation?  Indicate the number of units
        where possible.
                                               Number
    	 vehicle(s)                   	
    	 automatic sampler(s)         	
    	 flow meter(s)                	
    	portable pH meter (s)         	
    	 gas detector(s)              	
    	 self contained breathing     	
        unit(s)
    	other safety equipment
        (describe)  	
                                      5-11

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SECTION Hi  POIW PRETREATMENT PROGRAM FACT SHEET  (Continued)

      3}  How does the POTW intend to fund the pretreatment program?
                                               Percent of Total Funding
               POTW general operating fund
              ~IU permit fees
              "monitoring charges
              "industry surcharges
              "other (describe)	
                                        Total
  100%
      4)  What is the total estimated level of annual funding required to
          iitplenent the P0IW pretreatment program?
          $	/year
Other Supporting Connents;
SECTION II Completed By:
                  Title:
	  Date:
 Telephone:
                                      5-12

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                   PCTIW PRETREA1MENT PROGRAM AUDIT CHECKLIST

SECTION III.  LEGAL AUTHORITY AND CONTROL MECHANISM

INSTRJCTIONS:  Complete during on-site audit based on POTW interview.

A.  Legal Authority

     1)  Is the POTW.'s current legal authority (i.e., sewer use ordinance) the
         sane as that in the approved program?   	 Yes   	 No

         If nor provide reasons for any changes:  	
         If no, highlight the changes (deletions, additions and changes) on
         a copy of the ordinance, rules, regulations, etc. and attach them
         to the checklist.

     2)  Has the PO1W experienced any practical difficulty implementing and
         enforcing the provisions of its Sewer Use Ordinance (SUO) or other
         legal authorities?  	 Yes  	 No

         If yes, briefly explain:  	
B.  POTW Jurisdiction

     1)  Is the current jurisdictional situation the same as that documented
         in the approved program?  	 Yes  	 No

         If no, briefly describe any changes:  	
     2)  If all contracts or agreements necessary to regulate lUs in outlying
         jurisdictions were not officially enacted at the time the program was
         approved, have they since been enacted?  	 Yes  	No	N/A

     3)  Have procedures been implemented in outlying jurisdictions which
         adequately address the following:
         o  Updating industrial waste survey             	 Yes  	 No
         o  Notification of lUs                          	 Yes  	No
         o  Permit issuance                              	 Yes  	No
         o  Receipt and review of IU reports             	 Yes  	No
         o  Inspection and sampling                      	 Yes  	No
         o  Analysis of samples                          	 Yes  	No
         o  Enforcement                                  	 Yes  	No
         Briefly describe any deficiencies:  	
                                      5-13

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SECTION III:  LEGAL AUTHORITY AND CONTROL MECHANISM  (Continued)

C.  Control Mechanism

    1}  Is the POTW implementing the approved control mechanism (i.e., HI
        discharge permit system, contracts, etc)?  	 Yes  	 No

        If no, explain:	__^______	
    2)  Do all of the required lUs have current (unexpired) control documents?
        	Yes 	No

        If no, explain:  	


        Give number control documents issued/number, required: 	/	
        Give number currently expired:  	

    3)  If the control mechanism is an ordinance only, how are lUs notified
        of vdiat specific standards and requirements they must meet?


    4)  Does the POTW have a control mechanism for regulating lUs vdrose wastes
        are trucked to the POTW?  	Yes  	No
        	N/A

        Describe the control mechanism:
Other Supporting Comments;
Section III Completed by: 	Date:
                   Title: 	Telephone:"
                                      5-14

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                   POIW PRETREATMENT PROGRAM AUDIT CHECKLIST


SECTION IV:  APPLICATION OF PRETREATMENT STANDARDS

INSTRUCTIONS:  Cortplete during on-site audit based on POTW interview.

A.  Industrial User Characterization

    1)  How often has the POTW updated its Industrial Waste Survey (IWS) to
        identify new IUs or changes in wastewater discharges?  	
        Method used to update survey:

        	 review of newspaper/phone book
        	 review of pluntoing/building permits
        	 permit reapplication requirements
        	 onsite inspections
        	review of water billing records
         	other (describe)          	
    2)  Give the current number of IUs of each of the following types:

        	  I categorical IUs
        	  # significant noncategorical industries
        	  # other regulated noncategorical IUs
        	  # other nondomestic users
        	  TOTAL

    3)  Is the POTW's definition of "significant" IU the same as in the
        approved program?	Yes	No

        If no, explain: 	
    4)  How are categorical IUs identified and categorized?
    5)  Have any new IUs been added since the original IWS which are capable
        of causing interference or pass through or contribute significantly to
        the treatment plant's toxic loading?       Yes 	No

        If yes,  specify:  	


    6}  Have any new IUs been added since the original IWS which are located
        in outlying jurisdictions where the POTW has no inter jurisdictional
        agreements or IU contracts?	Yes	No

        If yes,  specify:  	
                                    5-15

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SECTION IV:  APPLICATION OF PRETREATMENT STANDARDS (Continued)

B.  Local Limits

    1)  Has the POTW made (or proposed) any changes to its local limits which
        have not been approved?  	Yes	No

        (Note that any changes to local limits should be submitted and approved
        before adoption.)

        Describe any unapproved changes (attach copy):  	
    2)  What was the principal reason for changing or proposing to change
        limits?
    3)  Did the POTW technically evaluate the need for local limits for at
        least the following six pollutants (See EPA Memorandum, "Local Limits
        Requirements for POTW Pretreatinent Programs," August 5, 1985):

                           Headworks Analysis     Local
                               Completed?         Limits Adopted?
                                                   Yes        No
        	Cadmium         	         	
        	 Chromium        	         	
        	 Copper          	         	
             Lead
             Nickel          2ZZZIZI         ZZHZ
             Zinc
    4)  Was site-specific monitoring data used in the calculations? 	Yes
        	No	N/A

        If yes, indicate types of site-specific data used:

        	sampling data:  	influent  	effluent  	sludge

        	ambient receiving water monitoring data
        	 biomonitoring data
        	 priority pollutant analyses
        	 other (specify) 	
    5)  How did the POTW identify pollutants of concern other than the basic
        six metals and evaluate the need for local limits for them?
    6)  If there is more than one treatment plant, were the local limits
        established specifically for each plant?	Yes 	No      N/A

    7)  Have there been instances of treatment plant inhibition/upsets during
        the past year? 	Yes	No

        If yes, briefly describe: 	
                                    5-16

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SECTION IV:  APPLICATION OF PRETREATMEOT STANDARDS (Continued)


     8)  Does the POTW attempt to determine if such inhibition/upsets are related
         to industrial wastes and to trace the problem to the IU?
               Yes 	No	N/A

     9}  Have there been instances of pass through the past year?
         	Yes  	No

         If yes, briefly describe: 	
    10)  If any NPDES permit violations have been caused by discharges of
         high-strength conventional wastes, what measures are being taken to
         correct the problem?
    11)  Have POTW workers experienced industrial waste related injuries or
         illnesses?  	Yes	No

         If yes, explain: 	


    12)  How many times were the following monitored for toxics during the past
         year?
                        Influent    Effluent     Sludge
         metals         	     	     	
         organics       	     	
         biomonitoring              	
         EP toxicity                             	

    13)  Has monitoring at the treatment plant shown a noticeable change in
         whole effluent toxicity or in the quantity of metals or toxic organics
         in influent, effluent or sludge?  	Yes 	No

