United States
Environmental Protection
Agency
Office of
Water
(EN-336)
September 1989
EPA Industrial User
Permitting Guidance
Manual
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\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
w I WASHINGTON. D.C. Z0460
,-/
OFFICE OF
WATER
SUBJECT: Pretreatment Program Industrial User Permitting
Guidance Manual ^
FROM: James Jt^Eider, Director
of Water Enforcement and Permits
TO: Users of the Industrial User Permitting Guidance Manual
This manual provides publicly owned treatment works (POTWs)
with guidance on the development and issuance of effective
industrial user (IU) permits. The need for this guidance has
been identified by EPA and approved pretreatment states through
audits of local programs during the past several years. There
have also been many technical and procedural questions about
industrial user permits from control authorities. During program
audits, Approval Authorities found that nearly one half of local
Control Authorities were issuing inadequate or incomplete control
mechanisms. EPA believes that individual industrial user permits
are the most effective control mechanism available.
Recognizing the need to address this issue, EPA proposed on
November 23, 1988 to amend the General Pretreatment Regulations
to include a requirement that POTWs with approved pretreatment
programs must issue permits or similar individual control
mechanisms to control the discharges from all significant
industrial users (53 FR 47632). The proposed amendment also
identified certain minimum conditions which EPA has determined
must be present in each control mechanism to ensure its
effectiveness. This manual has been developed to address and
expand upon these minimum requirements and to provide Control
Authorities with guidance on how to establish a permit program,
procedures for permit issuance, procedures for writing a permit,
and requirements for waste haulers.
The Agency expects POTWs to issue effective and enforceable
control mechanisms pursuant to 40 CFR §403.8(f)(1)(iii). POTWs
that are currently issuing permits are encouraged to use the
materials in this manual when drafting new permits or when
reissuing existing permits as their terms expire. Upon
promulgation of the November 23, 1988 proposed revisions to the
General Pretreatment Regulations, control mechanisms should be
revised, where necessary, to include the minimum requirements
identified in these revisions. For POTWs that are not currently
using a permit system, EPA recommends that this manual be used to
establish new permitting policies and procedures to ensure that
industrial users are adequately controlled.
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INDUSTRIAL USER PERMITTING GUIDANCE MANUAL
(A TRAINING MANUAL FOR CONTROL AUTHORITIES TO DEVELOP
INDUSTRIAL USER PERMITS)
September L989
Office of Water
Office of Water Enforcement and Permits
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
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ACKNOWLEDGMENTS
This document was prepared under the technical direction of Mr. Gene
Chou, Environmental Engineer, Technical Support Branch, Office of Water
Enforcement and Permits, U.S. Environmental Protection Ag,ency. Assistance was
provided to EPA by Science Applications International Corporation (SAIC) of
McLean, Virginia under EPA Contracts Nos. 68-01-7043 and 68-C8-0066. Ms. Mary
Waldron was the SAIC Work Assignment Manager; principal technical authors
were: Ms. Mary Waldron, Mr. Mark Charles, and Mr. David Hair.
Acknowledgement is also given for the valuable comments received from the
review team who donated their time and efforts to make this a more useful
document. The review team included: EPA Regional Pretrnatment Coordinators,
State Pretreatment Coordinators from North Carolina, Virginia, and Washington,
and EPA Headquarters staff, Richard Kinch, Roland Dubois, George Utting and
Paul Conner. In addition, acknowledgement is given to the many POTWs that
contributed their comments and/or the use of portions of their wastewater
discharge permits as examples within the guidance manual.
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TABLE OF CONTENTS
Page
ACKNOWLEDGMENTS i
LIST OF FIGURES AND TABLES v
HOW TO USE THIS MANUAL vii
LIST OF ACRONYMS xi
PART I - ESTABLISHING A PERMIT PROGRAM
1. BACKGROUND 1-1
1.1 INDUSTRIAL USER PERMITS 1-3
1.2 WHO ISSUES PERMITS 1-3
1.3 WHY PERMITS ARE RECOMMENDED 1-4
2. PRELIMINARY DECISIONS 2-1
2.1 WHO NEEDS A PERMIT 2-1
2.2 WHEN TO ISSUE A PERMIT 2-2
2.3 HOW LONG SHOULD PERMITS BE ISSUED FOR 2-3
2.4 WHEN TO MODIFY OR TERMINATE PERMITS 2-4
2.5 PERMIT TRANSFERABILITY 2-6
3. LEGAL AUTHORITY FOR A PERMIT PROGRAM AND
PERMIT ISSUANCE PROCEDURES 3-1
3.1 LEGAL AUTHORITY 3-3
3.2 PUBLIC PARTICIPATION 3-7
3.3 ISSUING THE FINAL PERMIT 3-9
3.4 PERMIT APPEALS 3-10
3.5 PERMIT REISSUANCE 3-11
3.6 CONTINUING PERMITS BEYOND THEIR EXPIRATION DATE 3-11
PART II - PERMIT WRITING PROCEDURES
4. PERMIT APPLICATIONS 4-1
4.1 WHAT INFORMATION TO COLLECT 4-1
4.2 APPLICATION REVIEW PROCESS 4-2
4.3 PUBLIC ACCESS TO INFORMATION 4-9
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TABLE OF CONTENTS
Page
5. GENERAL PERMITTING CONSIDERATIONS 5-1
5.1 CONTENTS OF PERMIT 5-1
5.2 STRUCTURE AND WORDING 5-1
5.3 COMMON PERMITTING ERRORS AND OMISSIONS 5-2
5.4 FLEXIBILITY 5-3
5.5 DOCUMENTING PERMIT DECISIONS 5-4
6. COMPONENTS OF THE COVER PACE 6-1
6. 1 FORMAT 6-1
6.2 ELEMENTS OF THE COVER PAGE 6-1
7. EFFLUENT LIMITATIONS 7-1
7.1 SELECTING POLLUTANTS TO BE REGULATED 7-1
7.2 APPLYING EFFLUENT LIMITS 7-7
7 .3 TIERED PERMITS 7-9
8. MONITORING AND REPORTING REQUIREMENTS 8-1
8.1 SAMPLING LOCATIONS 8-2
8 .2 POLLUTANTS TO BE MONITORED 8-4
8 .3 SAMPLE TYPE 8-5
8.4 MONITORING FREQUENCIES 8-7
8.5 ANALYTICAL METHODS 8-9
8.6 REPORTING REQUIREMENTS 8-10
9. STANDARD CONDITIONS 9-1
10. SPECIAL CONDITIONS 10-1
10.1 COMPLIANCE SCHEDULES 10-1
10.2 INDUSTRIAL USER MANAGEMENT PRACTICES 10-2
10.3 SPECIAL MONITORING REQUIREMENTS 10-4
11. DOCUMENTATION OF PERMIT DECISIONS 11-1
11.1 FACT SHEET 11-2
11.2 PERMIT RECORD 11-2
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TABLE OF CONTENTS
PART III - PERMITTING WASTE HAULERS AND OVERVIEW OF REQUIREMENTS REGARDING POTW
RECEIPT OF HAZARDOUS WASTES
Page
12. PERMITTING WASTE HAULERS 12-1
12 . 1 LEGAL AUTHORITY 12-2
12.2 PERMIT APPLICATION PROCEDURES 12-2
12.3 CONDITIONS FOR WASTE HAULER PERMITS 12-3
13. OVERVIEW OF REQUIREMENTS REGARDING POTW RECEIPT OF HAZARDOUS
WASTES 13-1
PART IV - APPENDICES
APPENDIX A - BIBLIOGRAPHY
APPENDIX B - LIST OF STATE AND REGIONAL PRETREATMENT COORDINATORS
APPENDIX C - GLOSSARY OF TERMS
APPENDIX D - SAMPLE SEWER USE ORDINANCE PROVISIONS FOR PERMITS
APPENDIX E - SAMPLE PERMIT APPLICATION FORM
APPENDIX F - SAMPLE INDUSTRIAL USER PERMIT
APPENDIX G - SAMPLE STANDARD CONDITIONS FOR PERMITS
APPENDIX H - INDUSTRIAL USER MANAGEMENT PRACTICES
APPENDIX I - SAMPLE FACT SHEET
APPENDIX J - SAMPLE WASTE HAULER PERMIT
PART V - KEY WORD INDEX
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LIST OF FIGURES AND TABLES
Figures Page
3-1 COMMON ELEMENTS OF THE PERMIT ISSUANCE PROCESS 3-2
12-1 PROCEDURES OF A WASTE HAULER PERMIT PROGRAM 12-7
Tables Page
4-1 EXAMPLES OF DEFICIENCIES COMMONLY FOUND IN PERMIT APPLICATIONS 4-12
4-2 INACCURACIES IN PERMIT APPLICATIONS 4-13
4-3 VERIFICATION OF FLOW DATA USING WATER BALANCE 4-14
5-1 EXAMPLE OF PERMIT FLEXIBILITY 5-5
7-1 EXAMPLES OF SELECTING POLLUTANTS FOR REGULATION 7-13
7-2 NATIONAL PROHIBITED DISCHARGES 7-14
7-3 EXAMPLE OF INCORPORATING PROHIBITED DISCHARGES IN PERMIT 7-15
7-4 FORMULAS FOR CALCULATING EQUIVALENT LIMITS FROM
PRODUCTION-BASED STANDARDS 7-17
7-5 EXAMPLE OF INCORPORATING PRODUCTION-BASED STANDARDS AS
EQUIVALENT MASS LIMITS IN A PERMIT 7-18
7-6 EXAMPLE OF FACT SHEET DOCUMENTING DETERMINING THE MOST
STRINGENT DAILY MAXIMUM EFFLUENT LIMITS 7-19
8-1 SPECIAL MONITORING AND/OR REPORTING REQUIREMENTS FOR SPECIFIC
CATEGORICAL PRETREATMENT STANDARDS 8-15
8-2 EXAMPLES OF SPECIFYING SAMPLING LOCATIONS IN PERMITS 8-18
8-3 RECOMMENDED INDUSTRIAL SELF-MONITORING FREQUENCIES DURING
INITIAL COMPLIANCE PERIOD 8-19
8-4 EXAMPLE OF SETTING MONITORING REQUIREMENTS IN PERMITS 8-20
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Tables Page
8-5 INDUSTRIAL USER REPORTING REQUIREMENTS PER 40 CFR 403.12 8-22
8-6 EXAMPLE OF REPORTING REQUIREMENTS IN PERMIT 8-24
8-7 FUNDAMENTAL ELEMENTS OF AN INDUSTRIAL USER PERIODIC
COMPLIANCE REPORT 8-27
9-1 EXAMPLES OF DIFFERENT LANGUAGE USED TO INCORPORATE
STANDARD CONDITIONS INTO INDUSTRIAL USER PERMITS 9-5
10-1 EXAMPLE OF INCORPORATING A COMPLIANCE SCHEDULE IN SPECIAL
CONDITION SECTION OF PERMIT 10-5
10-2 EXAMPLES OF IMPOSING INDUSTRIAL USER MANAGEMENT PRACTICES IN
PERMITS 10-6
10-3 EXAMPLES OF INCORPORATING SPECIAL MONITORING REQtIREMENTS IN
PERMITS 10-8
11-1 COMPONENTS OF A PERMIT FACT SHEET 11-3
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HOV TO USE THIS MANUAL
PURPOSE
This guidance manual has been prepared by the U.S. Environmental
Protection Agency (EPA), Office of Water Enforcement and Permits, to provide a
framework for drafting and issuing industrial user permits by Publicly Owned
Treatment Works (POTWs) and States with approved pretreatment programs acting
as Control Authorities. The purpose of this guidance is to assist new permit
writers, experienced permit writers, and legal and administrative personnel
who are involved in the implementation of an industrial user permitting
program in preparing effective and enforceable industrial user permits.
This manual provides documentation of EPA's recommendations for
industrial user permit contents and structure. The manual contains many
examples of sections and conditions of a permit, as well as complete sample
permits and fact sheets. The goal is to furnish this Information to permit
writers In a reference manual format which can be used throughout the
permitting process.
In addition to the people directly responsible for drafting and issuing
permits, legal and administrative support staff should be aware of several
aspects of the permitting process. For these individuals, the manual provides
background information on requirements of the issuance process and discusses
the necessary legal authority required to implement an effective program.
USE
It Is recommended that all personnel directly involved with the permit
drafting and Issuance processes scan the entire manual to get an overview of
its contents and structure. In scanning the manual, the reader should note
any sections of particular interest to his/her permitting process.
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HOW TO USE THIS MANUAL
It is important for new permit writers to read all sections of this
manual carefully to learn about each phase of the permit drafting and issuance
process. An understanding of each section will provide the inexperienced
permit writer with an overview of the typical components of an industrial user
permit and the interrelationship between legal authority, permit drafting,
public participation, and permit issuance.
Experienced permit writers should carefully study the permitting examples
provided to determine if their own permits could be strengthened through
modification or addition of the recommended provisions. The manual can also
be used as a reference source during subsequent permitting procedures.
The Control Authority's legal and administrative support personnel should
also become familiar with the provisions of the guidance manual with which
they will be Involved. These individuals should carefully read the background
and issuance procedures sections to ensure that their administrative
procedures and legal authority are adequate.
The glossary in Appendix C, the list of acronyms immediately following
this section, and the index of key words in Part V of the manual are provided
to assist the user of this text. The glossary and acronym sections should be
consulted whenever terms appear that are unfamiliar to the reader. It may
also be helpful to use the index of key words to see how the term is used in
context. In addition, the index will allow the user who is familiar with
permitting requirements to access specific sections of the manual during the
drafting of individual permits.
LIMITATIONS
While this guidance manual gives an overview of the permit writing and
issuance processes, it is not intended to address all of the specific
determinations which must be made during these processes. Where guidance has
previously been developed, this manual references the document which provides
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HOW TO USE THIS MANUAL
the additional information. For example, the use of the Combined Vastestream
Formula (CWF) is introduced in this manual, but the specific instructions on
how to apply the CWF are not within the scope of a permit writing manual. The
permit writer is, therefore, encouraged to use this manual in conjunction with
the following EPA guidance documents: 1) the Guidance Manual on the
Development and Implementation of Local Discharge Limitations Under the
Pretreatment Program: 2) the Pretreatment Compliance Monitoring and
Enforcement Guidance: and 3) the Guidance Manual for Use of Production-Based
Standards and the Combined Wastestrean Formula [and 51 Federal Register (FR)
21454 and 53 FR 40562]. These documents serve as companion documents to this
manual and contain technical guidance on development of local limits, specific
information on enforcement of pretreatment standards and requirements, and
technical guidance for applying production-based standards using the combined
wastestream formula.
Throughout the text of this manual, all references to supplementary
guidance material and development documents cite only the document title.
Complete citations for all relevant guidance documents are found in the
bibliography in Appendix A. Any reference to the Code of Federal Regulations
(CFR) is followed by a bracketed citation of the specific section (e.g., [40
CFR Part 403]). References to the Federal Register are also bracketed (e.g.,
[53 FR Part 40562]).
In general, each Control Authority has pretreatment concerns unique to
its own area and which necessitate specific local requirements. Discussion of
specific requirements that must be met in order to comply with local or State
laws under which a particular Control Authority operates is beyond the scope
of this document. The permit writer should, therefore, consult with his/her
attorney on these issues.
The National Pretreatment Program continues to evolve and the concepts
and procedures recommended here may change with time and experience. EPA
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HOW TO USE THIS MANUAL
intends to distribute additions or modifications to this manual that will
reflect such changes. These additions or modifications will be dated and
formatted so that they can be inserted directly into this manual to replace or
append previous sections. Specific questions about this guidance should be
addressed to the appropriate State or Regional Pretreatment Coordinator. A
list of these coordinators can be found in Appendix B.
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LIST OF ACRONYMS
The following is an alphabetical list of all acronyms used in this manual.
Its purpose is to serve as a quick reference for those who may be unfamiliar
with the lettered short cuts that are commonly used to signify terms and
phrases associated with the industrial pretreatment permitting program.
BMR - Baseline Monitoring Report
BOD - Biochemical Oxygen Demand
BPJ - Best Professional Judgment
CFR - Code of Federal Regulations
CIU - Categorical Industrial User
CWA - Clean Water Act (P.L. 95-217 as amended)
CWF - Combined Wastestream Formula
EPA - U.S. Environmental Protection Agency
FR - Federal Register
FWA - Flow Weighted Average
GC - Gas Chromatography
GC/MS - Gas Chromatography/Mass Spectroscopy
gpd - Gallons Per Day
IU - Industrial User
LEL - Lower Explosive Limit
mgd - Million Gallons Per Day
mg/1 - Milligrams Per Liter
NPDES permit - National Pollutant Discharge Elimination System permit issued
pursuant to Section 402 of the Clean Water Act
O&M - Operation and Maintenance
POTW - Publicly Owned Treatment Works
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LIST OF ACRONYMS
PSES
PSNS
QA
QC
RCRA
SIC
SIU
SWDA
TOMP
TSS
TSDF
TTO
Pretreatnent Standards for Existing Sources
Pretreatment Standards for New Sources
Quality Assurance
Quality Control
Resource Conservation and Recovery Act
Standard Industrial Classification
Significant Industrial User
Solid Waste Disposal Act
Toxic Organic Management Plan
Total Suspended Solids
Treatment, Storage, and Disposal Facility
Total Toxic Organics
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xii
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PART I
ESTABLISHING A PERMIT PROGRAM
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CHAPTER 1
BACKGROUND
The National Pretreatment Program's primary goal is to protect Publicly
Owned Treatment Works (POTWs) and the environment from adverse impacts that
may occur when pollutants are discharged into a sewage system.
The specific pretreatment program goals are as follows:
• Prevent a pollutant from passing through the treatment works
• Prevent interference with POTV operations, including sludge use and
disposal practices and ensuring worker health and safety
• Improve opportunities to recycle and reclaim municipal and industrial
wastewaters and sludges.
Pretreatment standards are derived from a number of sources. First, the Clean
Water Act [33 USC 1251 et seq.] requires the U.S. Environmental Protection
Agency (EPA) to promulgate pretreatment standards and requirements. EPA has
responded by establishing general and specific prohibited discharge standards
[40 CFR 403.5) applicable to all nondomestic users and by promulgating
categorical pretreatment standards applicable to specific industrial
categories [40 CFR Parts 405-471]. In addition, Section 403.5(c) of the
General Pretreatment Regulations [40 CFR 483.5(c)] requires POTWs to develop
local limits where necessary to implement the prohibited discharge standards.
Finally, States and POTWs always have the option of establishing more
stringent requirements if they so choose. Therefore, the pretreatment program
is a mixture of Federal, State, and local standards and requirements.
Section 403.8(a) of the General Pretreatment Regulations [40 CFR
403.8(a)] requires all POTW's with design flows greater than 5 million gallons
per day (mgd) and receiving industrial discharges which pass through or
interfere with the operation of the POTW, or are otherwise subject to
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CHAPTER I BACKGROUND
pretreatment standards, to develop local pretreatment programs (unless the
State government has elected to administer the local program). Other POTWs
may also be required to implement pretreament programs, in the discretion of
EPA or a State authorized to implement a State pretreatment program. It is
assumed for the purposes of this manual that the POTW issuing industrial user
permits has an approved pretreatment program and is, thus, the "Control
Authority" responsible for administering and enforcing the pretreatment
program. The program implementation and enforcement responsibilities are
contained in the POTW's National Pollutant Discharge Elimination System
(NPDES) permit and failure to adequately fulfill these activities constitutes
a NPDES violation and may subject the POTW to penalties.
States with approved pretreatment programs are responsible for overseeing
and coordinating the development and approval of local pretreatment programs.
Prior to State approval, EPA is the Approval Authority for local pretreatment
programs. (NPDES States must receive EPA approval before they may function as
Approval Authorities for pretreatment purposes. Prior to this approval, EPA
serves as the pretreatment Approval Authority, even where the State issues
NPDES permits.) However, States may participate in pretrea'iment activities
even before their State program is approved.
EPA's General Pretreatraent Regulations require POTWs to use a control
mechanism which ensures that all applicable pretreatment standards and
requirements are met by industrial users (IU). It is EPA's experience that,
of all possible control mechanisms available, the permit has; proven to be the
most effective. Permits allow for the systematic integration of all
applicable requirements and, if properly structured, may grtatly facilitate
enforcement of any noncompliance. Therefore, EPA recommends that POTWs
satisfy the control mechanism requirement [40 CFR 403.8(f)(1)(111)] and the
requirement that the POTW have procedures to notify industrial users of
applicable pretreatment standards [40 CFR 403.8(f)(2)(111)] by issuing permits
to industrial users.
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CHAPTER 1 BACKGROUND
1.1 INDUSTRIAL USER PERMITS
Industrial user permits sanction the discharge of wastewater to a POTW
upon condition that permit terms are adhered to. An IU permit is typically
effective for only a limited time period, and revocable by the issuing
authority at any time for just cause. In addition, the Control Authority's
sewer use ordinance will typically include a provision which forbids the
discharge of industrial wastewater from a significant industrial user without
a current Industrial user permit.
An industrial user permit should describe, in a single document, all of
the duties and obligations of the permittee including all applicable
pretreatment standards and requirements. At a minimum, these should include
the prohibited discharge standards and applicable categorical standards, local
limits, and monitoring and reporting requirements. Permits should not simply
reference the applicable laws, but should contain actual numeric limitations
(expressed in terms of concentration or mass of pollutants which may be
discharged over a given time period), schedules for monitoring and reporting,
and requirements regarding sampling location and scope. These conditions
should reflect the most stringent of applicable Federal, State, and local
pretreatment standards and requirements.
In the most effective Industrial user permit programs, permittees are
given an opportunity to challenge permit terms administratively and/or in the
courts within only a specified time period after permit issuance. If the
permit Is not challenged upon issuance, or if all opportunities for challenge
of the final permit are exhausted, then It becomes binding on the permittee
and any violation of the permit Is enforceable simply by proving that the
permit included a certain term and that the term was violated.
1.2 WHO ISSUES PERMITS
POTWs with approved pretreatraent programs are required to issue
industrial user permits or other authorized control mechanisms to their
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CHAPTER 1 BACKGROUND
industrial users. Such POTWs are "Control Authorities" ir the National
pretreatment program. In States with approved State pretreatment programs,
the State may assume responsibility for implementation of a City's local
pretreatment program [40 CFR 403.10(e)]. In these cases, the State becomes
the Control Authority. As of this writing, five States have chosen to
implement a State-wide program: Vermont, Connecticut, Alabama, Mississippi,
and Nebraska. These States must implement the program to the same extent as
the POTWs themselves would otherwise be required to do. Cansequently, an
industrial user permit may be issued by these States rather than by POTWs. Of
course, all States are free to issue such permits or other control mechanisms
as they deem necessary to carry out the requirements of State law; this may be
particularly appropriate where significant industrial users are discharging to
a POTW that does not have an approved pretreatment program
1.3 VHY PERMITS ARE RECOMMENDED
The Control Authority must be able to regulate through permits, orders,
or similar means the contributions of Its industrial users in order to ensure
that the requirements of the General Pretreatment Regulations are met [40 CFR
403.8(f)(1)(ill) ] . EPA believes that in most circumstances a permit program
is the most effective mechanism for controlling wastewater discharges.
A permit system provides a mechanism for the Control Authority and its
industrial users to determine, at an early stage, the meaning of various
pretreatment standards and requirements in terms of specific discharge
limitations, monitoring frequency and locations, reporting requirements, etc.
Any disagreement between the Control Authority and the industrial user as to
pretreatment requirements is resolved at an early date, prisr to possible
damage to the environment. A permit clearly identifies all of the permittee's
responsibilities and obligations in a single document, thereby increasing the
understanding of the industrial user with regard to pretreatment requirements.
The permit issuance process itself leads to greater understanding and
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CHAPTER I BACKGROUND
increased compliance rates by fostering dialogue and development of a one-to-
one relationship between the POTW and an industrial user.
Permit modification procedures can be established to provide flexibility
to accommodate changes in the industrial user's circumstances. For example,
if an industrial user significantly expands its process operation, the permit
can be modified to reflect the increased wastewater discharge. The ability to
modify or revoke and reissue a permit also enables the Control Authority to
accommodate changes in Federal, State, and local requirements.
Permits are also easily enforced, providing that permit conditions are
written in a clear and concise manner and require specific actions on the part
of the user. For example, the permit must state that a user "shall" self-
monitor rather than stating that the user "should" or "may" monitor. Permits
allow the POTW and interested citizens to measure the performance of the user
against the permit conditions to determine compliance. In addition, where
permittees are given only a limited time period to challenge the substantive
content of an industrial user permit, enforcement actions brought after the
limited time for review need only demonstrate noncompliance with the specific
conditions of the permit; the calculation of applicable discharge limitations
from narrative statutory and regulatory provisions is not at issue.
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CHAPTER 2
PRELIMINARY DECISIONS
Before a Control Authority can begin issuing permits to industrial users,
it must have adequate legal authority to do so, and it must make some basic
policy decisions regarding who will be required to obtain permits, when
permits will be issued, the effective period or duration for permits, and the
circumstances when a permit may be modified or terminated. The following
sections address factors which the Control Authority should consider when
answering these questions.
2.1 WHO NEEDS A PERMIT
One of the first decisions to be made when establishing a permit program
is which industrial users will be required to obtain a permit. EPA strongly
recommends that permits at least be issued to all users which are regulated
under Federal categorical standards (or similar State requirements) and other
users that the Control Authority determines to be "significant." As early as
possible, the Control Authority should establish a definition of a significant
industrial user (SIU) to avoid the appearance of being arbitrary or
discriminatory. To assist Control Authorities in this effort, EPA has
published a recommended definition of "significant industrial users" in its
Pretreatment Compliance Monitoring and Enforcement Guidance and is proposing
to adopt a similar definition in the General Pretreatment Regulations [53 FR
47632]. This definition includes all categorical users, and all
noncategorical users who's process flows exceed 25,000 gallons per day,
contribute more than five percent of the hydraulic or pollutant loading to a
POTW or have a reasonable potential to adversely affect the POTW. EPA has
also proposed that Control Authorities be required to issue industrial user
permits to these significant industrial users [Id.]. Many Control Authorities
have already identified significant industrial users in their ordinances.
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CHAPTER 2 PRELIMINARY DECISIONS
Other factors to consider In deteminlng which industrial users should be
required to have permits should include:
• Pollutants being introduced
• Spill potential
• Previous compliance history
• Potential for causing POTW to violate its NPDES permit
• Potential for causing difficulties with sludge use or disposal.
In addition, it is recommended that Control Authorities consider
permitting all waste haulers. Further discussion on permitting waste haulers
appears in Chapter 12. Once the permitting program has become more firmly
established, or if additional staff become available, the Control Authority
may then decide to expand its program beyond the significant industrial users.
2.2 WHEN TO ISSUE A PERMIT
Once all potential permittees have been identified, another important
question to be considered involves the timing of permit issuance. Since
permits assist in the imposition and enforcement of pretreatment requirements,
they should be Issued with as little delay as possible. Where the Control
Authority will be permitting several significant industrial users, the permits
should be written with staggered expiration dates in order :o equalize the
permit reissuance workload in the future. Control Authorities should plan to
reissue permits before they expire, or provide that an industrial user who has
filed a timely application for permit renewal nay continue 1:0 discharge in
accordance with an expired permit In the Interim before the Control Authority
issues a renewal permit.
Many Control Authorities have required existing significant users to
apply for initial permits within six months of the adoption of ordinance
provisions authorizing a permit program. New significant industrial users
should receive permits before they may begin discharging to the sewer system.
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CHAPTER 2 PRELIMINARY DECISIONS
Control Authorities have typically required each significant user to submit
an application for permit reissuance at least 90 days prior to the expiration
date of the applicable existing permit to provide the Control Authority with
sufficient time to adequately evaluate the discharge, develop permit
conditions, and issue the permit on or before expiration.
The most important task before the Control Authority is to have all
significant industrial users under enforceable control mechanisms which
contain specific discharge conditions, based on all available information at
the time of permit issuance. In instances where a Control Authority has a
large number of significant industrial users, the initial permit issuance,
including thorough site inspections, may create a considerable backlog of
industrial users waiting to be permitted. The Control Authority may want to
issue short-term permits or full-term permits with reopener conditions
allowing permit modification when more complete information has been obtained.
However, such permits should still contain the minimum elements outlined in
Chapter 5 and should be based on all existing data available to the permit
writer at that time.
2.3 HOW LONG SHOULD PERMITS BE ISSUED FOR
An industrial user permit should not be issued for an indefinite term.
Expiration of the permit initiates reevaluation of the relevant information
pertaining to the industrial user and the appropriateness of the permit
standards and conditions. EPA suggests that pretreatment permits be limited
to a five-year period or less (see EPA's Guidance Manual for POTW Pretreatroent
Program Development): however, local or State law may mandate a shorter
maximum duration. A short-term permit is recommended where the permit writer
knows the industrial user is planning a major process change or the business
has been advertised for sale. Moreover, a short-term permit is also advisable
where the permit writer is aware of proposed changes in the Federal, State, or
local pretreatment program which might significantly affect how the user will
be regulated in the future (e.g., a revision to include a categorical
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CHAPTER 2 PRELIMINARY DECISIONS
pretreatment standard). Alternatively, the permit writer oould insert a
special condition to "reopen" the permit when the change occurs or, if
authorized to do so, may simply choose to modify the permi : under its general
modification authority (see Section 2.4 below).
2.4 WHEN TO MODIFY OR TERMINATE PERMITS
2.4.1. Permit Modifications
Control Authorities must be able to revise their industrial user permits
to implement revisions in Federal, State, and local program requirements and
make mid-course corrections or adjustments to reflect significant changes in
the user's circumstances. At a minimum, the Control Authority's ordinance
should always provide (and the permits should indicate) that they can be
modified when, in the opinion of the Control Authority, goad cause exists to
do so. Generally speaking, permits should not be modified to make discharge
standards less stringent where the user is in compliance with the current
permit conditions and no changes in operations justifying a relaxation of the
permit are involved. Common justifications for modifying permits include the
following:
• Alterations in the industrial user's operations, including production
rates, which result in new pollutant contributions or substantial
changes (increases or decreases) in the amount of pollutants
discharged or the volume of wastewaters discharged
• New information which was not available at the tim«; of permit issuance
• New Federal, State, or local requirements promulgated since the time
of permit issuance (e.g., revised categorical standards or local
limits)
• Correction of technical mistakes, erroneous interpretations of
Federal, State or local law, or typographical errors.