         If yes, provide details:  	
C.  Standards and Requirements for Industrial Users

    1)  Has the POTW notified its industrial users of the pretreatment standards
        and requirements they must meet? 	Yes 	No

    2)  Does the POTW compare local limits against federal categorical stan-
        dards and apply the most stringent standards to categorical lUs?
        	Yes 	No	N/A

    3)  Is the method of remaining abreast of categorical regulations adequate
        to ensure that the POTW is prepared to properly implement categorical
        standards?  	Yes  	No	N/A

    4)  For industries with combined wastestreams, is the combined wastestream
        formula being correctly applied?	Yes 	No	N/A
                                   5-17

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SECTION IV:  APPLICATION OF PRETREATMENT STANDARDS  (Continued)

    5)  For IDs subject to production-based standards, do limitations in
        control documents incorporate them properly?
        	Yes  	 No	N/A

    6)  Are all applicable local, State, and federal standards included in
        control documents issued to IDs?	Yes 	 No

    7)  Are TTO standards or alternatives (solvent management plans or oil &
        grease monitoring) being implemented for lUs subject to TTO limitations?
        	 Yes 	No	N/A

    8)  If the POTW has removal credits authority, is it correctly granting
        removal credits to lUs? 	Yes 	No	N/A

    9)  If applicable, is the POTW maintaining its approved removal credits
        efficiency?  	Yes  	No 	N/A

   10)  Has the POTW notified lUs of RCRA obligations?
        	Yes  	No

   11)  Are all applicable categorical standards and local limits applied ta
        lUs whose wastes are trucked in to the POTW?
        	Yes 	No	N/A

   12)  If any of the answers to questions 1-12 are "no", briefly explain:
   13)  List below any available EPA guidance materials Which the POTW does
        not have, but should have:
Other Supporting Contents;
Section IV Completed by:  	Date:
                  Title:  	Telephone:"
                                    5-18

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                POTIW PRETREAIMENT PROGRAM AUDIT CHECKLIST

SECTION V:  COMPLIANCE MONITORING

INSTRUCTIONS;  Ccnplete during on-site audit based on POTW interview.

A.  Inspection and Monitoring

    1)  What is the current frequency (attach schedule, if available) for:

                                                  ttimes/year/ IU
                                        Categorical  Significant Nonoategorical
        1.  POTW sampling of Ills        	  	
        2.  POTW inspections of IDs     	  	
        3.  IU self-monitoring          	  	
        4.  IU reporting                	  	

    2)  Are the monitoring and reporting frequencies the same as those described
        in the approved program?
                                            Frequency        Reason for change
                                       same  less greater
         1.  POTW sampling of IU       	   	  	     	
         2.  POTW inspections of lUs   	   	  	     	
         3.  IU self-noni-toring        	   	  	     	
         4.  IU reporting              	   	  	     	

    3)  The following question is optional, at the discretion of the Approval
        Authority.  If any significant or categorical lUs were either not
        sampled or not inspected within the last year, then list the lUs and
        provide a reason,  (attach additional pages if necessary)

                                                               Date Inspection/
                                                                 Sampling is
            Name of IU                 Reason                      Planned
    4)  Are composite samples used to evaluate compliance with categorical
        standards when appropriate?	Yes  	No	N/A

    5)  Does the POTW sample for all regulated pollutants?       Yes  	No

    6)  Are samples split with industrial personnel:
        o if requested?       	Yes	No
        o if necessary to verify IU self-monitoring results?  	Yes 	No

    7)  Are chain-of-custody procedures employed (attach copy of chain of
        custody form, if available)?  	 Yes  	 No

    8)  Do all sampling and analytical procedures conform to EPA methodologies
        (including 40 CFR Part 136)?	Yes  	No
                                   5-19

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SECTION V:  COMPLIANCE MDNITORING  (Continued)

    9)  Indicate where the following pollutant analyses are performed
        (i.e., inhouse laboratory, contract laboratory, etc.) and method
        used  (AC, QC, GC/MS, wet chemistry, etc.):
        metals
        cyanide
        organics
   10)  Is a CA/QC program implemented for sanpling?	Yes  	No
        for analysis?	Yes  	No

   11)  Hew nuch time normally elapses between sample collection and obtaining
        analytical results? 	

   12)  Is the Control Authority prepared to take samples on short notice
        (i.e., vehicles, personnel, preservatives, etc. readily available)?
         	Yes  	No

         Briefly describe any deficiencies in demand monitoring capabilities.
   13}  Are sanpling location, techniques, preservatives, etc., clearly detailed
        for sanpling personnel before they take a sanple?  	Yes  	No

        Briefly describe any deficiencies in the ability to perform routine
        compliance monitoring.  	
   14)  Do the PCTW's inspections of IDs consist of:

             o  Inspection of manufacturing facility?       	 Yes   	 No
             o  Inspection of chemical storage areas?       	 Yes   	 No
             o  Evaluation of hazardous waste generation?   	 Yes   	 No
             o  Inspection of spill prevention and control
                procedures?                                 	Yes   	No
             o  Inspection of pretreatment facilities?      	Yes   	No
             o  Inspection of IU sanpling procedures?       	Yes   	No
             o  Inspection of lab procedures?               	Yes   	No
             o  Inspection of monitoring records?           	Yes   	No

B.  IU Self-Monitoring and Reporting

    1)  Are categorical His required to sanple for all pollutants regulated in
        the categorical standards?  	Yes  	No	N/A

    2)  Dees the POW routinely review the periodic IU self-monitoring reports
        and compare the results to the applicable pretreatment standards?
        	Yes  	No	N/A
                                    5-20

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 SECTION V:   COMPLIANCE MONITORING (Continued)

     3)   Have the following reports been received from all categorical lUs
         for vdiich the due date has passed?
                                       Nurrber Received       Number Required
         Baseline Monitoring Reports
           (BMRs)                       	        	
         Conpliance Schedule Milestone
          Reports                      	        	
         90-Day Final  Conpliance
          Reports                      	        	
         Periodic Self-Monitoring
          Reports                      	        	

         Is  the information contained  in these reports analyzed and verified
         by  the POTW?  	Yes 	No	N/A

    4)   Are lUs required  to report spills,  slug  discharges,  etc.,  to the
         POIW?   	Yes   	No

    5)   If  the answer to  any of questions  (l)-(4) is no,  briefly explain:
Other Supporting Conments;
Section V Ccnpleted by: 	Date:
                Title:  	Telephone:
                                   5-21

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                   POTW PRETREATMENT PROGRAM AUDIT CHECKLIST


SECTION VI:  ENFORCEMENT

INSTRUCTIONS:  Complete during on-site audit based on POTW interview.

     1)  Estimate the number of IUS that are currently in significant noncompliance
         with pretreatment standards and whether noncompliance results from
         lack of pretreatment facilities or O&M problems.

                                           Number of lUs In Non-Compliance
          a) Noncompliance with           Total    Lack of Treatment     O&M
             Categorical Standards        	         	        	
          b) Noncompliance with Local     	         	        	
             Limits

     2)  Estimate the number of lUs that are currently in significant non-
         compliance with:
                                               Number of lUs in Noncampliance
          a) Self-Monitoring Requirements               	
          b) Reporting Requirements                     	

     3)  Approximately how many (or what percent) of all the IUS were subject to
         any kind of enforcement action during the last 12 months?  	

     4)  Indicate whether the following types of compliance/enforcement actions
         have been used by the POTW during the past 12 months:
                                                     Yes        No
          Vsrbal warning                           	   	
          Written notice or letter of violation    	   	
          Issue compliance schedule                	   	
          Revoke permit                            	   	
          Consent decree                           	   	
          Civil penalties (fines)                  	   	
          Criminal penalties                       	   	
          Termination of service                   	   	
          Injunction relief                        	   	
          Other (Specify) 	        	   	

     5)  Has the Control Authority used any unusual enforcement techniques
         that are effective which other POTWs could benefit by knowing about?
         	 Yes  	No

         If yes, briefly describe:  	
     6)  Has the POTW published an annual notice of significant violators (40 CFR
         403.8(£)(2)(vii))? 	 Yes 	 No

     7)  Does the POTW require the development of compliance schedules when
         installation of pretreatment facilities or additional O&M is necessary
         for an IU to achieve compliance with applicable pretreatment standards?
                 Yes          No
                                      5-22

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SECTION VI:  ENFORCEMENT  (Continued)

     8)  How many  lUs are currently on compliance schedules?
         Have any of these lUs been allowed more than 3 years from the effective
         date of a categorical standard or local limit to achieve ccnpliance?
         	Yes  	ND

         If yes, provide details:	
     9)  Have all New Source Categorical lUs been ccnpliant from the first day
         of discharge ?  	Yes  	ND	N/A

    10)  Does the control authority have procedures that define the appropriate
         enforcement response and time frames to initiate the response for
         different types and patterns of IU violations?  	 Yes  	 No
         (if yes, attach a copy).

    11)  Provide the following information for all significant industrial users
         (SIUs) currently in significant noncompliance (Attach additional pages
         if necessary.):

                               Date of        Enforcement Action
            Name of SIU     1st Violation       Taken to Date       Date of Action
         The POW's annual report may include this information.  The appropriate
         sections of the report may be updated and substituted for the listing
         described above.

Other Supporting Garments;
Section VI Completed by: 	Date:
                  Title: 	Telephone;
                                      5-23

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                     POTW PRETREATMENT PROGRAM AUDIT CHECKLIST

SECTION VII:  DATA MANAGEMENT AND PUBLIC PARTICIPATION

INSTRUCTIONS:  Complete during on-site audit based on POTW interview.

A.  Data Management

    1)  Are files/records?  	conputerized	hard copy	both

    2)  Does POTW have an ample source of technical documents for
        implementing its pretreatment program?  	Yes   	No

    3)  Does the POTW keep apprised of current regulations?  	 Yes
        	No

        If yes, describe how:	
    4)  Are data on permit issuance and compliance status readily available?
        	Yes  	No

    5)  Are inspection and sampling records well organized and readily retrievable?
        	Yes	No

    6)  Can IU monitoring data be retrieved by:
o
o
o
o
o
o
o

o
Industry name
Pollutant type
Industrial category or type
SIC code _
IU discharge volume
Geographic location
Receiving treatment plant (i.e., if there
is more than one plant in the system)
Other (specify)
Yes
Yes
Yes
Yes
Yes
Yes

	 Yes _

No
No
No
No
No
No

	 No

    7)  Are all records maintained for at least 3 years?  	Yes  	No

B.  Public Participation

    1)  Are program records available to the public?  	Yes  	No

    2)  Have lUs requested that data be held confidential?  	Yes	No

    3)  Does the POTW have provisions to address confidentiality?  	Yes
        	No

    4)  Has public content been solicited during revisions to the SUO
        and/or local limits [403.5(c){3)]?  	Yes  	No	N/A

    5)  Are there significant public or community issues impacting the
        POTW'B pretreatment program?  	Yes  	No

        If yes, please explain:  	
Section VII Completed by: 	Date:
                   Title:                          Telephone:


                                      5-24

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                     POTW PRETREATMENT PROGRAM AUDIT CHECKLIST

SECTION VIII:  PROGRAM RESOURCES

INSTRUCTIONS:  Complete during on-site audit based on POTW interview.

A.  Personnel and Equipment

    1)  Does the POTW have the same or greater resources (full time
        equivalents and equipment) than was stated in the submission?
        	 Yes	 No

        If no, describe the nature of the reduced resources:
    2)  Are an adequate number of personnel available for the following
        program areas:

        o  IU sampling                                 	 Yes   	 No
        o  IU sample analyses                          	Yes   	 No
        e  IU inspections                              	 Yes   	 No
        o  Administration (including recordkeeping/
            data management)                           	 Yes   	 No
        o  Legal                                       	 Yes   	 No
        o  Data analysis, review and response          	 Yes   	 No

    3)  Do available personnel have appropriate
        training?                                      	 Yes   	No

    4)  Is the available sampling equipment adequate?  	 Yes   	 No

    5)  Is the available safety equipment adequate?    	 Yes   	 No

    6)  Is the number of vehicles available adequate?  	 Yes   	 No

    7)  Does the POTW have access to adequate analytical
        equipment?                                     	 Yes   	 No

        o  Conventional pollutant analysis equipment (i.e.,
           lab oven, precision balance, pH meter)      	 Yes   	 No
        o  Atomic adsorption spectrophotometer         	 Yes   	 No
        o  Gas chronatograph                           	Yes   	No
        o  Gas chronatograph/mass spectrometer         	 Yes   	No

B.  Funding

    1)  Is the POTW's annual budget for progran implementation the same or
        greater than that projected in the POTW submission?
        	 Yes  	No

        If no, describe the reason(s) it is less:  	
                                 5-25

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SECTION VIII:  PROGRAM RESOURCES  (Continued)

     2)  Have any problems in program inplementation been observed vrfiich appear
         to be related to inadequate funding?  	Yes  	No

         If yes, describe: 	
     3)  Is funding expected to continue near the current level?  	 Yes
         	No (Increase	Decrease	)
Other Supporting Ccmnents;
Section VIII Completed by:  	   Date:
                  Title:                               Telephone:
                                    5-26

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                   POIW PRETREATMENT PROGRAM AUDIT CHECKLIST

SECTION IX:  POTW FILE REVIEW

INSTRUCTIONS:  Review the POTW's files on a representative sample of SIUs
               (at least 5 files), attempting to include at least two significant
               noncomply.ing IDs and two categorical lUs.  If the question is
               correct or should be answered yes, mark with an "X."  If the
               appropriate response is none or no, then mark an "0."  Numerical
               responses may also be required.  Narrative comments should be
               recorded in part G.

                                            IU #1  IU #2  IU 13  IU #4  IU #5

A.  File Contents

    1)  Does the IU file contain:
        a) Industrial waste survey
            information?
        b) Description of wastewater
            flows and pollutants?
        c) Discharge permit application?
        d) Control document?
        e) POIW sampling results?
        f) POTW inspection report(s)?
        g) IU reports (BMR, 90-day, etc.)?
        h) IU self-monitoring results?
        i) Correspondence?
        j) Telephone log?
        k) Meeting notes?
        1) Determination of IU compliance
            status?