To the extent that the Control Authority allows industrial users or
interested members of the public to request permit modifications, it is
recommended that such requests be made in writing and include facts or reasons
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CHAPTER 2 PRELIMINARY DECISIONS
which support the request. If the Control Authority is required to or
routinely provides public notice of draft permits, any proposal for a
significant modification should also be subjected to similar public scrutiny.
Public participation in the permit issuance process is discussed further in
Chapter 3. To avoid nonproductive paperwork, the Control Authority may wish
to structure its procedures so that minor modifications to the permit need not
be subject to the public notice procedure. The following typically qualify as
minor changes:
• Correction of typographical errors
• Imposition of more frequent monitoring or reporting conditions
• Changing interim compliance dates in compliance schedules (which will
not affect the final compliance date).
Generally, a permit can be modified in a number of ways. One method,
where extensive modifications are necessary, is to reissue a whole new permit
with the modifications incorporated. Another method, if only one section of
the permit needs modification, may be to issue an addendum to the existing
permit. Addendums issued separately from the permit can be forgotten or
misplaced so the industrial user should be instructed to replace the original
section of the permit that is being modified with the addendum or attach the
addendum to the permit.
When modifying a permit, the permit writer should allow a reasonable time
frame for the industrial user to comply with the new or changed conditions if
the user cannot meet them at the time of the modification and if permitted by
law. If these new or changed conditions are the result of new or changed
categorical pretreatment regulations, those regulations will stipulate the
compliance period. The Control Authority cannot extend the Federal compliance
period. Of course, if the industrial user is already complying with the
modified condition, no compliance or "grace period" should be provided. The
compliance period must be clearly designated in the modified permit. In no
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CHAPTER 2 PRELIMINARY DECISION?
event, however, may a compliance schedule relieve the user of Its duty to
comply with currently applicable pretreatnent standards and requirements.
2.4.2 Permit or Discharge Termination! or Suspensions
Situations may arise during the effective period of a j>ennit which
require the Control Authority to suspend or terminate the industrial user's
right to discharge into the sewer system. The General Pretreatment
Regulations require Control Authorities to be authorized to terminate the
industrial user's discharge if it presents or may present an endangerment to
the environment or if it threatens to interfere with the operation of the
treatment works [see 40 CFR 403.8(f)(1)(vi)(B)]. Therefore, the Control
Authority's legal authority must allow it to halt any such discharges. Use of
permit suspensions or terminations should be part of an overall enforcement
management strategy. Development of such a strategy Is described in EPA's
Pretreatment Compliance Monitoring and Enforcement Guidance
2.5 PERMIT TRANSFERABILITY
The Justifications for limiting the transferability of permits are very
similar to those mentioned In Section 2.3 for limiting permit duration. The
Control Authority needs to be notified of owner/operator transfers and be
given the opportunity to question the new owner/operator regarding plans to
redesign or otherwise change the process or management practices at the
facility. The Control Authority should, therefore, require advance notice of
all proposed owner/operator transfers, preferably at least 30 days in advance
of the transfer. In addition, if the Control Authority does not wish to
provide for transfers for changes in owner/operator, it may simply revoke the
existing permit and reissue a new permit to the new owner/operator.
2.5.1 Informal Transfer
When the Control Authority is satisfied that the transfer involves only a
change in owner/operator, the permit may be transferred to a new user without
changing any of the permit conditions. This may be accomplished by using what
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CHAPTER 2 PRELIMINARY DECISIONS
is referred to as an informal transfer. The following procedures are
recommended to implement this type of transfer:
• The current or future owner/operator must submit to the Control
Authority, at least thirty days in advance of the proposed transfer
date, a notification describing the anticipated transaction and
identifying the transfer date. (However, the Control Authority should
have authority to allow a shorter notification period for good cause.)
• The notice must include: (1) a written agreement between the current
and future owner/operator that the permit held by the current
owner/operator, together with all privileges and obligations bestowed
through it, be transferred to the future owner/operator effective as
of the specified transfer date, and (2) a signed statement by the
future owner/operator that it has no immediate intention of modifying
operations at the permitted facility in any manner that could result
in a discharge from the facility, that it will notify the Control
Authority in advance of any such modification it may choose to
implement in the future, and that it will abide by all terms and
conditions set forth in the permit. These documents should be signed
by individuals with authority to execute official documents on behalf
of the company represented.
It should be noted that this informal transfer need not preclude the
Control Authority from collecting any applicable permit or application fee.
2.5.2 Modify or Revoke and Reissue
If, in the opinion of the Control Authority, the change in owner/operator
at a permitted facility will result in a substantial change in process,
operation, or management practices at the facility, or if local or State law
prevents permit transfers, the Control Authority should formally modify or
revoke and reissue the existing permit. The procedure in this case should be
the same as if the user were a new connection and all application and permit
issuance procedures should be followed.
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CHAPTER 3
LEGAL AUTHORITY FOR A PERMIT PROGRAM AND PERMIT ISSUANCE PROCEDURES
The legal authority of a POTW or other local Control Authority to
administer a permit program Is derived from State law and local ordinance.
Although this chapter describes the legal authority and procedures required
for a POTW to implement an effective permit program, a State acting as the
Control Authority should have similar legal authorities and procedures in
place. State law will determine what authorities are available to the Control
Authority and, thus, the Control Authority must be aware of these laws when
developing or seeking modifications to its local ordinance. The local
ordinance (which constitutes the Control Authority's exercise of the authority
conferred by State law) must describe the permit program in sufficient detail
so that industrial users and permit writers will know the procedures,
expectations, and liabilities associated with the program. The Control
Authority should request its attorney to assist it in reviewing the ordinance
to ensure that it provides adequate authority and that the ordinance does not
create any unnecessary procedural or institutional obstacles which might
hinder the permit program. If legal authority must be modified to establish a
permit program, the Control Authority should bear in mind that such
modifications are considered a substantial modification requiring approval by
the Approval Authority (EPA or State) in accordance with the procedure in 40
CFR 403.18.
Although each Control Authority will have its own set of procedures, the
basic formula for permit Issuance will usually be the same. Figure 3-1 shows
this basic permitting process. Subsequent chapters of this manual will
address the application and permit writing processes. This chapter considers
the legal authority necessary to implement and enforce a permit program and
the permit issuance activities associated with permit development, including
public participation, transmitting a final permit to the industrial user,
permit appeals, and permit reissuance considerations.
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CHAPTER 3 LEGAL AUTHORITY FOR A PERMIT PROGRAM AND PERMIT ISSUANCE PROCEDURES
FIGURE 3-1. COMMON ELEMENTS OF THE PERMIT ISSUANCE PROCESS
SIU fVet Ptmit Appikaboo
Sead Draft Pratt 10
Natty 06er
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3-2
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CHAPTER 3 LEGAL AUTHORITY FOR A PERMIT PROGRAM AND PERMIT ISSUANCE PROCEDURES
3.1 LEGAL AUTHORITY
Under general principles of administrative law, final permit decisions of
the Control Authority typically nay be challenged by permit applicants and
other interested parties. Therefore, the Control Authority should ensure that
it has the requisite legal authority to impose pretreatment requirements in
industrial user permits and that it exercises its authority in a non-arbitrary
manner. Assuming that State law authorizes Control Authorities to issue and
enforce permits, the local ordinance should clearly provide the Control
Authority with the following authorities:
• Authority to regulate all industrial users contributing wastewater to
the POTW
• Authority to require and issue industrial user permits, including:
Authority to require users to obtain permits
Authority to require users to submit permit applications containing
all data which the Control Authority deems relevant to permit
decisions and provisions for public access to data
Authority to enter, inspect, and sample to verify information
supplied by the Industrial user as well as to assess the industrial
user's compliance status
Authority to incorporate local limits
Authority to incorporate Federal and State pretreatment standards
and requirements
Authority to require self-monitoring, record keeping, and reporting
by permittee
Authority to develop other appropriate permit conditions
• Authority to enforce permit violations.
Each of these authorities is discussed briefly below. Appendix D contains
sample sewer use ordinance provisions addressing permit issuance and
enforcement.
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CHAPTER 3 LEGAL AUTHORITY FOR A PERMIT PROGRAM AND PERMIT ISSUANCE PROCEDURES
3.1.1 Authority Over All Industrial Pier» Contributing Waitevater to the POTV
A Control Authority must be able to impose and enforce^ applicable
pretreatment standards and requirements on every nondoraestic user contributing
wastewater to its collection system. Therefore, it is necessary that the
Control Authority's sewer use ordinance provides it with the requisite
authority to issue control mechanisms, conduct compliance monitoring
activities, and, when warranted, take appropriate enforcement action in
response to noncompliance by users located within its boundaries. However,
many Control Authorities serve nondomestic users located beyond their
political boundaries (e.g., beyond a city's limits or county line) and the
enforceability of the sewer use ordinance in these "roultijarisdictional" areas
may be uncertain. Such circumstances typically require th>a Control Authority
to take additional measures to ensure its regulatory authority throughout its
service area. Control Authorities should consult their at:orneys for
approaches under State and local laws to any multijurisdicrional problems
3.1.2 Authority to Require and Issue Industrial User Pernits
3.1.2.1 Requiring Users to Obtain Permits
The ordinance authorizing a permit system should make it clear that
industrial users covered by the permit program (as defined in the local
ordinance) must obtain a permit. Ideally, the permit should be obtained as a
precondition to discharging wastewater into the sewer system. This
requirement places the burden on the user to come forward find identify itself
or risk an enforcement action for failing to obtain a permit.
3.1.2.2 Submitting Application D«t«
The ordinance should authorize the Control Authority to require the user
to submit information on its facility, processes, raw materials, flows,
pollutant discharge, storage areas, production, and other environmental
permits held. Since each industrial user is unique, the Control Authority
should also be able to require that the user submit additional information as
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CHAPTER 3 LEGAL AUTHORITY FOR A PERMIT PROGRAM AND PERMIT ISSUANCE PROCEDURES
may be necessary Co evaluate its wastewater discharge and spill potential.
The ordinance must ensure information submitted to the Control Authority which
meets EPA's definition of "effluent data" under 40 CFR 2.302 will be available
to the public without restriction [40 CFR 403.14).
3.1.2.3 Entering and Inspecting
EPA regulations require the Control Authority to have the authority to
enter and inspect industrial users' facilities. This authority must be at
least as extensive as EPA's own broad authority under Section 308 of the Clean
Water Act. At a minimum, these entry and inspection authorities should allow
the Control Authority's authorized representative(s) to, (1) have a right of
entry to, upon, or through any premises in which an effluent source is located
or in which records required to be maintained by the permittee are located,
and (2) at reasonable times, have access to and copy any records, inspect any
monitoring equipment or methods (required of the permittee), and sample any
effluents which the owner or operator of such source is generating (40 CFR
403.8(f)(l)(v)].
3.1.2.4 Imposing Local Limits
The Control Authority is obligated to develop and enforce local limits
necessary to implement and enforce the general and specific prohibitions [40
CFR 403.5]. The ordinance should state that such local limits may be imposed
on industrial users directly through the sewer use ordinance, through
industrial user permits, and through additional control mechanisms the Control
Authority intends to use as part of its pretreatment program.
3.1.2.5 Imposing Federal and State Requirements
Control Authorities are responsible for enforcing Federal and State
pretreatment standards and requirements as well as local limits. The
ordinance should specifically state that EPA's categorical pretreatment
standards [40 CFR Subchapter N], the general and specific prohibitions [40 CFR
403.5], and any other requirements mandated under State law are adopted by
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CHAPTER 3 LEGAL AUTHORITY FOR A PERMIT PROGRAM AND PERMIT ISSUANCE PROCEDURES
reference and may be imposed and enforced through industrial user permits [40
CFR 403.8(f)(1)(ii)]. Moreover, the Control Authority should ensure that the
ordinance does not provide for any variance or adjustment of these
requirements other than those authorized under applicable State or Federal
law.
3.1.2.6 Requiring Users to Self-Monitor. Keep Records, and Report
Federal regulations require certain classes of industrial users to
conduct periodic self-monitoring, maintain sampling records, routinely report
on their compliance status, and disclose any changing conditions or planned
alterations at their facilities [40 CFR 403.12). The Control Authority's
ordinance should authorize the Control Authority to impose and enforce these
requirements in industrial user permits. In addition, the ordinance should
authorize the Control Authority to impose and enforce these or similar
obligations on other industrial users.
3.1.2.7 Imposing Other Conditions
In many instances, the Control Authority will have developed other local
requirements or conditions applicable to industrial user discharges. These
conditions may Include such things as user fees, a cross-connection
prohibition, or Biochemical Oxygen Demand (BOD) or Total Suspended Solids
(TSS) concentrations above which the Control Authority will impose surcharge
fees. Although these conditions may not directly relate to controlling
interference or pass through, they are nonetheless industrial user
requirements and may be included as permit conditions. For this reason, the
local ordinance should clearly authorize that industrial user permits may
contain other conditions as the Control Authority deems necessary or
desirable.
3.1.3 Authority to Enforce Permit Violations
Few ordinances expressly mandate all the pretreatmert requirements which
a Control Authority may impose through a permit on a particular industrial
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CHAPTER 3 LEGAL AUTHORITY FOR A PERMIT PROGRAM AND PERMIT ISSUANCE PROCEDURES
user. In other words, they leave a great many details regarding the contents
and issuance of a permit to the discretion of the Control Authority in
general, and the permit writer in particular. At a minimum, the ordinance
should always expressly state that permit conditions are specifically and
independently enforceable regardless of whether they are expressly required by
or set out in the ordinance. The ordinance should specify the enforcement
response alternatives available to the Control Authority including injunctive
relief, civil and criminal penalties, and service termination.
3.2 PUBLIC PARTICIPATION
The permit writer should not draft a permit in seclusion; nor need the
permit development process be viewed as an adversarial contest. Rather,
communication between the permit writer, the industrial user, and the public
is frequently a legal requirement and should always be encouraged. One way
for Control Authorities to encourage public involvement is by publicly
noticing permit development activities and accepting comments on draft
permits. Alternatively, the Control Authority may wish to hold a public
hearing on draft permits. The local ordinance may require some sort of public
notice of and opportunity to comment on the draft permit, such as publishing a
notice in a local newspaper, notifying specific individuals on a Control
Authority's mailing list, and/or publicizing permits during public meetings of
sewage districts, City Councils, town meetings, or in a bulletin or
newsletter. Such notice is helpful to explain the Control Authority's actions
and may be particularly important if any possibility exists that the permit
may become controversial.
Public involvement during permit development, particularly discussions
with the applicant, allow the permit writer to identify and resolve issues
that are of concern to the public sinply by modifying a draft permit before it
is made final. In addition, it provides a source of supplementary data which
may fill in gaps and omissions or clarify ambiguities in the permit appli-
cation. Such communication often leads to a better understanding by the
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CHAPTER 3 LEGAL AUTHORITY FOR A PERMIT PROGRAM AND PERMIT ISSUANCE PROCEDURES
permit writer of the Industrial user's process and to less anxiety by the
industrial user, since the user gains a clearer picture of the Control
Authority's expectations. Therefore, EPA encourages Control Authorities to
Involve the permittee and the general public as nuch as possible In the permit
development process. However, dialogue with the permittee or the public at
large should continue only as long as it proves useful. If the development
process stalls or the interested parties reach an impasse over a particular
issue, the permit writer should proceed directly to permit issuance. If the
discharger believes that the permit writer's position Is unreasonable, it may,
upon permit Issuance, seek reconsideration through an administrative or
judicial appeal.
Once the Control Authority decides to provide public notice of and
opportunity to comment on draft permits, it should provide this notice and
opportunity for comment for all permits. This will avoid .any appearance of
arbitrary behavior on the part of the Control Authority. Public participation
can occur at several points in the permit development process. The Control
Authority may want to meet with the industrial user and inrerested citizens
prior to drafting the permit or wait until a draft permit Is available for
discussion. Alternatively, the Control Authority may choose to distribute
copies of a completed draft permit and request comments in writing. A
subsequent meeting can be arranged to discuss these comments, If warranted.
If comments are received from the public, the Control \uthority should
review them and respond in writing, either on an Individual, basis to each
commenter, or for all commenters in a single "Response to Comment" document
issued at the same time as the final permit. The Control Authority should
keep a record of all public meetings, comments received, and telephone
conversations to document how the permit was developed and to substantiate
that proper procedures were followed. Informal practices during the permit
development and issuance processes (such as undocumented meetings or
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CHAPTER 3 LEGAL AUTHORITY FOR A PERMIT PROGRAM AND PERMIT ISSUANCE PROCEDURES
undocumented verbal communications) with the industrial user or any other
interested party may create the appearance of undue and inequitable influence.
Therefore, such practices should be avoided.
Even where a Control Authority chooses not to involve the general public
in its permit issuance process, it must still develop procedures to respond to
individual requests to be notified of permitting activities. EPA regulations
require Control Authorities to provide individual notice and opportunity to
comment to persons or groups who request notification of local limits
development [40 CFR 403.5(c)(3)]. Consequently, Control Authorities are
expected to, at a minimum, maintain a mailing list of interested persons and
provide them with notice of local limit development.
3.3 ISSUING THE FINAL PERMIT
Once the public participation requirements, if any, are satisfied, the
Control Authority revises the draft permit as necessary and proceeds to issue
a final permit to the user. A transntittal letter accompanying the permit
should summarize its contents. For example, the effective and expiration
dates, its enforceability, and, where available, procedures for appealing the
permit conditions being imposed should be summarized. To ensure that the
industrial user receives the permit, it is recommended that one of the
following delivery methods be followed: hand delivery or sending the permit
by certified mail with return receipt requested.
In all cases, a signature should be obtained from the person accepting
delivery of the permit. This signature should only indicate that the
applicant has received the permit. There should not be a statement indicating
that, by signing, the permittee agrees to comply with the terms and conditions
of the permit. Such a statement could, depending on the circumstances, be
misconstrued as changing the legal nature of the document from a permit to a
contractual agreement; thereby affecting the interpretations and
enforceability of the terms and conditions of the permit.
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CHAPTER 3 LEGAL AUTHORITY FOR A PERMIT PROGRAM AND PERMIT ISSUANCE PROCEDURES
3.4 PERMIT APPEALS
Once the final permit is issued, industrial users should have the right
to challenge or appeal specific provisions of the permit which they believe
are contrary to law or an unreasonable exercise of the Control Authority's
discretion under that law. The appeal period specified in the local ordinance
should be clearly identified in the letter transmitting th«; final permit (See
Appendix F), together with a brief description of the procedures the permittee
must follow to file an appeal. The most effective permit programs provide
that once the limited time period for administrative and/or judicial appeals
has passed, the permittee may not challenge the legality or appropriateness of
the permit terms. Thus the permittee may not (in an enforcement proceeding)
raise issues that could have been raised in a permit appeal.
The Control Authority should establish, through its sewer use ordinance,
an administrative forum where interested parties may request reconsideration
of specific permit conditions. An administrative appeal process may allow
legitimate errors to be corrected without expending the resource requirements
of a judicial proceeding. The Control Authority should consider the factors
listed below when fashioning an administrative appeal mechanism.
• Requests for reconsideration should be in writing and include
supporting reasons for reconsidering the permit conditions.
• Requests for reconsideration should be made soon after final issuance
(15-30 days) after which time the right of reconsideration, by the
Control Authority or by a court of law, is considered waived.
• Reconsideration requests should be evaluated by someone other than the
person drafting and issuing the final permit. For example, if the
Control Authority has a Board of Directors or a Director who was not
directly involved in permit development, the Board or the Director
should consider the appeal.
• The appeal may be considered on the basis of written submissions only
or may also provide for a hearing before the Board or Director.
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CHAPTER 3 LEGAL AUTHORITY FOR A PERMIT PROGRAM AND PERMIT ISSUANCE PROCEDURES
• The request for reconsideration should not result in an automatic stay
of the final permit conditions. However, in the event the request is
granted, a stay night be considered appropriate at the discretion of
the Board or the Director.
The ordinance should also provide the permittee with a limited time to bring a
judicial appeal if the administrative appeal is not successful, after which
the right to such an appeal is considered waived.
3.5 PERMIT RZISSUANCE
A permit application to renew the user's current permit must be received
with adequate lead time for the Control Authority to issue a new permit prior
to the existing permit's expiration. Ideally, the permit issuance process
should take no more than two months to complete for any user. Therefore, EPA
recommends that applications for reissuance be filed at least 90 days prior to
expiration of the existing permit. To lessen the administrative burden on the
Control Authority and to provide additional time to review the permit
applications, it is recommended that permits be issued with staggered
expiration dates. For additional information on permit issuance and
reissuance, see Chapter 2.
3.6 CONTINUING PERMITS BEYOND THEIR EXPIRATION DATE
A Control Authority may wish to state in its sewer use ordinance that a
permit's effectiveness continues beyond its expiration date where the
permittee has filed a timely application for permit reissuance but the Control
Authority, through no fault on the part of the industrial user, has not
reissued the permit at the time of expiration. This is important because the
ordinance will typically forbid discharge without a valid permit. Thus, an
industrial user, through no fault of its own, could be forced to either cease
operations or to continue discharging in violation of the ordinance. Also, in
locations where there is no prohibition on industrial user discharges without
a permit, the user would not specifically be required to continue to follow
the prescribed permit conditions of a lapsed permit pending Control Authority
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CHAPTER 3 LEGAL AUTHORITY FOR A PERMIT PROGRAM AND PERMIT ISSUANCE PROCEDURES
reissuance of the permit. However. EPA does not expect permits to be
routinely continued beyond their expiration dates and this stopgap measure
should only be relied on in unusual situations. This procedure should not be
used in lieu of maintaining a sufficient permitting staff Dr reissuing permits
in a timely manner. Furthermore, the length of time a pemit is continued
should be kept as brief as possible. The Control Authority should be aware
that the failure to reissue any permit within 180 days of expiration may
result in a determination that the Control Authority itself is in reportable
noncompliance with the terms of its NPDES permit. For additional information
regarding reportable noncompliance, please refer to EPA's FY 1990 Guidance for
Reporting and Evaluating POTW NoneQUIDliance with Pretreatment Requirements.
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PART II
PERMIT WRITING PROCEDURES
-------
CHAPTER A
PERMIT APPLICATIONS
After the Control Authority has established its legal authority and
permitting procedures (as discussed in Chapter 3), permit preparation can
begin in earnest. The initial step in this process is to obtain and review
industrial user data from the permit application and all other pertinent
background information. The permit writer must evaluate and verify the
completeness and accuracy of these data because they are used as a basis for
permitting decisions.
4.1 WHAT INFORMATION TO COLLECT
The Control Authority's ordinance should require an industrial user to
complete and file a permit application in order to receive a permit. The
permit application serves as the formal request from the industrial user to
the Control Authority to connect and/or discharge to the sewer system. The
application enables the Control Authority to obtain the information necessary
to evaluate the quality and quantity of wastewater to be discharged and to
determine what controls to place on the discharge.
The permit application format should be standardized so that all
necessary information is requested, but should also allow the applicant the
leeway to include narrative information. While it is evident that the
industrial user should be required to provide flow and wastewater
characteristics, other information, such as number of employees and list of
chemicals used or stored, is also vital to the permit writer. The number of
employees can indicate the magnitude of sanitary flow and the list of
chemicals can indicate potential pollutants present in the wastestream. This
information can lead to a better understanding of the facility's operations
which, in turn, enables the permit writer to evaluate the industrial user's
discharge comprehensively and to develop adequate and appropriate permit
conditions. An example of an application form appears in Appendix E.
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CHAPTER 4 PERMIT APPLICATIONS
4.2 APPLICATION REVIEW PROCESS
After receiving the completed application, the review process begins.
First, the application should be reviewed for completeness and accuracy of the
information submitted. Because the draft permit is based upon the information
in the application, it is imperative that the permit writer use all means
possible, including inspecting the facility, to verify its completeness and
accuracy.
4.2.1 Completenax
At a minimum, the application form should have all applicable spaces
filled in. Instructions provided to the industrial user on how to complete
the application should state that all items must be completed and that the
term "not applicable" should be used to show that the item was considered but
was not pertinent to the facility. If blanks do appear on the submitted
application form, the permit writer must obtain a response to the items before
issuing a permit. In some cases, obtaining a response can be handled over the
telephone, with the phone conversation documented in writirg. However, the
permit writer may choose to meet the responsible party at the industry to
assist in completing the missing application information and clarifying
questions that may not have been understood. The most reliable method is to
obtain the response in writing by returning a copy of the application to the
applicant for completion. This method has the advantages of requiring the
permit applicant to actually fill in the blanks in the application thereby
allowing greater clarity as to who provided the information and who is
responsible for any inaccuracies or distortions of fact. Additionally, the
permit writer should conduct a facility inspection in order to determine
whether the information on the application is complete. If changes or
corrections to any application are extensive, the applicant may be required to
submit a new application.
When reviewing the application for completeness, the permit writer should
make sure that two items which are often overlooked by applicants are included
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CHAPTER 4 PERMIT APPLICATIONS
in the application: 1) the facility's sewer piping layout and process
diagrams; and 2) effluent data (of course, new facilities would not have
effluent data, but should provide estimates based on best professional
judgment). Applicants may fail to submit any data whatsoever or data
sufficient to characterize the facility properly. Waste characterization
(through sampling and analysis) of individual wastestreams may be necessary.
Pollutant data on the final effluent may not always be adequate for complex
facilities where internal wastestreams can be diluted by large volumes of
cooling water prior to the sampling point. In some cases, such as where
significant dilution is thought to occur, data on the characteristics of
internal wastestreams, particularly treatment unit effluents, may be needed to
assess the adequacy of existing pollution controls and the feasibility of
achieving greater reductions of pollutants in the effluent. In addition,
flows of internal wastestrearas should be known if the permit writer is
applying the combined wastestreara formula. Table 4-1 (page 4-12) gives two
examples of how to analyze permit applications to determine if they are
complete. The permit writer should not hesitate to require any
supplementary information (such as more detailed production information or
monitoring data) needed to develop the permit.
Finally, signatories must be of sufficient stature (e.g., a corporate
officer) so as to enable the Control Authority to hold the facility legally
responsible for the representations made in permit applications and subsequent
compliance reports. EPA regulations [40 CFR 403.12(1)) require that reports
from categorical industrial users be signed by the following persons:
a) By a responsible corporate officer, if the industrial user submitting
the reports is a corporation. For the purposes of this paragraph, a
responsible corporate officer means:
(i) a president, secretary, treasurer, or vice-president of the
corporation in charge of a principle business function or any
other person who performs similar policy- or decision-making
functions for the corporation, or;
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CHAPTER 4 PERMIT APPLICATIONS
(ii) the manager of one or more manufacturing, production, or
operation facilities employing more than 250 persons or having
gross annual sales or expenditures exceeding $25 million (in
second-quarter 1980 dollars), if authority to sign documents has
been assigned or delegated to the manager in accordance with
corporate procedures.
b) By a general partner or proprietor if the industrial user submitting
the reports is a partnership or sole proprietorship respectively.
c) The principal executive officer or director having responsibility for
the overall operation of the discharging facility :.f the Industrial
User submitting the reports is a Federal, State, or local
governmental entity, or their agents.
d) By a duly authorized representative of the individual designated in
paragraph (a), (b), or (c) of this section if:
(i) the authorization is made in writing by the individual described
in paragraph (a), (b), or (c);
(ii) the authorization specifies either an individual or a position
having responsibility for the overall operation of the facility
from which the industrial discharge originates, such as the
position of plant manager, operator of a well, or a well field
superintendent, or a position of equivalent responsibility, or
having overall responsibility for environment.il matters for the
company; and
(iii) the written authorization is submitted to the City.
e) If an authorization under paragraph (d) of this section is no longer
accurate because a different individual or position has
responsibility for the overall operation of the facility, or overall
responsibility for environmental matters for the company, a new
authorization satisfying the requirements of paragraph (d) of this
section must be submitted to the City prior to or together with any
reports to be signed by an authorized representative.
4.2.2 Accuracy
A permit application must be accurate. In other words, not only should
all of the necessary information be submitted (complete), it must also be
correct. While it may be difficult to detect certain inaccuracies, a number
of common mistakes can be readily detected. When mistakes are detected, they
must be corrected. The permit writer should follow the same procedures to
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CHAPTER 4 PERMIT APPLICATIONS
correct inaccurate information as were used to obtain missing information.
The examples in Table 4-2 (page 4-13) illustrate the type of review which the
permit writer must conduct.
In verifying the industrial user's information, particular attention
should be given to:
• Information on the use, production, and discharge of toxic substances
• Information on all wastestreans (including schematic flow diagram(s)
and waste characterization of individual wastestreans).
Accurate information on the use or production of toxic or nonconventional
pollutants at a facility and adequate sampling data on these pollutants in the
facility's effluent are essential for preparing appropriate permit limits.
Industrial users should provide a comprehensive list of toxic substances used,
produced (as products, by-products, or intermediates), and stored, and
identify those toxic substances known or suspected to be present in the waste-
stream. If the industrial user lists toxic substances but does not indicate
their potential presence in the wastestream, an explanation for their absence
from the wastestream should be provided. Specific organic constituents of
trade name products or compounds should be obtained from manufacturers.
Facility inspections should be conducted to verify this information by
inspecting all storage areas and reviewing material safety data sheets.
Schematic diagrams of facility operations and internal wastewater streams
should also be verified by inspecting the facility. If the facility is
subject to categorical pretreatment standards, particular attention should be
paid to classifying regulated, unregulated, and dilution wastestreams. Proper
classification of the various wastestreams and accurate flow data on the
individual wastestreams are critical to the calculation of correct effluent
limits.
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CHAPTER 4 PERMIT APPLICATIONS
Facility Inspections may Include dye testing as a method of verifying
piping diagrams or Identifying where piping diagrams do not exist. Developing
a water balance (as Illustrated In Table 4-3, page 4-14), aslng the water and
wastewater flow data provided by the Industrial user, can determine whether
all wastestreans have been accounted for and whether flow data are accurate.
If discrepancies exist, actual flow measurement should be employed to gather
more accurate data.
4.2.3 Background Information Review
To assist in evaluating the completeness and accuracy of the permit
application, the permit writer should consider any additional background
information on the facility which may be relevant. Much of this information
may already be available in the Control Authority's industrial user files.