B.  Control Mechanism Evaluation            IU II  IU #2  IU 13  IU #4  IU #5

    1)  Is the IU discharge permit,
         contract, etc. current (i.e.,
         unexpired)?
    2)  Daes it cite the POTW's
         legal authority?
    3)  Does it contain correct
         discharge limitations?
    4)  Are types of samples for
         self-monitoring specified?
    5)  Is sample location(s)
         identified?
    6)  Are applicable IU reporting
         requirements specified?
    7)  Are standard conditions
         included for:
        o Right of entry?
        o Records retention?
        o Penalty provisions?
        o Revocation of permit?
        o Nontransferability?
        o Notice of slug loading?
        o Permit expiration date?
                                      5-27

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SECTION DC:   POTW FILE REVIEW (Continued)

C.   POTW Compliance Monitoring Evaluation        IU  II   IU  12   IU  »3   IU  »4   IU  15

     Within the  last twelve months:
     1)  How many times  was the IU  inspected?
     2)  Approximately how many sanpling
         visits  were made to  the IU?
     3)  Were all the parameters specified
         in the  control mechanism  evaluated?
     4)  Indicate TTO monitoring status*
     5)  Are monitoring  results well documented?
        o Date sample taken
        o Type of  sample
        o Sampler  name
        o Condition of  sample,
         preservatives added,  etc
        o Chain  of custody form
        o Analytical procedures used

     6)  Did the  IU inspection report have
        adequate documentation to  support
       potential  enforcement actions?
        Did it include:

       o Date  and time of inspection?
       o Name  of ccnpany official contacted?
       o Verification of production and flow
          rates,  if needed?
       o Identification of  sources and types   _
           of wastewater (regulated, unregulated,
           dilution flow, etc.)?
       o  Problems with pretreatment facilities?
       o  Evaluation of IU self-monitoring
          equipment and methods?
       o  Other (describe)
D.  IU Self-Monitoring Evaluation               IU »1  IU »2  IU #3  IU »4  HJJJ5

    1)  Have periodic IU self-monitoring
         reports been submitted?
    2)  Were the required parameters
         evaluated?
    3)  Did the IU comply with the
         reporting requirements in the
         control mechanism?
*(N) not regulated, (M) monitoring data submitted, (S) solvent management plan
 submitted, (U) monitoring data/SMP required but not included in file.
                                      5-28

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SECTION  IX:  -  POTW FILE REVIEW (Continued)

E.  POTW Enforcement Initiatives                IU »1  IU »2  IU__#3   IU  14   IU 15

    1)   Did the POIW identify all
         IU violations:
         o In POTW monitoring results?
         o In IU self-monitoring results?
    2)   Was the IU notified of all
         violations?
    3)  Was compliance/enforcement action
         taken by the POTW?
    4)   Did the POTW's action result in
         the IU achieving ccnpliance
         within 3 months?

F.  Skills/Slug Loading                      IU *1  IU »2  IU »3  IU  »4  IU  15

    1)  Has the industry been responsible
         for spills or slug loads
        discharged to the POTW?
    2)   If yes, does the file contain
        documentation regarding:
          a) Notification by the IU of
             the spill or slug?
          b) POIW response to notification?
          c) POTW response to the
             discharge?
          d) the effect of the spill
             on the POTW?
Notes:
                                   5-29

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SECTION  IX:  POTW FILE REVIEW  (Continued)

G.  Narrative Garments Fran POIW File Review
FILE 1
Industry Name 	
Industry Address
Type of Industry
Cements:
File/ID No.
Flow(gpd);
SIC:
FILE 2

Industry Name 	
Industry Address
Type of Industry
Comments:
File/ID No.
Flow(gpd)•
SIC:
FILE 3

Industry Name 	
Industry Address
Type of Industry
Comments:
File/ID No.
Flow(gpd)i
SIC:
FILE 4

Industry Name 	
Industry Address
Type of Industry
Comments:
File/ID No.
Flow(gpd):
SIC:
FILE 5
Industry Name 	
Industry Address
Type of Industry
Comments:
File/ID No.
Flow(gpdjT
SIC:

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                   POTW PRETREATMENT PROGRAM AUDIT CHECKLIST
SECTION X:  EVALUATION AND SUMMARY

INSTRUCTIONS:  Complete during or after on-site audit based on reviewer's
analysis of program documentation and implementation.  Distinguish between
required POTW actions necessary to achieve compliance with the POTW permit,
approved program, or General Pretreatment Regulations and recatimended actions
to improve or refine the existing program.

A.  legal Authority and Control Mechanism (Section III)

    1)  Does the POTW have adequate legal authorities to implement and enforce
        pretreatment standards and requirements upon all nondomestic/industrial
        users (i.e., mobile sources, lUs in outside jurisdictions)?
        	 Yes  	No

    2)  If the POTW's legal authority has been changed since program approval,
        does it still have the requisite authorities per 40 CFR 403.8(f)(l) to:

                                                                   Yes    ]to
           Deny or condition new or increased contributions (i)    	    	
           Apply and enforce pretreatment standards (ii)           	    	
           Control each IU through permit, contract, etc. (iii)    	    	
           Require development of IU compliance schedules (iv)(A)  	    	
           Require submission of IU reports (iv)(B)                ___    	
           Conduct IU inspections and sampling (v)                 	    	
           Obtain remiedies for nonconpliance (vi)(A)              	    	
        0  Halt or prevent discharges (vi)(B)                      	    	
        0  Comply with confidentiality requirements (vii)          	    	

    3)  Have effective procedures been established to implement interjurisdictional
        agreements?  	Yes  	No	N/A

    4)  Has the POTW implemented an adequate control mechanism to regulate:
                                                          Yes       No
        0  Categorical industrial users?                  	      	
        0  Significant noncategorical industrial users?   	      	
        0  Waste haulers?                                 	      	

    5)  Has the POTW issued all of the necessary control docunents?
        	Yes	No

    6)  Describe required POTW actions necessary to achieve compliance with
        legal authority requirements:
    7)  Describe recommended POTW actions to improve the existing legal authority
        and interjurisidictional agreements.
                                   5-31

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SECTION X:  EVALUATION AND SUtWARY (Continued)

B.  Application of Pretreatment Standards (Section IV)

    1)  Has the POTW developed technically based local limits that will
        sufficiently protect the POTW treatment plant from interference,
        pass through/ and sludge contamination and protect worker safety
        [403.5(c) and (d)]?  	Yes 	No

    2)  Are pretreatment standards (local limits and categorical standards)
        being properly applied to all industrial users, including:
                                                           Yes     No
           Correct categorization of industries
           Application of more stringent standard
            (local limits vs. categorical standards)
           Designation of proper sampling location(s)
           Application of production-based standards
           Use of the combined wastestream formula
           Sample type and frequency
           Use of an effective control mechanism
           Other
    3)  Is the POTW implementing adequate procedures per
        40 CFR 403.8(f)(2) to:
                                                           Yes     No
        0  Identify and locate all lUs (i)                 	    	
        0  Notify lUs of all applicable standards
            and requirements including RCPA (iii)          	    	

    4)   Describe required POTW actions necessary to adequately apply pretreatment
        standards:
    5)   Describe reconinended POTW actions to improve the POTWs applicaton of
        pretreatment standards:
                                    5-32

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SECTION X:  EVALUATION AND SU*IAK5f  (continued)

C.  Compliance Monitoring (Section V)

    1)  Docs the POTW perform (in oontoination with IU self-monitoring) adequate
        inspections and sailing of its IUs, consistent with 40 CFR 403.8
        (f)(2), to:

                                                               Yes     No

        0  Identify the character and volume of pollutants     	    	
            from all IUs (ii)
        •  Receive and review industrial user reports (iv)     	    	
        •  Assess industrial user compliance (v)               	    	
        e  Investigate instances of nonconpliance (vi)         	    	
        *  Produce admissible evidence in an enforcement       	    	
            action (vi)

    2)  Does the POTW implement the categorical IU reporting requirements
        as specified in 40 CFR Part 403.12?  	yes	No
    3)  Describe required POIW actions necessary to comply with all compliance
        monitoring requirements:
    4)  Describe reocranended POTW actions to improve the POIW's compliance
        monitoring program:
D.  Enforcement (Section VI)