Pertinent background Information to consider includes:
• Current permit and rationale for the current permit (if one was
prepared) - The permit writer should be aware of the parameters
regulated, the basis for setting effluent limits, and any management
practices required of the discharger. This information will alert the
permit writer to pollutants previously thought to be of concern and
the monitoring requirements deemed appropriate. In addition to
reviewing the industrial user background information, the permit
writer should also consider whether changes In the treatment plant's
operation, Its NPDES permit conditions and/or its sludge disposal
practices and limitations could affect the industry's permit
conditions. If the conditions under which specific discharges were
permitted have not changed since the last permit application, little
reason exists for drastic changes to the conditions for that
discharge, assuming the previous permit was developed properly.
Exceptions to this Include cases where a record of problems or
noncompliance exists at the facility, as discussed below.
• Old peralt application, baieline monitoring report, and industrial
y«Bte lurveri - Information In these documents can be used: (1) to
establish past operating practices and conditions; (2) as a baseline
for evaluating the new application; and (3) to identify changes.
• Compliance inspection report*. »ampling data, and self-monitorIng
report! - These reports may provide the permit writer with Information
regarding possible causes for any permit violations, indicate how well
wastewater treatment units are operated, and provide insight as to the
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CHAPTER 4 PERMIT APPLICATIONS
discharger's attitude toward environmental compliance. Information
gathered from these reports such as evidence of spills or poor
operation and maintenance of a pretreatnent system may also provide a
basis for the requirement of industrial user management practices as a
permit condition. If these reports reveal any changes in the
facility's operations (compared to the previous permit application),
these differences should be noted and verified on the latest
application. Any discrepancies should be resolved to the permit
writer's satisfaction before a permit is issued.
Review and evaluation of sampling data are important because these
data can indicate how consistently the permit limits have been met
(this information may be relevant in establishing monitoring
frequencies required in the new permit). Changes in monitoring data
or compliance can also indicate possible changes at the facility.
• Correspondence concerning compliance or enforcement actioni - This
information can alert the permit writer to the occurrence and/or
resolution of compliance problems and can be used to assist the permit
writer in determining monitoring frequencies and/or special
conditions.
The permit writer can obtain additional Information on the industrial
processes and pollutants that might be present, by reviewing National
categorical pretreatment regulations, related development documents, reference
text books on specific industry categories, EPA's Treatabillty Manual, and
information from other environmental permit programs such as the Resource
Conservation and Recovery Act (RCRA) and the Clean Air Act. As needed,
supplemental information should be requested from various State agencies, EPA
Regional offices, EPA's Industrial Technology Division, and the applicant.
A.2.A Facility Inspection
As mentioned earlier, a facility inspection is necessary to verify
application information and to gain an understanding of the industrial user's
facilities. The inspection should encompass a review of the following:
• Production processes - This will assist the permit writer in
identifying:
Applicable categorical pretreatment standards
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CHAPTER 4 PERMIT APPLICATIONS
Toxic or hazardous substances Chat nay be presert in raw materials,
products, and by-products that have the potential to be present in
the industry's discharge
Water uses and resulting wastewater streams
Existing in-process pollution controls
Potential for spills and leaks.
From this information, the permit writer can select pollutants to be
limited and/or require development of additional in-process controls.
• Sewer layout of the plant - If a sewer plan exists, the permit writer
needs to review the plan thoroughly to determine the course and
destination of each sewer line. The exact source of and the point at
which each wastestream enters the sewer need to be identified. The
existing monitoring point or any potential location for monitoring
should also be located. Where sewer plans do not exist, smoke or dye
testing should be performed in order to locate all points of discharge
to the sewer system. This information will be used to determine the
appropriate sampling points, to ensure that all points of discharge to
the sewer system will be identified in the permit, and to evaluate the
need for application of the combined wastestream formula.
• Wastewater treatment facilities, including treatment: performance and
operation and maintenance practices - This information can be used
to evaluate the adequacy of existing treatment, to assess the
feasibility of improvements, and to evaluate perforriance data.
• Types of batch discharges that occur at the facility - This informa-
tion could affect the design of the monitoring requirements. Clean-up
operations usually result in batch discharges of washdown water.
Information about clean-up times and water volumes should be sought.
• Raw material and product storage and loading areas, sludge storage and
disposal areas, hazardous waste management facilities (if applicable)
including onsite disposal areas, and all process areas and the
proximity of these areas to sewer discharge points - This review will
help to identify potential pollutants and potential or known problems
with spills or leaks. This information is then used to determine the
need for additional controls through the establishment of specific
industrial user management practices (e.g., slug loading control
plans, toxic organic management plans, and good housekeeping
practices).
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CHAPTER 4 PERMIT APPLICATIONS
• Sampling points, sampling methods, and analytical techniques - This
information is needed to define any needed changes and to evaluate the
quality of both the Control Authority's and the industrial user's
sampling data.
To conduct an adequate inspection of a facility may require a full day.
Complex plants with several treatment systems, numerous sewer connections, and
extensive ancillary activities may require more than one day to inspect.
Guidance on the performance of inspections may be found in the NPDES
Compliance Inspection Manual. EPA Region 8's draft Industrial Pretreatment
Program Inspection Manual, and EPA's Pretreatment Facility Inspection.
4.3 PUBLIC ACCESS TO INFORMATION
Certain information collected through a permit application form and
industrial monitoring reports must be made available to the general public
upon request [40 CFR 403.14(b)]. The following information is considered
"effluent data" under 40 CFR Part 2 of EPA's regulations and must always be
available to the public:
• General description of the location and nature of the source to the
extent necessary to identify the source and distinguish it from other
sources (including, to the extent necessary for such purposes, a
description of the device, installation, or operation constituting the
source)
• Information necessary to determine the identity, amount, frequency,
concentration, temperature, or other characteristics (to the extent
related to water quality) of the pollutants which, under an applicable
standard or limitation, the source was authorized to discharge
(including, to the extent necessary for such purpose, a description of
the manner or rate of operation of the source)
• Information necessary to determine the identity, amount, frequency,
concentration, temperature, or other characteristics (to the extent
related to water quality) of any pollutant which has been discharged.
While the effluent data must be made available to the public, other data
submitted by industrial users may be claimed "confidential" and withheld from
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CHAPTER 4 PERMIT APPLICATIONS
public scrutiny. Of course, the Control Authority must release information
submitted under a claim of confidentiality to the Approval Authority and EPA
(if different) whenever requested to do so. In order to guarantee that
effluent data remain available for public review, it is recommended Chat the
ordinance specifically state that effluent data [as defined in 40 CFR
2.302(a)(2)] will not be considered confidential under any circumstances. The
ordinance may also provide that proprietary information or trade secrets will
be entitled to consideration by the Control Authority for possible
confidential treatment (provided these are not "effluent data") if the
industrial user stamps "Confidential Business Information" over all parts for
which protection is sought. The Control Authority, when it first receives the
request for confidential treatment of submitted information, may make an
immediate determination as to whether to grant the request or defer making a
determination until it receives a request to disclose the information.
If the Control Authority does not make a determination until a request to
disclose is received, the Control Authority should notify :he industrial user
that a request to disclose has been received, inform the industrial user of
the preliminary determination, and provide an opportunity for the industrial
user to appeal. A period of 15 days should be allowed for the industrial user
to respond after which if no response is obtained the Cont.rol Authority can
release the data (if the information was not entitled to confidentiality) or
deny the request to disclose (if the information is considered confidential).
If the Control Authority makes a determination when it first receives the
request for confidentiality and determines that the information is not
entitled to confidential treatment, it should notify the industrial user
orally and then by written notice of the denial of confidentiality status.
The written notice may be made by certified mail return receipt requested, by
personal delivery, or by other means which allow verification of the fact of
receipt and the date of receipt. This written notice should provide an
opportunity for the industrial user to appeal the decision within 15 days.
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CHAPTER 4 PERMIT APPLICATIONS
If the information is deemed confidential (or if it is being treated as
confidential pending a final determination), it should be separated from the
rest of the permit file and kept in "limited access" (lock and key) status.
This will typically require the creation of a second file for each user which
contains additional confidential materials. Access to this special
information should be safeguarded, even against Control Authority employees
who have no legitimate reason for access to such materials. In the event such
information is turned over to EPA, it will receive such protection as is
afforded by 40 CFR Part 2. All information which is not specifically
identified as confidential (or which is later determined by the Control
Authority not to be entitled to confidential treatment) should be available to
the public upon request.
It is important to maintain the public information in an orderly and
complete manner and protect against theft or destruction of valuable
documents. Therefore, it is recommended that a "request system" be devised
which will create a permanent record of the information requested and the
person(s) handling and receiving the data. Such a system might function
similar to a checkout system at a public library and would enable the Control
Authority to identify persons looking at the file in the event a portion of it
was ever missing. In fact, it is recommended that the Control Authority has
photocopying services available in order to prohibit files from being taken
off the premises.
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CHAPTER 4 PERMIT APPLICATIONS
TABLE 4-1. EXAMPLES OF DEFICIENCIES COMMONLY FOUND IN PERMIT
APPLICATIONS
• Are required toxic organic pollutants listed?
Example: An application from an industrial user subject to Federal
categorical metal finishing regulations fails to list the presence or absence
of any toxic organics.
Discussion: Industrial facilities subject to metal finishing categorical
standards are regulated for 111 toxic organics (40 CFR 433.11(e)]. To comply
with the Federal baseline monitoring report (BHR) requirements, the facility
must monitor for those regulated toxic organics reasonably expected to be
present, based on a process engineering analysis of the rav materials used and
the possibility of any toxic organics present at the facility coming into
contact vith water and wastewater sources. If no toxic organics are used or
expected to be discharged, this should be so seated by the facility's
authorized representative. [Note: For the purposes of tha BHR had this
industrial facility been subject to the Total Toxic Organic (TTO) standard for
the electrical and electronic components industrial category, it vould have
been required to monitor for all regulated toxic organics. The permit writer
needs to check the specific categorical regulations to determine the TTO
requirements for each category.]
0 Are all expected pollutants listed?
Example: A Jobshop electroplater marks zinc and copper as "believed
absent in the wastewater."
Discussion: If the facility discharges 10,000 gpd or more, zinc and
copper are regulated by the electroplating categorical standards (40 CFR 413
Subpart A) and must be monitored even if they are not expected to be present
in the discharge in significant quantities [40 CFR 403.12(b) and (e)]. If the
facility discharges less than 10,000 gpd, zinc and copper are not regulated
and, therefore, not required to be monitored by Federal regulations; however,
these pollutants may be present in trace amounts in proprietary chemicals or
because the base material contains zinc or copper. A comprehensive test will
determine whether any unexpected contaminants are present in significant
quantities and will provide information on levels of pollut.ints which are
known to be present.
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CHAPTER 4 PERMIT APPLICATIONS
TABLE 4-2. INACCURACIES IN PERMIT APPLICATIONS
• Do the reported values coaport with the existing permit, previous
application, and monitoring data?
Example: The monitoring data from the previous permit shoved an average
discharge of 38 pounds per day for oil and grease. The new application
reports an average of 3.3 pounds per day.
Discussion: There may be a problem in calculation here. It could be
simply a shift in the decimal point, or it could involve some other type of
error. It also could represent a significant change in production techniques
or treatment efficiencies.
• Are analytical detection limits sufficient to detect the presence of
pollutants?
Example: An industrial user subject to the metal finishing categorical
pretreatment standards reported that methylene chloride was not detected at
Che detection level of 0.1 mg/1.
Discussion: The TTO standard is the summation of all quantifiable values
greater than 0.01 mg/1 of the specific toxic organics listed in the
regulation. A detection limit of 0.1 mg/1 would not reveal the presence of
methylene chloride at concentrations between 0.01 mg/1 and 0.1 mg/1. The
permit writer should verify that the best approved analytical procedures were
used to verify the presence or absence of methylene chloride. If not. further
testing using approved procedures should be required.
• Do the concentration, mass, and flow values correspond?
Example: Suppose an industrial user reports a maximum daily flow of 0.12
mgd, a daily suspended solids concentration of 23 mg/1, and a maximum daily
mass discharge of 2.3 pounds per day.
Discussion: There appears to be a mathematical error since the maximum
daily flow and concentration yield a maximum daily discharge of 23 pounds per
day. The permit writer should investigate this apparent error.
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CHAPTER 4 PERMIT APPLICATIONS
TABLE 4-3. VERIFICATION OF FLOW DATA USING WATER BALANCE
An industrial user has estimated a wastestream flov of 50.000
gpd using water usage records. However, a review of historical water usage
records and an old permit application indicates wastewater flows ranged from
100,000 to 150,000 gpd. The facility had not instituted tny water-reduction
measures, significantly changed its process operations, or decreased its
number of employees.
Discussion: An inspection of the facility revealed tvo separate water
meters (one for sanitary and one for process water); the industrial user had
overlooked the sanitary meter. Further, the process water meter was found to
be defective. Subsequent flow monitoring of the total wastestream recorded a
flow of 125,000 gpd. A new water meter was installed and concurrent
wastestream flow monitoring and water meter readings resulted in the following
water balances:
Hater In (based on both water meter readings): 148,000 gpd (131,000 gpd
process line and 17,000 gpd sanitary line)
Water Out (based on wastestream flow monitoring): 125,000 gpd total
wastestream discharged to sewer system. Evaporative and consumption losses
were estimated at 23,000 gpd (15 percent of total water usage).
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CHAPTER 5
GENERAL PERMITTING CONSIDERATIONS
5.1 CONTENTS OF PERMIT
Once complete and accurate Information is obtained and verified, the next
step in the industrial user permit development process is to draft the actual
permit. At a minimum, the permit should consist of the following elements:
• Cover page (Chapter 6)
• Effluent limits (Chapter 7)
• Monitoring requirements (Chapter 8, Sections 8.1-8.5)
• Reporting requirements (Chapter 8, Section 8.6)
• Standard conditions (Chapter 9)
• Special conditions where necessary to adequately regulate the dis-
charge (Chapter 10).
These elements are set out in a sample permit in Appendix F and sample
standard conditions in Appendix G. These appendices illustrate many of the
concepts discussed in this chapter. Before the six elements are discussed in
more detail, some general considerations need to be emphasized: the care that
should be taken in the structure and wording of the permit; common permitting
errors or omissions to avoid; the flexibility of the permit; and the
importance of documenting all permit decisions.
5.2 STRUCTURE AND WORDING
The structure and wording of a permit directly affect the Control
Authority's ability to invoke its various enforcement options successfully.
For this reason, the permit writer should follow three general rules:
• Use specific language
• Develop concise and complete discharge conditions and requirements
• Write as clearly and simply as possible.
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CHAPTER 5 GENERAL PEtUCTTING CONSIDERATIONS
The permit writer should avoid vague, weak, or obtuse language which could
undermine the permit's enforceability. The list below shows language to avoid
and appropriate language to use in the permit.
AVOID USE
may shall
could required
should must
The permit writer should avoid, as well, overly long and confusing
requirements. However, the permit writer should not be so brief as to leave
out vital specifics. A permit frequently acts as the principal notification
to the industrial user of its responsibilities for compliance. Therefore,
permit requirements must be clear and simple to understand.