    1)  In the event of IU nonconpliance, does the POTW take appropriate and
        necessary enforcement action to bring IUs back into compliance in a
        timely manner?  	Yes  	No
                                    5-33

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SECTION X:  EVALUATION AND SUMMARY (Continued)
     2)  Describe required POTW actions necessary for proper enforcement of all
         pretreatment standards and requirements:
     3)  Describe reccmnended POTW actions to improve enforcement of pretreatment
         standards and requirements:
E.  Data Management and Public Participation (Section VII and IX)

    1)  Does implementation of the POTW's pretreatment program include:

                                                                Yes    tto_

        *  Annual publication of significant violators
            C403.8(f)(2)(vii)]
        *  Notice to interested parties vrtien local
            limits are developed [403.5(c)(3)]
        *  Adequate procedures for handling confidential
            information [403.14(a)]
        •  Unrestricted access to effluent data provided
            to the public [403.14(b)]
        *  Maintenance of records for at least three years
            [403.12(n)(2)]
        •  Well-documented activities in IU files

    2)  Describe required POTW actions necessary for compliance
        with data management and public participation requirements:
                                    5-34

-------
 SECTION X:   EVALUATION AND SUMMARY (Continued)

     3)   Describe reccrmended POTW actions to iitprove data ttanagement and public
         participation:
F.   Program Resources

     1)   Does the POTW have  adequate personnel,  equipment,  supplies,  and funding
         and technical guidance documents  to effectively implement all  elements
         of  its pretreatment program [40 CFR 403.8(f)(3)J?

                  Yes          No
    2)  Describe the required POTW actions necessary to comply with  all  resource
        requirements:
    3)  Describe recontnended POTW actions to improve its ability to implement
        its pretreatment program:
Section X  Completed by:  	Date:
                  Title:  	Telephone:
                                     5-35

-------
               SUPPORTING DOCUMENTATION
                         FOR
                   AUDIT CHECKLIST
NPDES permit conditions for pretreatment program development
or implementation (II.A)

Copy of administrative order, consent decree or other document
containing pretreatment program requirements {II.A)

Copy of local limits from the approved program (II.D)

Copy of POTW SUO if changed since program approval (III.A)
(Highlight the changes that have been incorporated.)

Copy of local limits if changed since program approval (IV.B)

POTW sampling and inspection schedule for regulated lUs (V.A)

List of lite not sampled or not inspected in the past year (V.A)
(Optional)

Copy of POTW chain-of-custody form (V.A)

List of all nonconpliant industries and history of enforcement
actions taken (VI)
                         5-36

-------
                APPENDIX A
              EPA MEMORANDA
FROM J. WILLIAM JORDAN AND MARTHA PROTHRO
        INSTRUCTIONS FOR COMPLETING
               FORM  3560-3

-------
         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                       WASHINGTON. D.C. 20460
                            . ..,   -  ---                   OFFICE OF
                            '•'"                           WATER


MEMORANDUM

SUBJECT:  NPDES and Pretreatraent Inspection Reporting  for
          FY 19Jjfjl:> OffQ2&y-idJSvWateftr Accountability System

FROM:    (^jJmiJ^am^OT?l^n^lJirec,tor  |
          Enforcemeirt Division (ENV338)

TO:       Water Management Division Directors, Regions I-X
          Environmental Service Division Directors, Regions  I-X


     In FY 1986, the Office of Water Accountability System will
require EPA and State commitments for POTW pretreatment  inspections,
industrial user pretreatment inspections, NPDES inspections, and  a
commitment to inspect each major facility during the year  (EPA and
State inspections combined).  For this measure, the list of  major
facilities will be those designated as major in PCS as of July 31,
1985*  The inspection strategy encourages Regions to use resources
efficiently.  This can be accomplished by combining the  pretreatment
inspection for the POTW and/or the industrial user with  an NPDES
inspection.  The purpose of this memorandum is to provide guidance
for reporting NPDES and pretreatment inspections in PCS  and  to
confirm that all inspections, including pretreatment inspections,
will be tracked on a one quarter "lag" basis.

     We will not allow the entry of multiple inspections at  a
single facility on a single day, but it will be acceptable to enter
the code for the POTW pretreatment inspection or industrial  user
pretreatment inspection on the day(s) following the other NPDES
compliance inspection.  This method should only be used  for
pretreatment inspections and static biomonitoring inspections that
are coupled, with other NPDES compliance inspections.   Any other
multiple inspections at a single facility within a five  day  period
must have reasonable justification.

     If the inspection involves an industrial user(s), a separate
entry should be made with the inspection type "I" and  the POTW
permit number.  You must also indicate the number of lUs covered
during the inspection under comments in Columns 21 through  23.
                           A-l

-------
                              - 2 -


Please "right justify" the number in these three columns (e.g.,
"003" for 3 IU's that have been inspected).   This approach will
allow us to track pretreatment inspections of industrial users and
POTWs separately.  W« can also separate IDs  in approved POTWs from
those in unapproved POTWs based on their approval status data.  A
'Y1 in the Pretreatment Program Required Indicator (PRET) indicates
an approved POTW in PCS.

     Although we are not presently requiring detailed lists of the
name and SIC code for each industrial user inspected, this informa-
tion should be maintained by the Regions.  We may request this
information later to help develop an inspection strategy for
industrial users.  If you have any questions concerning this issue,
please call either Gary Polvi at (FTS 475-8313) or Ed Bender at
(FTS 475-8331).

cc: PCS User Group
                              A-2

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          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                         WASHINGTON. O.C. 20460
                           AUG30I985                   OMieiOP
                                                         WATER


 MEMORANDUM


 SUBJECT:  Audits of POTWs with Approved Pretreatment
          Programs

 FROM:     Martha G. Prothro, Director ^V .  \Y.  .    O AC  -^
          Permits Division (EN-336)   v'\^-V^-C^  N VCT^VC,

 TO:       Water Management Division Directors
          Regions I-X


     The purpose of this memorandum is to provide  final draft
 procedures for conducting a POTW pretreatment audit and to describe
 Headquarters tracking of audits in FY 86.  We solicit your comments
 of the final draft audit procedures by September 16, 1985.

     In FY 85, EPA Regions conducted 59 audits of  POTWs with
 approved pretreatment programs and States performed additional
 audits.  The local pretreatment program audit is a detailed
 on-site review of an approved program to determine its adequacy.
 The audit report identifies needed modifications to the approved
 local program and/or the POTW'3 NPDES permit to address any
 problems.  The audit includes a review of the substantive require-
ments of the program, including local limits, to ensure protection
 against pass through and interference with the treatment works
 and the methods of sludge disposal.  The auditor reviews the
 procedures used by the POTW to ensure effective implementation
 and reviews the quality of local permits and determinations
 (such as implementation of the combined wastestream formula). In
 addition, the audit includes all the elements of a pretreatment
 compliance inspection (PCI).

     The draft PCI was distributed to the Regions  by Bill Jordan
 of the Enforcement Division, OWEP, for review and  comment on
 August 5.  Regions and States will need a capability to conduct
 both audits and inspections.  We recommend that audits be per-
 formed first at (1) POTWs which have been approved for one year
 or longer and have not previously been audited, and at  (2) POTWs
 which are within one year of permit reissuance.  As a minimum,
 roughly 20% of all POTW pretreatment programs must be audited
 in each fiscal year to assure adequate oversight of local
 programs during each five year permit term.  All Regions have
                              A-3

-------
                              - 2 -

informally committed to FY 86 SPMS outputs for audits consistent
with  this approach.  (All POTWs that are not audited in a given
year  should have a PCI as part of the routine NPDES inspection
at that  facility.)