5.3 COMMON PERMITTING ERRORS AND OMISSIONS
The permit writer should keep in mind that any of the following errors
and omissions in the permit may cause it, at worst, to be susceptible to legal
challenge or to fail to properly regulate the industrial user, and at best, to
be misleading or confusing to the permittee:
• Failure to correctly calculate and apply effluent limitations from
applicable pretreatraent standards
• Failure to apply the most stringent limit (Federal categorical
pretreatment standard, State requirement, or local limit)
• Failure to regulate all discharge points
• Omission of standard conditions
• Failure to specify adequate monitoring and/or analytical requirements,
including a failure to identify specific monitoring locations
• Use of ambiguous or inappropriate permit commands, such as "should,"
"recommended," and "expected" rather than "required," "shall," "will,"
and "must"
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CHAPTER 5 GENERAL PERMITTING CONSIDERATIONS
• Failure to incorporate specific citations to requirements contained in
an ordinance or regulation, where the requirements are not otherwise
set forth in the permit
• Failure to specify the signatory requirements for self-monitoring
reports and other notification requirements
• Failure to account for any known seasonal changes or other predictable
variations in the effluent.
5.4 FLEXIBILITY
Specific conditions within each permit element should be tailored to the
industrial user for which the permit is intended. While it may be obvious
that very dissimilar industrial users will need different permit conditions,
even similar industrial users may need permit conditions tailored to
site-specific discharge situations. Table 5-1 (page 5-5) presents an example
which illustrates the use of flexibility in the permit system.
Certain permit conditions are not flexible and cannot be modified. For
example, the permit writer cannot modify categorical pretreatment standards
and requirements or the general and specific prohibitions in 40 CFR 403.5.
The following are Federal requirements that must be imposed on industrial
users where they apply:
• Those conditions based on Federal pretreatment standards and
requirements
• Use of the combined wastestrean or flow weighted averaging formulas to
derive appropriate limits for categorical industrial users where
applicable
• Requirement to follow analytical methods in 40 CFR Part 136 or other
EPA-approved methods for wastewater analyses.
Likewise, any condition mandated by State law or local ordinance with which
the industrial user must comply typically cannot be modified by the permit
writer, such as:
• Those conditions based on State pretreatment standards and
requirements (unless otherwise specified)
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CHAPTER 5 GENERAL PERMITTING CONSIDERATIONS
• Standard conditions adopted by the Control Authority
• Control Authority's ability to modify or terminate the permit during
Its effective period
• Extent of the permittee's enforcement liability in the event of
noncompliance.
Flexibility is provided, however, in the drafting process allowing the
permit writer to analyze comments and modify portions of the permit.
Conditions which typically (depending on legal authority) may be modified in
light of comments received and the particular circumstances include those
regarding:
• Uastewater flow rate
• Production rates
• Pollutants of concern other than those addressed bv Federal, State, or
local regulations
• Monitoring location and frequency
• Special conditions
• Effective period (a maximum of five years is recommended).
5.5 DOCUMENTING PERMIT DECISIONS
Throughout the permit drafting process, the permit writer should
carefully and thoroughly document each step. There are several reasons for
this. First, It will assist the permit writer in developing the permit in a
thorough and logical fashion. Second, it will facilitate defending any
challenges that the permit terms and conditions were developed in an arbitrary
or capricious manner. Finally, careful documentation will make future permit
reissuance easier, particularly If a new permit writer is responsible for
permit reissuance. Chapter 11 discusses development of the two critical
elements needed to properly document the permit issuance process; a
documentary record and a fact sheet.
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CHAPTER 5 GENERAL PERMITTING CONSIDERATIONS
TABLE 5-1. EXAMPLE OF PERMIT FLEXIBILITY
Company X, which manufactures product X, conducts metal finishing
operations including zinc plating, phosphate coating (using a zinc-phosphate
solution), and painting. The company has a history of zinc violations and has
a continuous discharge of 35,000 gpd.
Company Y manufactures product Y and, like Company X, conducts metal
finishing operations including zinc plating, phosphate coating, and painting.
However, Company Y's operations are on a smaller scale. Plating is done only
one or two days a week; the company has switched to an iron phosphate solution
and recycles the phosphate solution and first rinse waters. The discharge Ls
less than 3,000 gpd.
The Control Authority writes a permit for Company X that contains
conditions based on the applicable metal finishing categorical pretreatment
standards. The permit also requires weekly monitoring for zinc and monitoring
for the other metals six times per year. Company Y's permit, like Company
X's, contains conditions based on applicable metal finishing categorical
pretreatment standards but requires only monthly monitoring for zinc (on a day
when any batch discharges from the recycled phosphate solution and first rinse
waters and plating operations occur) and a twice per year monitoring for all
other metals regulated in the permit.
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CHAPTER 6
COMPONENTS OF THE COVER PAGE
The most basic and, therefore, most frequently overlooked portion of a
permit is the cover page. However, drafting the cover page improperly may
have significant ramifications regarding permit enforceability. An example of
a cover page is shown on page F-2 of Appendix F.
6.1 FORMAT
The cover page should have the appearance of a legal document. It is
recommended that the cover page appear on official agency letterhead or
stationery or on a special permit form.
6.2 ELEMENTS OF THE COVER PAGE
The cover page should contain the following:
• Name and address of the permittee - The correct and legal name of the
permittee should be used. The facility's physical location address
should be used. The mailing address can also appear on the cover
page.
• Citation to legal authority - A specific citation to the Control
Authority's legal authority to issue and enforce permit provisions.
• Duty to comply - The permittee's duty to comply with all applicable
Federal, State, and local laws whether or not they are specifically
incorporated into the permit.
• Reapplication requirements - The permittee's duty to reapply for
continuation of the permit prior to the expiration date.
• Effective period - The permit's effective date and expiration date
must be clearly set out. If the permit's effectiveness is to begin on
a date other than the one on which it was signed or issued by the
Control Authority, that effective date should appear clearly on the
cover page. Although Control Authorities may establish shorter
durations, the effective periods should extend no more than 5 years
into the future for significant industrial users.
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CHAPTER 6 COMPONENTS OF THE COVER PAGE
• Signature of Control Authority - The permit should be signed and dated
only by a Control Authority official authorized to issue permits.
Failure to sign and date the permit properly may call its validity
into question at a later date. In addition, to avoid any possible
misunderstanding that the permit is some form of contract, the
industrial user should not sign the permit. For a further discussion
see Chapter 3.
The cover page should also clearly state that a violation of any permit
provision is a violation of the Control Authority's sewer use ordinance and
may subject the permittee to enforcement action. In addition, if the
ordinance requires the industrial user to have a permit before it can commence
its discharge, the cover page should indicate that the pern it allows or grants
the industrial user permission to discharge.
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CHAPTER 7
EFFLUENT LIMITATIONS
This chapter explains how to select which pollutants to specifically
regulate and how to derive effluent limits for application in a permit.
7.1 SELECTING POLLUTANTS TO BE REGULATED
To identify pollutants to be regulated, the permit writer must first
determine what pollutants are present or suspected of being present in the
wastewater. A determination can then be made on which of these pollutants to
regulate. These two steps are outlined below. Of course specific permit
limits must be developed, independent of this evaluation, for pollutants
regulated by applicable Federal categorical pretreatment standards.
7.1.1 What Pollutants are Present
This first step is accomplished by reviewing the permit application and
other supplemental materials requested from the industrial user. For example,
analytical data on wastewater quality indicate actual pollutants present and
the concentration/strength of these pollutants in the wastewater; a list of
raw materials enables the permit writer to identify additional possible
pollutants that could be present in the wastestream; and flow data help the
permit writer identify variability in pollutant and hydraulic loadings.
7.1.2 Vfhich Pollutants Require Regulation
After determining what pollutants are present, the permit writer must
decide which of these pollutants require regulation. The permit should
contain effluent limits based on:
• National prohibited discharges (general and specific) [40 CFR 403.5(a)
and (b)]
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CHAPTER 7 EFFLUENT LIMITATIONS
• Categorical pretreatment standards [40 CFR Parts 405-471]
• Local limits [40 CFR 403.5(c) and (d)].
The examples in Table 7-1 (page 7-13) illustrate how a permit writer
selects pollutants for regulation.
7.1.2.1 National Prohibited Discharge*
Section 403.5(a) and (b) of the General Pretreatment Regulations
establishes general and specific prohibitions that apply 1:0 all nondomestic
users that discharge to POTWs (see Table 7-2 on page 7-14). Local ordinances
for POTWs with approved pretreatment programs should already include authority
for local enforcement of these provisions. As of the dat;r to the ordinance
section containing those standards.
7.1.2.2 Categorical Pretreatment Standards
Categorical pretreatment standards are technology-based standards for a
selected group of industries established by EPA under authority of the Clean
Water Act. These standards are developed based upon industry-wide studies of
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CHAPTER 7 EFFLUENT LIMITATIONS
current treatment practices for pollution control and, therefore, establish
national baseline pollution control requirements for the regulated industrial
categories. Pretreatment standards are generally promulgated for both
existing sources and new sources. These standards may be the same or
different. If an industrial user is subject to categorical pretreatment
standards, the permit writer must include effluent limits based on these
standards in the user's permit. In order to include all relevant categorical
pretreatment standards in the permit, the permit writer must be familiar with
specific categorical pretreatment standards to which the industrial user is
subject and follow the rules below to apply categorical pretreatment
standards.
Rules for Applying Categorical Pretreatment Standards
• Determine the proper category and subcategory for the industrial
processes operated by the permittee.
• Identify all regulated, unregulated, and dilution wastestreams.
• Identify appropriate sampling locations.
• Categorical standards apply directly to the regulated wastestream or at
the end of pretreatment of the regulated wastestream. When the
designated sampling location described in the permit contains a
regulated wastestream and one or more other wastestreams (dilution,
regulated, or unregulated), then the Combined Wastestreara Formula (CWF)
or the Flow Weighted Averaging Formula (FWA) must be used to calculate
appropriate effluent limits based on the categorical pretreatraent
standards.
• Effluent limits based on both the daily maximum and the monthly average
categorical pretreatment standards must be included in the permit.
• Limitations on all pollutants regulated by the categorical pretreatment
standards must be included in the permit, even though the industrial
user may not discharge all of the regulated pollutants. Note, however,
that some of the categorical regulations allow the use of indicator
pollutants or allow exemptions from monitoring for certain pollutants.
• The Control Authority has the option of converting production-based
categorical pretreatment standards to equivalent mass or equivalent
concentration limits.
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CHAPTER 7 EFFLUENT LIMITATIONS
• Categorical pretreatment standards establish the compliance date(s) by
which industrial users covered by the standards must be in compliance.
The Control Authority cannot extend these Federally-promulgated dates
In the permit.
Several EPA documents provide guidance on how to apply categorical pre-
treatment standards. Appendix A of this manual provides an alphabetical
listing of all currently available development documents and guidance manuals;
these should be used to supplement the information provided in this section
and in the standards themselves for incorporating into permits effluent limits
based on the standards.
Rules for Applying Production-Based Categorical Pretreataent Standards
The incorporation of production-based categorical pretreatment standards
in permits involves special considerations. These standards are expressed in
terms of an allowable pollutant mass discharge per unit of production, such as
pounds of pollutant per 1,000 pounds of product produced. The standards can
be placed in the permit verbatim from the regulations. The permit should then
require the industrial user to submit actual production da:a from the date(s)
on which the compliance samples were collected and to calculate the actual
mass of pollutant(s) discharged, based on flow and concentration, to evaluate
compliance for that specific day.
Often, it may be impractical or difficult for the Control Authority to
independently determine or verify compliance since the production rate as well
as the wastestream flow and pollutant concentration must b«; known. The
Control Authority has the option of using equivalent mass or concentration
limits [40 CFR 403.6(c)]. Equivalent mass or concentration limits use an
industry's long-term average daily production and flow ratvs to derive the
corresponding daily maximum and monthly average limits. The applicable
formulas are shown in Table 7-4 (page 7-17).
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CHAPTER 7 EFFLUENT LIMITATIONS
The industrial user permit may function as the legal document for the
conversion of production-based standards to equivalent mass or concentration
limits. These equivalent limits are deemed pretreatment standards under
section 307(b) of the Clean Water Act and are Federally enforceable.
It is critical when converting production-based standards to equivalent
mass or concentration limit! that the permit writer correctly calculate the
equivalent limits and document the calculations. A permit containing
equivalent limits must clearly specify: (1) the applicable equivalent limits;
(2) the flow and production rates upon which the limits are based; (3) the
requirement that the industrial user report a reasonable measure of its long-
term production rate in each periodic compliance report; (4) the requirement
that the industrial user notify the Control Authority of significant changes
in long-term flow and/or production rates within two days of knowing that they
will change in the next calendar month; and (5) a provision that the Control
Authority may modify the permit based upon such new information. Table 7-5
(page 7-18) provides an example.
Determining the appropriate production rate is one of the critical
factors in deriving equivalent limits. EPA recommends using a production
figure that approximates the long-terra average. Data for a day, week, month,
or year that are unusually high or low should not be used; three to five years
of data should be reviewed to determine the appropriate long-term average.
For example, after reviewing 5 years of data, the permit writer could select
the highest yearly average (provided this value was not unusually high). If a
facility does not have good historical data, as in the case of a new facility
or a facility which has had significant operational changes, the permit writer
will have to rely on the facility's future projections for production.
Detailed guidance and procedures for developing and applying equivalent limits
and example problems are presented in EPA's Guidance Manual for the Use of
Production-Based Pretreatment Standards and the Combined Wastestream Formula.
The permit writer is encouraged to use this guidance manual when developing
equivalent limits. If an industrial user is expected to have significant
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CHAPTER 7 AFFLUENT LIMITATION?
fluctuations in the production (e.g., a 20 percent increase or decrease in the
long-term average) during the permit period, a tiered perm:.t may be
considered. See Section 7.3 for nore detailed discussion on tiered permits.
7.1.2.3 Local Limits
Section 403.5(c) of the General Pretreatment Regulations requires Control
Authorities to develop and enforce specific limits to implement the general
prohibition against pass through and interference [40 CFR 403.5(a)] and the
specific prohibitions [40 CFR 403.5(b)]. In December 1987, EPA published an
extensive guidance document on the development and implementation of local
limits (Guidance Manual on the Development and Implementation of Local
Discharge Limitations Under the Pretreatment Program). For the purposes of
this guidance manual, it is assumed that the Control Authority has developed
local limits in accordance with this guidance or some other acceptable
approach.
The Control Authority may have established local limits for any number of
pollutants. There are several considerations which may affect the Control
Authority's decision on how to incorporate these local limits into industrial
user permits. Two principal considerations are whether or not the sewer use
ordinance contains all the local limits and whether the Control Authority has
allocated the same limits to all industrial users or different limits to
different Industrial users.
When uniform local limits for all users appear in the sewer use
ordinance, the permit writer can include such limits in industrial user
permits in two ways: 1) list only those pollutants and their limits that are
known or believed to be present in the discharge and include a narrative
statement requiring compliance with all local limits contained in the sewer
use ordinance; or 2) list all local limits contained in the .sewer use
ordinance. The first approach highlights those pollutants in that industrial
user's discharge, and the narrative statement ensures that all local limits
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CHAPTER 7 EFFLUENT LIMITATIONS
are also Imposed as a permit condition. The second approach ensures that the
industrial user is aware of all local limits. The permit writer can establish
monitoring requirements for the pollutants present in the discharge. However,
the monitoring frequency for pollutants known to be absent, or present at
levels at or below local background concentrations, could be minimal.