      The POTW audit checklist contains 10 sections (I thru X)  as
shown in the checklist table of contents (Appendix A).  The PCI
generally consists of six of these sections (I, II, III, VI,  VII
and X).  Although an audit includes all the elements of a PCI,
the activity should not be counted as both an audit and a PCI.
If the on-site POTW review does not include all the aspects of
an audit (checklist Sections I thru X), it may still be counted
as a  PCI (assuming all elements of a PCI are addressed), but  it
may not be counted as an audit.

     Our current plan (subject to OW and OMSE agreement) is that
for purposes of reporting, audits will be tracked at Headquarters
based on retrievals from the Permit Compliance System (PCS) on
a "lag" basis similar to that traditionally used for NPDES
compliance monitoring inspections.  Further instructions on
entry codes, audits with industrial user inspections, and other
procedures will be provided early in FY 86.  The audit will not
be counted as completed and entered into PCS until the audit
checklist has been completed, the auditor's reviewer or supervisor
has signed the completed 3560-3 form and the audit has been
officially sent to the POTW.  Tracking from PCS in FY 86 will be
conducted according to the following schedule:

            AUDITS                        RETRIEVAL DATE

July  1, 1985 through September 30, 1985   NO REPORT
Oct.  1, 1985 through December 31, 1985    April 2, 1986
Oct.   1, 1985 through March 31, 1986       July 2, 1986
Oct.  1, 1985 through June 30, 1986        October 1, 1986
July  1, 1986 through September 30, 1986   To be credited in FY 87
                                            first quarter report

     An OWEP strategy for conducting local pretreatment program
audits and inspections is being prepared.  The strategy will
describe FY 86-87 implementation activities, plans for additional
guidance, training, workshops and assistance, and clarification
of EPA and State roles and responsibilities.  Rebecca Hanmer
will discuss this strategy at the September Water Management
Division Directors meeting.

     Please let me know if you have any comments on the attached
audit checklist or our reporting requirements or if you have any
suggestions on how to make it work more effectively.  You may
contact me at 755-2545 or ask your staff to submit comments to
Jin Gallup (755-0750) by September 6, 1935.

Attachment

cc:  Rebecca Hanmer
      Jim Elder
      Bill Jordan
      Regional and State Pretreatment
       Coordinators


                               A-4

-------
       UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                     WASHINGTON. D.C. 20460
                        DEC 16  1965
                                                    OFFICE OF
                                                     WATER
MEMORANDUM

SUBJECT       Pretreatment Audit Reporting Requirements

FROM:         Martha G. Prothro, Director CNK p, \V\    Nr1
              Permits Division (EN-336)   V^^*-**^- ^

TO:           Water Management Division Directors
              Regions I-X


     My August 30, 1985 memorandum to you provided final draft
procedures for conducting a POTW pretreatment audit and described
Headquarters tracking of audits in FY 1986 (see attachment).
The purpose of this memorandum is to provide further instructions
on audit tracking and Region/State PCS data entry requirements.
A final pretreatment audit/inspection procedures guidance document
should be issued by Rebecca Hanmer in the very near future.

     As stated in the aforementioned memorandum, for purposes of
reporting, audits will be tracked at Headquarters based upon
retrievals from PCS on a one quarter "lag" basis.  The schedule
in the August 30 memorandum for audit and PCS retrieval dates is
still valid.  Audits are not counted as complete and should not
be entered into PCS until the audit has addressed all th^ subiects
contained in the checklist, form 3560-3 has been completed and
signed, and a letter containing the audit findings and recommendations
has been officially sent to the POTW.  Once the audit is complete,
the Region/State should enter the appropriate information from
form 3560-3 into PCS.  Particular attention must be paid to data
entered from two fields:  Inspection Type (Column 18) and Inspection
Date (Columns 12-17).  We have established the code "G" to describe
pretreatment audits.  This code should be entered in Column 18.
Enter the date the POTW site visit was conducted in Columns 12-17.
See Example 1,form 3560-3 (attached).Section D should be completed
by either providing a short summary of the audit results or attaching
the letter transmitting the checklist and audit findings and recom-
mendations to the POTW.

     The Office of Water Accountability System will track
industrial user (ID) pretreatment inspections in FY 1986.  For
those IU inspections performed as part of a POTW pretreatment
audit, data entry requirements are basically the same as those for
IU inspections performed in conjunction with POTW pretreatment
inspections.
                           A-5

-------
                              -2-
Those requirements are discussed in the August 6, 1985 memorandum
from Bill Jordan to the Regions (copy attached).   Because multiple
entries for a single facility on a single day are not permitted
in PCS, a separate entry should be made with the  Inspection Type
code "U" in Column 18 (rather than "I" used for IU inspections
performed in conjunction with pretreatment inspections),  the
receiving POTW1s permit number in Columns 3-11, and the date
following the pretreatment audit site visit date  in Columns
12-17.  Regions/States should also indicate the number of lU's
inspected in conjunction with an audit using Columns 21-23 of
the comments section of form 3560-3.  This number should be
"right justified" in these columns (e.g., "003" for three lU's
inspected).  See Example 2, form 3560-3 (attached).  Guidance on
industrial user inspections will be provided by the Enforcement
Division in OWEP.

     Please contact me or have your staff call Jim Gallup of my
staff (FTS: 755-0750) if you have any questions or comments on
these reporting requirements.


Attachments
cc:  Rebecca Hanmer
     Bill Jordan
     Ed Bender
     Larry Reed
     Dela Ng
     Regional and State Pretreatment Coordinators
                            A-6

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                                                                                          cxampie  a.
f% J— M « WMhcngton. 0 C 20*60
VS'trA NPDES Compliance Inspection Report
i[N| 1_S| 3|X|X|Q|0|0|0|0|0[g|ii dfl*l/|0|2|Yli7 iEl3 ,df
1 1
flmrved Facility Evaluation Rating
67ULJJ 69 7C$j

All American VWTP
1 USA Drive
Everywhere, New York 999?
NameiS) of On-Sne Representative!*}
John Smith
Same as above

-------
   vEPA
                                         Wainmgion. 0 C 2046O
                    NPDES  Compliance Inspection Report
                                                              OMB No  2040-0003
                                                              Approval  Enoires 7.31 95
                                            Section A: National Data System Coding
   Transaction Code
            IS!
                                NPQES
                                                       yr/mo/day
                                                                    Inspection Type     Inspector      F»c Type
                                                   Remarks
                                               M     M
                                                             !   1  1  1   !     1  !
                                                                II     1   1  1   1
 2!
      Reserved      Facility Evaluation Rating
   67{   |  |   |69     7CU
                                           61         0-A           	Reserved	
                                        7lU      'tJ        *3l   I  I 74      7d  |   !  I   I  I   180
                                                Section B: Facility Data
  Name and Location  ol Facility inspected
                                                                         entry Time
                                                                                     AM    PM
                                                                         Exit T.me. Date
                                                                                            Permit Effective Date
  rMameisi ct On-Site Representatives)
                                                    Titleis)
                                                                                                   Phone Nois)
  Name. Aaoress at ResponsiOie Official
                                                    T,ue
                                                    Pnone .No.
                                                                                                        Comac;ea
                                                                                                      D Yes D rJo
                                          Section C. Areas Evaluated During Inspection
                                 (S = Satisfactory M = Marginal. U = Unsatisfactory. N = Not Evaluated)
Permit
Records/Reports
Facility Sue Review
  Flow Measurement
  Laboratory
I  Effluent.-Receiving Waters
Pretreatment
Compliance Schedules
Self-Monitoring Program
                                                                                                 Operations 4 Maintenance
                                                                                                 Sludge Disposal
                                                                                                 Other
                           Section O: Summary ot Findings/Comments /Attach additional sheets /> necessaryl
     Guidance  on  industrial  user inspections  will be  provided  by  the  Enforcement Division.
  Named: and Signature);) ot Inspectors)
                                      Agency/ Office/ Telepnone
                                                                                                Date
  Signature o( Reviewer
                                             Agency/ Off ice
                                                                                                 Date
                                                 Regulatory Office Use Only
  Action Ta*en
                                                                              Date
                                                                                                 Compliance Status
                                                                                                   1  ! Moncomoliance
                                                                                                   1 _ ! Comoliance
EPA Form 3560-3 (H«w. 3-8SI Previous editions are oosolete.
                                                            A-8