If the uniform local limits do not appear in the Control Authority's
sewer use ordinance, then the permit should contain all of the local limits.
The permit writer can structure the permit so that limits for those pollutants
discharged by the industrial user are highlighted.
The Control Authority may develop industry-specific local limits.
Because each permitted industry receives different numerical limits, it is
difficult to incorporate them into a local sewer use ordinance. In this
situation, the ordinance will generally cite the authority to develop and
implement local limits and state that these limits will be enforced through
industrial user permits. If this method is used, all local limits applicable
to the facility should be included in its permit. This is particularly
important because the limits are not incorporated in the ordinance. The
monitoring frequency for any pollutant of concern could then be set based on
the pollutant's presence in the wastestream.
7.2 APPLYING EFFLUENT LIMITS
It is important that the permit writer correctly apply the effluent
limits in the permit. The permit should clearly designate the point where the
limits apply (e.g., pipe 01), the period in which the limits apply (e.g., from
a specific date to a specific date if different from the effective time period
of the permit), and the units (e.g., mg/1 or Ibs/day). In addition, the
effluent limits should be expressed in terms of the duration for which the
limits themselves are intended to apply (e.g., instantaneous maximum, daily
maximum, or monthly average) and these terms should be well defined. For
example, a daily maximum limit is defined as the average concentration
9/15/89 7-7
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CHAPTER 7 EFFLUENT LIMITATIONS
measured over a 24-hour period (for a concentration limit) or the total mass
discharged over a 24-hour period (for a mass limit). On the other hand,
instantaneous maximum limits are the maximum concentrators in any sample
collected, regardless of the collection period.
7.2.1 Relationship of Local Lialtt to Categorical rretreatment Standards
Categorical pretreatment standards and local limits are distinct and
complementary types of pretreatment standards. Promulgation of a categorical
pretreatment standard by EPA in no way relieves a Control Authority from its
obligation to evaluate the need for, and to develop, local limits to meet the
general and specific prohibitions in the General Pretreatment Regulation. As
mentioned earlier, categorical pretreatment standards are developed to achieve
a degree of water pollution control for selected industries and pollutants
based on an assessment of available technology and costs. Local limits are
intended to prevent site-specific plant and environmental oroblems resulting
from particular nondomestic users.
In implementing its pretreatment program, a Control Authority is required
to enforce the "applicable pretreatment standard" (i.e., Federal, State, or
local, whichever is most stringent). When the Control Authority is drafting a
permit for an industrial user subject to categorical pretroatment standards,
the task of applying the applicable effluent limits can be complicated. Local
limits are often more stringent than categorical pretreatmont standards since
they are based on local site-specific situations. In addition, there may be
local limits for more pollutants than are regulated in the applicable
categorical pretreatment standard. Therefore, a permit may contain a mixture
of categorical pretreatment standards and local limits. One complicating
factor is that, in contrast to the categorical pretreatment standards which
apply to individual discharges from regulated processes (erd-of-process),
local limits normally apply at the point(s) of discharge tc the public sewer
system (end-of-pipe).
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CHAPTER 7 EFFLUENT LIMITATIONS
In the situation where the industrial user's discharge to the public
sever contains only wastewater from a process regulated under a particular
categorical standard, the end-of-process pollutant load is the same as the
end-of-pipe. The determination of which limits apply, local or categorical,
is accomplished by simply choosing the limit which is numerically more
stringent. More commonly, the industry's discharge at the point of connection
contains other regulated wastestreams, unregulated wastestreams, and/or
dilution wastestreams. If categorical standards are to be applied at the
point of connection where dilution or unregulated wastestreams exist, the
permit writer must use the combined wastestream formula or flow-weighted
average formula to adjust the categorical pretreatment standards to end-of-
pipe limits. EPA's Guidance Manual for the Use of Production-Based Pretreat-
ment Standards and the Combined Wastestream Formula (and 51 FR 21454 and 53 FR
40562) contains guidance on these two formulas. These adjusted limits must
then be compared to the Control Authority's local limits and the most
stringent would be included in the permit. The example in Table 7-6 (page
7-19) illustrates the results of comparing Federal and local limits.
In other instances the Control Authority may find it necessary or
preferable to monitor the industrial discharge at more than one location. In
this case the permit must clearly indicate where the specific limits apply and
where samples for various parameters must be collected. For example, a
Control Authority may want to regulate a metal finishing industry by requiring
monitoring for local limits at the connection to the sewer system, monitoring
for categorical pretreatment standards at the discharge from the pretreatment
facility, and monitoring for cyanide on the segregated wastestream from the
cyanide destruct unit of the pretreatment facility.
7.3 TIERED PERMITS
The Control Authority may encounter situations where one set of effluent
limits may not be appropriate for the permit's entire period. A tiered permit
may be appropriate in such situations, eliminating the need for continual
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CHAPTER 7 EFFLUENT LIMITATIONS
permit revisions. For example, an industrial user may be issued one set of
limits for the average production rate and another set which take effect when
there is a significant change in the average production rate. Generally, a 10
to 15 percent deviation above or below the long-term average production is
within the range of normal variability. Predictable changes in the long-term
production higher than this range could warrant consideration of a tiered
permit. Tiered permits are recommended where the long-term average
productionvaries by 20 percent or greater. Typically, there are three
situations where tiered permits are warranted.
The first situation would involve a facility which the Control Authority
knows will begin a new process or add a new process line during the term of
the permit. In this instance the permit writer could include two sets of
limits; one set for the current conditions, and one set for the future
conditions. The permit should also clearly state the terms and conditions
under which each set of limits would apply.
The second situation would involve an industry which ha.i an annual
pattern of low and high production rates. For example, an industry that
produces Christmas items may operate at only 40-50 percent capacity from
January through June, but at full capacity from July through December. In
this instance the permit writer would also develop two (or nore) sets of
limits for the industry. For seasonal variations the permit could stipulate
either dates or production levels which would trigger the application of one
set of limits versus another.
For this type of permit, a special condition should be included in the
permit which requires the industrial user to notify the Control Authority when
this scheduled production charge occurs and/or if unexpected circumstances
cause seasonal operations to differ from the fixed periods defined in the
permit.
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CHAPTER 7 EFFLUENT LIMITATIONS
The third scenario would involve an industry where the demand is variable
and the permit modification process is not fast enough to respond to the need
for higher or lower equivalent Units. A permit might be written with two or
three tiers which apply to ranges of production. For example, a hypothetical
battery plant has a historical average production rate that varies between 40
and 100 percent with a maximum average production rate of 2.0 x 106 Ibs/day.
The plant is subject to a production-based categorical standard for pollutant
X - 1 Ib/million Ib of product (daily maximum). Alternate effluent limits
might be set as follows:
First Tier: Basis of Calculation - 1 x 106 Ibs/day
Limit for Pollutant X - 2.0 Ibs/day (daily maximum)
Applicable Production Range - 0.8 x 106 to 1.2 x 10* Ibs/day
Second Tier: Basis of Calculation - 1.4 x 1C6 Ibs/day
Limit for Pollutant X - 2.8 Ibs/day (daily maximum)
Applicable Production Range - >1.2 x 106 to 1.6 x 106 Ibs/day
Third Tier: Basis of Calculation - 1.8 x 10* Ibs/day
Limit for Pollutant X - 3.6 Ibs/day (daily maximum)
Applicable Production Range - >1.6 x 106 to 2.0 x 10* Ibs/day
The first tier has an applicable production range that covers plus or
minus 20 percent of the basis of the calculation for that tier. This can be
seen by noting that the basis of calculation for the first tier is 1 x 106
Ibs/day and the threshold level that would trigger the next tier is set at
1.2 x 106 Ibs/day or 20 percent higher. Similarly, the second and third tiers
have applicable production ranges of 14 percent and 11 percent, respectively.
This is consistent with the general rule (mentioned earlier) that a 10 to 15
percent change in average production rate is within the range of normal
variability while a 20 percent or greater change should warrant alternate
limits.
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CHAPTER 7 EFFLUENT LIMITATIONS
The production range for each tier must be specified in the permit and
the industrial user must be required to report the measurements or estimates
of the actual production rate which prevailed during the reporting period.
The anticipated production rate for the next reporting period should also be
reported.
For this type of permit, a special notification condition should be
included in the permit which requires the industrial user to notify the
Control Authority within 30 days prior to a change in production.
A tiered permit requires an increased technical and a
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CHAPTER 7 EFFLUENT LIMITATIONS
TABLE 7-1. EXAMPLES OF SELECTING POLLUTANTS FOR REGULATION
EXAMPLE 1. SELECTION OF CONVENTIONAL POLLUTANTS FOR REGULATION
The operator at the Cleanwater POTV noticed that periodically the influent
to his plant vas milky white. He collected an influent sample and noted that
the milky color vas due to very fine particles in the waste which did not
settle readily but produced a high total suspended solids (TSS) value. As a
result, the plant violated its NPDES TSS limit. The operator traced the milky
white discharge to ABC Company. After reviewing data indicating extremely
high TSS concentrations from ABC Company's discharge, the permit writer
included a TSS limit in the ABC Company's permit to reduce the TSS load to the
POTV and thus prevent pass through.
EXAMPLE 2. SELECTION OF TOIIC ORGANIC POLLUTANTS FOR REGULATION
In reviewing the discharge data for the Double D Company, the permit writer
noticed that the discharge contained 106 mg/1 of 2,4,6-trichlorophenol and 5.3
mg/1 of pentachlorophenol. At this point, the permit writer was faced with a
problem. The POTVs NPDES permit did not contain limits for these pollutants
and no data were available on the levels of these pollutants in the POTV's
effluent, influent, or sludge. Since the permit writer did not know the
concentrations of either pollutant at the treatment plant, he decided to have
the POTV analyze its influent, effluent, and sludge for the organic priority
pollutants. The resulting data indicated concentrations of 0.580 mg/1 and
0.060 mg/1 of 2,4,6-trichlorophenol and pentachlorophenol, respectively, in
the treatment plant's influent. Sludge and effluent data indicated the
presence of both pollutants, with pentachlorophenol present in the effluent at
levels exceeding State ambient water quality criteria. Based on concern for
the water quality of the receiving stream and based on broad authority in the
local ordinance for the POTV to regulate industrial users so as to prevent
harm to the environment, the permit writer established local limits for both
compounds and include the requirements in the Double D Company's permit.
EXAMPLE 3. SELECTION OF POLLUTANTS BASED ON POTENTIAL HEALTH RISKS
The Anytown POTV superintendent had not noticed any apparent inhibition of
his treatment system but plant operators complained periodically about strong
organic smells in the wet well and at Triple T Company's sampling manhole. In
reviewing the discharge data from the Triple T Company, he noticed that the
company discharged 1,2 dichloroethane. Additional sampling of the gases in
the collection system revealed concentrations of 1,2 dichloroethane that
exceeded the Occupational Safety and Health Administration's Immediately
Dangerous to Life and Health (IDLH) levels. Due to his concerns about the
health and safety of the workers at the POTV, the superintendent decided to
establish a local limit and regulate 1,2 dichloroethane in the Triple T
Company's permit.
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CHAPTER 7 EFFLUENT LIMITATIONS
TABLE 7-2. NATIONAL PROHIBITED DISCHARGES
General Prohibitions
A User may not introduce into a POTV any pollutants which cause Pass Through
or Interference [40 CFR 403.5(a)(1)].
Specific Prohibitions
The following pollutants shall not be introduced into a PO2V:
o Pollutants which create a fire or explosion hazard in the POTV [40
CFR 403.5(b)(l)]
o Pollutants which will cause corrosive structural damage to the POTV,
but in no case discharges with pH lover than 5.0, unless the POTV is
specifically designed to accommodate such discharges [40 CFR
403.5(b)(2)]
o Solid or viscous pollutants in amounts which vill cause
obstruction to the flow in the POTV resulting in interference [40 CFR
403.5(b)(3)]
o Any pollutant, including oxygen demanding pollutants (BOD, etc.)
released in a discharge at a flow rate and/or pollitant concentration
which will cause interference with the POTV [40 CFK 403.5(b)(4)]
o Heat in amounts which will inhibit biological activity in the POTV
resulting in interference, but in no case heat in such quantities
that the temperature at the POTV Treatment Plant exceeds 40 degrees C
(104 degrees F) unless the Approval Authority, upon request of the
POTV, approves alternate temperature limits [40 CFR 403.5(b)(5)].
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CHAPTER 7 EFFLUENT LIMITATIONS
TABLE 7-3. EXAMPLE OF INCORPORATING PROHIBITED DISCHARGES IN PERMIT
VERBATIM IN STANDARD CONDITIONS SECTION OF PERMIT
Part IV - STANDARD CONDITIONS
1. The permittee shall comply with all the general prohibited discharge
standards in Section 5 of the City Ordinance. Namely, the industrial
user shall not discharge wastevater to the sever system:
o Having a temperature which causes the influent at the POTW to exceed
104 degrees F.
o Containing more than 100 mg/1 of fats, oils, and grease.
o Containing any liquids, solids, or gases which by reason of their
nature or quantity are, or may be, sufficient either alone or by
interaction with other substances to cause fire or explosion or be
injurious in any other way to the sewer system or to the operation of
the sewer system. At no time shall two successive readings on an
explosion hazard meter, at the point of discharge into the system (or
at any point in the system) be more than five percent (5%) nor any
single reading over ten percent (10%) of the Lower Explosive Limit
(LEL) of the meter. Prohibited materials include, but are not limited
to, gasoline, kerosene, naphtha, benzene, toluene, xylene, ethers,
alcohols, ketones, aldehydes, peroxides, chlorates, perchlorates,
bromates, carbides, hydrides, and sulfides.
o Containing any solid or viscous substances which may cause
obstruction to the flow in a sewer or other interference with the
operation of the sewer system such as, but not limited to: grease,
garbage with particles greater than one-half inch (1/2") in any
dimension, animal guts or tissues, paunch manure, bones, hair, hides
or fleshings, entrails, whole blood, feathers, ashes, cinders, sand,
spent lime, stone or marble dust, metal, glass, straw, shavings,
grass clippings, rags, spent grains, spent hops, waste paper, wood,
plastics, gas, tar, asphalt residues, residues from refining or
processing of fuel or lubricating oil, mud, or glass grinding or
polishing wastes.
o Having a pH lower than 5.0 or higher than 11.0, or having any other
corrosive property capable of causing damage or hazards to
structures, equipment, or personnel of the sewer system.
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CHAPTER 7 EFFLUENT LIMITATIONS
TABLE 7-3. EXAMPLE OF INCORPORATING PROHIBITED DISCHARGES IN PERMIT
(Continued)
o Containing toxic or poisonous substances in sufficient quantity to
injure or interfere with any wastewater treatment process or to
constitute hazards to humans or animals or to create any hazard in
waters which receive treated effluent from the sever system treatment
plant.
o Containing any substance which may affect the City's wastewater
treatment facility's effluent and cause violatior. of the NPDES permit
requirements or the receiving water quality stancards.
o Containing any substance which would cause the City's wastewater
treatment facility to be in noncompliance with sludge use, recycle,
or disposal criteria pursuant to guidelines or regulations developed
under Section 405 of the Federal Act, the Clean Air Act, the Resource
Conservation and Recovery Act Subtitle C, the Toxic Substance Control
Act, the Marine Protection Research Sanctuary Act, the Safe Drinking
Water Act Subtitle C, or other state law or regulations for sludge
management and disposal.
o Containing any pollutant, including BOD pollutants, released at a
flow rate and/or pollutant concentration which wculd cause
interference with the sewer system treatment plar.t.