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       APPENDIX B

SAMPLE FOLLOW-UP LETTER
TO THE CONTROL AUTHORITY

-------
 (Name of Control Authority Manaqer)
 (Address of Control Authority)

 Dear                       :
     As you are aware, a  (Pretreatment Compliance Inspection/Pretreabrent Program
Audit) was conducted at your facility (NPDES #) on  (date of event).  This
(inspection/audit)  indicated that your facility exhibited the following deficiencies
in its pretreatment program when compared to applicable pretreatment regulations,
your facility's NPDES permit, and/or your facility's approved pretreatment program
submission:

     0  (List such deficiencies)
     In addition, we suggest that your facility remedy the following deficiencies
to improve the effective implementation of your facility's pretreatment program:

     0  (List such deficiencies)
     We request that within 15 days of receipt of this letter you  inform us by
written response of the proposed corrective actions which will be  undertaken at
your facility to address the deficiencies listed here.

     Attached is a summary describing in general terms the results of the
(Pretreatment Compliance Inspection/audit) at your facility.  Note that the
absence on the summary report of any of the deficiencies listed in this letter
does not excuse you from the above request to perform coorective actions to remedy
deficiencies.

     If you have any questions regarding this matter, please contact (name of
Approval Authority representative) at (telephone number of Approval Authority
representative) as soon as possible.

                                           Yours truly,
                                           (Name and signature of
                                           Approval Authority representative)
Attachment
                                        B-l

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             APPENDIX C
POTW PRETREATMENT PROGRAM PACT SHEET

-------
                       POTW PRETREATMENT PROGRAM FACT SHEET

  SECTION II:   POTW PRETREATMENT PROGRAM FACT SHEET

  INSTRUCTIONS:   Complete  entire Fact  Sheet prior to on-site audit.   Parts  B
                 thru  F should  be completed based on the approved program
                 documents identified  in Part A.

A.   Inventory  of Documents  Comprising the Approved Pretreatment  Program

      1)  Original  Pretreatment Program  Submission Approval Date:  	
      2)  Does NPDES permit contain pretreatment  requirements or  conditions?
          	Yes 	No

         If yes, attach  a copy of NPDES pretreatment conditions  (e.g.,
         reporting requirements, implementation  requirements, etc.).

    3)  List in chronological order all program  modification requests.  Indicate
        whether request  was contained in a letter, annual report, or other,
        and whether request was approved, denied, or not yet acted upon.

        Date of   Where           Brief Description of     Approval Authority
        Request   Contained       Nature of Request          Response and Date
    4)  Is the POTW currently operating under any consent decree, administrative
        order or other document which contains pretreatment program requirements?
        	Yes 	No

        If yes, attach copy.

B.  Legal Authority and Control Mechanism

    1)  POTW authority to implement and enforce pretreatment standards and
        requirements is contained in (cite legal authority):


        Date Enacted/Adopted  	
    2)  Are all Industrial Users (lUs) located within the jurisdictional boundaries
        of the POTW?  	Yes   	No

        If no, what type of legal agreement provides the authority to enforce
        pretreatment standards in outlying jurisdictions?
                         interjurisdictional agreement
                         contracts with lUs
                         other (describe):  	   	
                                  C -1

-------
SECTION II:  POTW PRETREATMENT FACT SHEET (Continued)

    3)  If a nultijurisdictional situation exists, do the approved program
        documents specify who should have lead responsibility for carrying out
        each aspect of the pretreatroent program in the outlying jurisdiction?
        	Yes  	No 	N/A

        If yes, identify who undertakes the following (POTW or outlying jurisdiction);

        establishing local limits 	
        issuing IU control documents
        receiving reports (BMRs, etc.T
        sampling and analysis 	
        inspections of lUs 	
        compliance tracking 	
        enforcement
        pretreatment program administration
    4)  What IU control mechanisms are intended to be used by the POTW?
        	 permits
        	 contracts
        	 orders
        _^___________ sewer use ordinance (SUO) only
           	 other (describe):  	
    5)  According to the approved program documents, approximately how many
        IU permits or other control documents are intended to be issued the
        POTW? 	

    6)  How often are the control documents intended to be reissued? 	

C.  Industrial User Characterization

     1)  How many lUs were identified in each of the following groups:

         	 categorical lUs
         	 significant* noncategorical lUs
         	 other regulated** noncategorical lUs
         	 other nondomestic users
                          TOTAL
         *The POTW has defined "significant" IU to mean:
        ** By "other regulated" lUs is meant lUs that the POTW surcharges,
           inspects, controls through a permit, or otherwise regulates, but
           which are not considered significant for purposes of the pretreat-
           ment program.

           The POTW's "other regulated" lUs include:	
     2)  Does the POTW intend to update its industrial waste survey
         (IWS)?         Yes        No   How often?  	
                                  C-2

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SECTION  II:  POIW PRETREATMENT PROGRAM FACT SHEET  (Continued)

D.  Local Limits

     1)  Does the program submission indicate historical problems caused by
         IU discharges?
         	 inhibition/upset (describe) 	
         	 pass through  (describe) 	
         	 sludge  (describe) 	
                      other (describe)
     2)  Attach a copy of the local limits contained in the program
         submission  	attached
                     	 no local limits exist

     3)  How were the local limits derived?
                   technical basis (describe)
                   preexisting in ordinance, basis unknown
                   other (describe) 	
     4)  Does the POTW's NPDES permit(s) contain limits or monitoring require-
         ments for any toxic/priority pollutants?  	Yes  	No

         If yes, list pollutants:  	
         If yes, how many analyses per year for:

                      Influent   Effluent    Sludge

         metals        	   	   	
         organics      	   	   	
         bicmonitoring
         EP toxicity
E.   Standards and Requirements for Industrial Users

     1)  Do the approved program documents indicate that the POTW has lUs
         subject to any of the following requirements (indicate approximate
         number, if known):
                                             Yes   No     Approximate
                                                          Number
        a.  combined wastestream formula     	   	    	
        b.  production-based categorical     	   	    	
            standards
        c.  total toxic organic (TTO)        	   	    	
            limits
        d.  solvent management plans         	   	    	

     2)  Does the POTW have approval to grant removal credits to categorical
         Ills?  	Yes 	No  If yes, list parameters: 	

     3)  Does the POTW have a spill prevention and control plan to address

         toxic discharges from lUs?  	Yes	No

     4)  Does the program include procedures for accepting hazardous wastes by
         truck, rail, or dedicated pipeline?  	Yes	No	N/A

                                      C-3

-------
SECTION II:  POTW PRETREATMENT PROGRAM

      5)  Does the program include procedures for notifying HJs of Resource
          Conservation and Recovery Act (RCRA) obligations?  	Yes 	No

F.  Compliance Monitoring

    1)  Does the program submission establish a proposed frequency for
        conducting:
                                       Minimum Frequency (times/yr/IU)

                                      Categorical    Significant Noncategorical
        	 onsite IU inspections  	  	
        ~~H POTW monitoring of IDs 	  	
        	self-monitoring by IDs 	  	.	
        	reporting by IUs       	  	

G.  Enforcement

    1)  Check those compliance/enforcement options that are available to
        the POTW in the event of ID nonccrtpliance:

        	 notice or letter of violation
        	 establishment of IU compliance schedule
        	 revocation of permit
        	 injunctive relief
        _____________ fines; maximum amount:  $     /day/violation
        	 criminal penalties
                        termination of service
   2)  Does the program submission highlight any particular IUs as being
       problem dischargers?

            IU Name                                 Reason
H.  POTW Resources

    1)  How many full-time equivalents (FTEs) will be ccnmitted to the
        POIW's pretreatment program?  	FTEs
        (An PTE is sometimes referred to as a man-year.  For example, two
        persons working half-time all year are equivalent to one PTE.)

    2)  Which of the following equipment is to be available for
        pretreatment program implementation?  Indicate the number of units
        where possible.
                                               Number
    	 vehicle(s)                   	
    	 automatic sampler(s)         	
    	 flow meter(s)                	
    	portable pH meter (s)         	
    	 gas detector(s)              	
    	 self contained breathing     	
        unit{s)
    	 other safety equipment
        (describe)
                                      C-4

-------
SECTION II:  POTW PRETREATMENT PROGRAM FACT SHEET {Continued)

      3)  How does the POTW intend to fund the pretreatment program?

                                              Percent of Total Funding

         	POTW general operating fund	
         	IU permit fees                  	
         	monitoring charges              	
         	industry surcharges             	
              other (describe) 	  	
                                        Total         100%
      4)  Wiat is the total estimated level of annual funding required to
          implement the POW pretreatment program?
          $ 	 /year
Other Supporting Comments;
SECTION II Completed By: 	  Date:
                  Title:	Telephone:
                                      C-5

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            APPENDIX D

NPDES COMPLIANCE INSPECTION REPORT
            FORM 3560-3

-------
A C D^V Washington. D C 20460
OtrA NPDES Compliance Inspection Report
Form Approved
OMB No 2O40-0003
Approval Expires 7-31 -85
Section A: National Data System Coding
Transaction Cod* NPO
ill 451 al 1 1 1 1 1
1 1
jip-i — i — i — i
Reserved Facility Ev*luation Rating
67J I | \W 7(U
ES yr/mo/day Inspection Type Inspe
| | | |ii d 1 1 II 1 In ia 1 ,d J
Remarks
1 1 1 I I '11111
ctor Fac Type
2CLJ
1 ! 1 '

7l|J "I 1 73l 1 174 7d 1 1 ! ISO

Stction B: Facility Data
Name and Location of Facility Impacted tmry fima | 	 | AM £j PM Permit Effective Dale

Named) of On-Sita Representatives)
Nam*. Addces* of Responsible Official
IS-
Permit
Rteord*/R«port»
Facility Sit* Review
Section D:

Nam*li) and Signatured) of ln«p*ctor(t|

Signature of Reviewer

Action Taken
Exit Time/Dale Permit Expiration Date
Titled! Phone Nod)
Title
Phone No. Contacted
DveeDNo
Seotlon C: ATM* Evaluated During Inspection
Satisfactory, M • Marginal. U * Unsatisfactory. N « Not Evaluated)
Flow Measurement Pretreatment
Uboritory Complltnct ScfMdulM
Erfluent/Recerving Waters S«4f-Monltorlng rVogram
Operations & Maintenance
Sluog* Oiapeul
Other:
Summary of Findings/Comments (Antch tddtiionil thutt if n«c«Mary>

Agency/Officc/Telephone

Agency/Office
ReguUtory Office Use Only
Date
Date

Date

Compliance Status
BNoncomplianca
Comoliance
EPA Form 356O-3 (Rev. 3-85} Previous editions are obsolete.

-------
                                  INSTRUCTIONS
                   Section A: National Data System Coding (i.e., PCS)
Column 1: Transaction Code: Use N, C. or D for New, Change, or Delete. All inspections will be new
unless there is an error in the data entered.
Columns 3-11: NPDES  Permit No. Enter the facility's NPDES permit number. (Use the Remarks
columns to record the State permit number, if necessary^
Columns 12-17: Inspection  Date. Insert the date entry was made into the facility.  Use  the
year/month/day format (e.g., 82/06/30 = June 30, 1982).
Column 18: Inspection Type. Use one of the codes listed below to describe the type of inspection:
  A — Performance Audit      E — Corps of Engrs Inspection  S — Compliance Sampling
  B — Biomonitoring          L — Enforcement Case Support X — Toxic Sampling
  C — Compliance  Evaluation   P — Pretreatment
  D — Diagnostic             R — Reconnaissance Inspection
Column 19: Inspector Code. Use one of the codes listed below to describe the lead agency in the
inspection.
  C — Contractor or Other Inspectors (Specify in     N — NEIC Inspectors
      Remarks columns)                         R — EPA Regional Inspector
  E — Corps of Engineers                         S — State Inspector
  j _ joint EPA/State Inspectors—EPA lead        T—Joint State/EPA Inspectors—State lead
Column 20: Facility Type. Use one of the codes below to describe the facility.
  1 — Municipal. Publicly Owned Treatment Works (POTWs) with 1972 Standard Industrial Code
      (SIC) 4952.
  2 — Industrial. Other than municipal, agricultural, and Federal facilities.
  3 — Agricultural. Facilities classified with 1972 SIC 0111 to 0971.
  4 — Federal. Facilities  identified as Federal by the EPA Regional Office.
Columns 21 -t>6: Remarks. These columns are reserved for remarks at the discretion of the Region.
Column 70: Facility Evaluation Rating. Use information gathered during the inspection (regardless
of inspection type) to evaluate the quality of the facility self-monitoring program. Grade the program
using a scale of 1 to 5 with a score of  5 being used for very reliable self-monitoring programs, 3 being
satisfactory, and 1  being used  for very unreliable programs.
Column 71: Biomonitoring Information. Enter D for static testing. Enter F for flow through testing.
Enter N for no biomonitoring.
Column  72: Quality Assurance Data Inspection.  Enter Q if the  inspection was conducted as
followup on  quality assurance sample results. Enter N otherwise.
Columns 73-80: These columns are reserved for regionally defined information.
                                 Section B: Facility Data
This section is self-explanatory.
                       Section C: Areas Evaluated During Inspection
Indicate findings (S, M,  U, or N) in the appropriate box. Use Section D and additional sheets as
necessary. Support the findings, as necessary, in a brief narrative report. Use the headings given on
the report form (e.g.. Permit, Records/Reports) when  discussing the areas evaluated during the
inspection. The heading marked "Other" may include activities such as SPCC, BMP's, and multime-
dia concerns.
                       Section D: Summary of Findings/Comments
Briefly summarize the inspection findings. This summary should abstract thepertinent inspection
findings, not replace  the narrative report. Reference  a list of attachments, such as completed
checklists taken from the NPDES  Compliance Inspection Manuals and pretreatment guidance
documents, including effluent data  when sampling has been done. Use extra sheets as necessary,

EPA Form 3560-3 
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