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CHAPTER 7 EFFLUENT LIMITATIONS
TABLE 7-4. FORMULAS FOR CALCULATING EQUIVALENT LIMITS FROM PRODUCTION-BASED
STANDARDS
EQUIV. MASS LIMIT CATEGORICAL STANDARD LONG TERM AVERAGE DAILY
(IN LB/DAY) • (IN LB/DAY/1,000 LBS) * PRODUCTION RATE (IN 1,000 LBS)
EQUIV. CONCENTRATION [CATEGORICAL STANDARD LONG TERM AVERAGE DAILY
(IN MG/L) • (IN LB/DAY/1,000 LBS) x PRODUCTION RATE
(IN 1,000 LBS)]
LONG TERM AVERAGE PROCESS EFFLUENT FLOW
(IN MGD) X 8.34*
* CONVERTS MG/L TO LBS/MILLION GALLONS
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CHAPTER 7 EFFLUENT LIMITATIONS
TABLE 7-5. EXAMPLE OF INCORPORATING PRODUCTION-BASED STANDARDS
AS EQUIVALENT MASS LIMITS IN A PERMIT
Pare I. Effluent Limitations
A. Description of Discharfes
Pipe Description
01 Discharge of wastewater generated by all regulated battery manu-
facturing processes at the facility
B. Effluent Limits
Effective no later than March 9, 1987, and lasting unr.il the expiration
date of this permit, the permittee is authorized to discharge vastevater
from pipe 01. This discharge shall be limited as specified below:
Effluent Limitation (Ibs/day)
Limited Daily Monthly
Parameter Maximum Average
Total Copper 0.021 0.011
Total Lead 0.005 0.002
C. Notification of Production Changes
The production rate that vas used to calculate the equivalent mass per
day limits in this permit is:
o 0.1 million pounds of lead used per day
The permittee must report a reasonable measure of its long-term
production rate in each periodic compliance report submitted to the
City, In addition, the permittee must notify the City immediately of a
significant change in this production rate which would cause the
equivalent mass limits to have to be revised. A significant change is
an increase or decrease of 20 percent from the rate stated above.
D. Modification
This permit may be reopened and the effluent limits modified based upon
any changed production rate reported in C above.
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CHAPTER 7
EFFLUENT LIMITATIONS
TABLE 7-6. EXAMPLE OF FACT SHEET DOCUMENTING DETERMINING THE MOST STRINGENT
DAILY MAXIMUM EFFLUENT LIMITS
Daily Monthly Daily
Parameter PSES PSES CWF
Cadmium 0.69 0.26 0.46
Chromium (Hex)
Chromium (Total) 2.77 1.71 1.85
Copper 3.38 2.07 2.26
Cyanide 1.20 0.65 *
Lead 0.69 0.43 0.46
Manganese
Mercury
Nickel 3.98 2.38 2.66
Silver 0.43 0.24 0.28
Zinc 2.61 1.48 1.74
TTO 2.13 -- 1.42
Local
Monthly Daily
CWF Limit
0.17
1.14
1.38
*
0.29
1.59
0.16
0.99
0.1
0.1
1.0
5.0
2.0
0.1
1.0
0.005
2.0
0.1
5.0
1.0
Daily Monthly
Final Final
Limit
0.1
0.1
1.0
2.26
1.20 *
0.1
1.0
0.005
2.0
.1
74
0.
1
1.38
0.65 *
1.59
0.99
1.0
Note: All concentrations are in mg/1 unless otherwise noted.
Key:
PSES
CWF
Local Limit
Final Limit
- Pretreatment Standards for Existing Sources, metal finishing
category [40 CFR Part 433.15(a)]
- Alternative metal finishing standards after use of combined
wastestream formula
• Maximum pollutant concentrations established by the Control
Authority
• Final limits based on most stringent of local, State, and
Federal standards
* Cyanide limits shall apply to the segregated cyanide wastestream of the
cyanide destruct treatment process.
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7-19
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CHAPTER 8
MONITORING AND REPORTING REQUIREMENTS
Once an industrial user's effluent limits are developed, the permit
writer's next step is to establish monitoring and reporting requirements.
Requiring the industrial user to routinely self-monitor and to report the
results of such monitoring enables the Control Authority to keep informed
about characteristics of the user's discharge and compliance status so that
any necessary permit modifications or enforcement actions can be initiated.
Periodic self-monitoring also serves as a reminder to the industrial user that
compliance with the effluent limits is its responsibility. Pretreatment
facilities do not run themselves; if an industrial user is not monitoring,
then it does not know how well the pretreatment controls are working. The
Control Authority should be aware of and concerned with the potential problems
of self-monitoring, such as improper sample collection, poor analytical
techniques, and falsification of records. To prevent or minimize these
problems, the permit writer should clearly detail monitoring and reporting
requirements in the permit.
The permit's monitoring and reporting section should contain specific
requirements for each of the following items:
• Sampling location
• Pollutants to be monitored
• Sample collection method
• Monitoring frequencies
• Analytical methods
• Reporting requirements.
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CHAPTER 8 MONITORING AND REPORTING REQUIREMENTS
Several factors should be considered in determining the specific requirements
to be imposed. Basic factors which affect sampling location, sampling method,
sampling frequency, and reporting frequency are:
• Applicability of categorical pretreatment standard;;
• Effluent and process variability
• Flow and/or pollutant loading
• Type of pollutant.
These factors must be carefully considered by the permit writer, as any error
can lead to inaccurate compliance determination or misapplication of Federal
or local requirements. In particular, several categorical pretreatment
standards contain special monitoring requirements for specific regulated
pollutants (See Table 8-1, page 8-15).
8.1 SAMPLING LOCATIONS
Selection of the appropriate sampling point(s) is critical in determining
compliance with effluent limits. In determining the appropriate sampling
locations, the following rules should be applied:
• Sampling location(s) must coincide with the point(s) at which the
effluent limits apply
• Sampling location(s) must produce a sample representative of the
nature and volume of the industrial user's effluent
• Sampling locations must be safe, convenient, and accessible to
industrial user and Control Authority personnel.
If there is no ready access to a representative sampling point, the Control
Authority should require the permittee to provide such access including, if
necessary, installation of sampling manholes. The sampling location(s) chosen
should also allow the measurement or estimation of volume of wastewater flow.
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CHAPTER 8 MONITORING AND REPORTING REQUIREMENTS
Because the Control Authority's local limits generally apply to the
entire discharge from an industrial user, a sewer manhole located at the
connection between the industrial facility's sewer pipe and the Control
Authority's sewer pipe is usually selected as the sampling point. Such a
sampling manhole allows easy access by the Control Authority and usually
facilitates the collection of a sample of the user's total discharge.
However, in some cases, this manhole may contain wastewater discharges from
upstream domestic or industrial users connected to the Control Authority's
sewer pipe, making it impossible to obtain a sample of any one industrial
user's discharge. In this instance the Control Authority should identify a
more appropriate sampling location.
One additional important factor must be considered when establishing an
appropriate sampling location at an industrial facility subject to categorical
pretreatment standards. Categorical pretreatment standards are numerical
limits that apply to specific regulated wastestreams before these wastestreams
are mixed or diluted with other flows. Because of this factor, the sampling
point(s) chosen must provide representative samples of these regulated
wastestreams and should be located after pretreatment of these wastestrearas if
such treatment is utilized. If other regulated, unregulated, or dilution
wastestreams are combined prior to the pretreatment facility, and sampling of
the effluent occurs after pretreatment, the combined wastestream formula must
be used to adjust the categorical pretreatment standards to account for other
regulated, unregulated, and dilution wastestreams. However, if regulated and
unregulated or dilution wastestreams are combined after treatment but prior to
the facility's monitoring point, a different formula must be used.
EPA has clarified, in the preamble to the October 17, 1988 revisions to
the General Pretreatment Regulations [53 FR 40562], that a flow weighted
averaging formula or a more stringent calculation must be used to adjust
applicable categorical pretreatment standards where unregulated and dilution
flows combine after pretreatment but prior to sampling. (See also the
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CHAPTER 8 MONITORING AND REPORTING REQUIREMENTS
preamble to the proposed rule June 12, 1986 (51 FR 21454].) For an
explanation of the use of the combined wastestream formula and the flow
weighted averaging formula, the permit writer should refer to EPA's Guidance
Manual for the Use of Production-Based Pretreatment Standards and the Combined
Wastestream Formula.
Each of the above factors must be considered by the permit writer to
identify the most practical and most representative sampling location(s).
Once the sampling locations are selected, the permit writer must clearly
specify these sampling locations in the permit. The permit writer should not
assume that the sampling locations are known by other Control Authority staff
or by the permittee. Changes in either Control Authority or industrial
personnel can result in loss of knowledge of the exact sampling location
unless the sampling locations are clearly defined in the permit. Examples in
Table 8-2 (page 8-18) illustrates three ways of specifying sampling locations
by using brief narrative descriptions, designation by numbers, and a diagram.
If one or more sampling points are identified, each location and the limits
that apply should be clearly specified in the industrial user's permit.
8.2 POLLUTANTS TO BE MONITORED
The POTtf should always require industrial user self-monitoring for all
pollutants limited by specific numerical values in the industrial user permit.
Industrial users subject to categorical pretreatment standards are required to
monitor and report the analytical results for all regulated pollutants in
order to comply with the reporting requirements of 40 CFR 403.12(e) of the
General Pretreatment Regulations. Some categorical pretreatment standards
allow alternatives to sampling specific regulated pollutants. The permit
writer needs to review the specific monitoring and reporting requirements con-
tained in the applicable categorical pretreatment regulations. In addition,
EPA's Guidance Manual for Implementing Total Toxic Organics (TTCO Pretreatment
Standards contains guidance on the total toxic organic monitoring
alternatives.
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CHAPTER 8 MONITORING AND REPORTING REQUIREMENTS
The Control Authority need not limit the pollutants to be sampled to only
those subject to effluent limits. It may require the industrial user to
monitor for other pollutants of potential concern. In this case, a
monitoring-only requirement may be included as a special condition of the
permit (discussed in more detail in Chapter 10). The permit writer should
also require the industrial user to monitor flow (even if flow is not
limited). A flow monitoring requirement is necessary where mass limits are
imposed in order to determine compliance with mass limits. A flow monitoring
requirement can also serve as a reminder to collect flow data for those
categorical industrial users who are required to report daily maximum and
average flows in semiannual reports [40 CFR 403.12(g)].
8.3 SAMPLE TYPE
The permit should specify the sample collection method or type of
sample(s) for each pollutant to be monitored. In general, two types of
samples may be taken: grab or composite. The permit writer should review the
sampling objectives and the advantages and disadvantages of each sample type.
However, whenever possible, flow proportional composite samples should be
required except for pollutants which require grab sampling techniques.
Since there are two types of composite samples, time proportional and
flow proportional, the permit writer should clearly specify or define the
sample type. The sample period should also be specified. Generally, the
sample period is 24 hours but if the industrial user's discharge is 8 hours in
duration each day the permit writer could specify that the composite sample be
collected over the 8 hours of discharge. The number of grab samples should be
specified (e.g., a minimum of four per day at equal time intervals or a grab
sample taken after a specified volume of wastewater has been discharged).
8.3.1. Grab Sample
A grab sample is a single discreet sample collected over a time period
not exceeding 15 minutes, without any regard to the wastestream's flow. Grab
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CHAPTER 8 MONITORING AND REPORTING REQUIREMENTS
samples may be used when both wastewater flow and pollutant concentrations or
loadings are constant over time. Grab samples may also be used for batch
discharges, such as a contaminated process tank that is periodically
discharged. However, a batch discharge must be homogeneous in order to be
accurately represented by a grab sample.
Grab samples are useful in characterizing an industrial user's fluctua-
tions or extremes in wastewater flow and quality (i.e., changes in pollutant
concentrations or loadings) and, therefore, are useful in identifying slug
loads. These samples are also appropriate to determine compliance with
"instantaneous" effluent limits where a composite sample could mask extreme
conditions in the wastewater. The pH parameter can illustrate this concept
clearly: a composite sample could exhibit a neutral pH, while individual grab
samples could exhibit a wide range of pH.
Grab samples should be used when storing or compositing of a sample will
alter the concentration or characteristics of pollutants being measured.
Parameters which necessitate grab sampling techniques include pH, oil and
grease, temperature, total phenol, cyanide, sulfides, anc; some volatile
organics (purgeable halocarbons, purgeable aromatics, acrolein, and
acrylonitrile) .
8.3.2. Composite Sample
Composite samples are used to measure the average amount of pollutants
discharged by an industrial user during the composite period. Composite
samples are preferred when evaluating compliance with 24-hour or daily average;
concentration limits and mass limits. Samples may be obtained as either
time-proportional or flow-proportional.
Time-proportional composite samples are generally collected under
conditions of constant or slightly fluctuating effluent ::lows. For a non-
homogeneous batch discharge, wastes are stratified in a -;ank and the
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CHAPTER 8 MONITORING AND REPORTING REQUIREMENTS
effluent's quality will vary over the period of batch discharge. For this
situation, a time-proportional composite sample collected over the period of
discharge would be most appropriate. Flow-proportional composite samples are
collected when both an industrial user's effluent flow and pollutant
concentrations or loadings exhibit irregular changes. For pollutants for
which grab samples are not necessitated, flow-proportional composite samples
should always be used to determine compliance with categorical pretreatment
standards. However, the permit writer may specify time-proportional composite
samples or grab samples where flow-proportional samples are not feasible and
the use of these other sampling techniques will provide a representative
sample.
8.4 MONITORING FREQUENCIES
The Control Authority has considerable discretion in establishing
monitoring frequencies. However, Federal regulations [40 CFR 403.12(e)(1)]
specify a minimum reporting frequency of twice per year to demonstrate
"continued compliance" with categorical pretreatment standards. Therefore,
monitoring frequencies must be no less than twice per year [see 40 CFR
403.12(g)]. In addition, the Control Authority should also require twice
annual monitoring and reporting from all other significant industrial users
[see proposed rule at 53 FR 47632]. Furthermore, monitoring must be conducted
to satisfy baseline monitoring report, 90-day compliance report and repeat
noncompliance monitoring reporting requirements pursuant to 40 CFR 403.12. In
establishing monitoring frequencies, the permit writer's primary task is to
achieve a reasonable balance between the need for sufficient representative
data to assess compliance and the expense or burden of obtaining such data.
Each of the following factors should be considered by the Control Authority as
it develops both the industrial user self-monitoring requirements and its own
compliance monitoring program:
• Frequency necessary to obtain data representative of the nature and
volume of the industrial user's wastewaters
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CHAPTER 8 MONITORING AND REPORTING REQUIREMENTS
• Amount of historical data available to characterize the industry's
discharge (industries with no historical data should be sampled more
frequently)
• Actual (or potential) impact of the industrial user's wastes on the
operation of the Control Authority's treatment plant, receiving
stream, and sludge disposal practices
• Types of pollutants contained in a facility's wastewaters and the
concentrations or loadings discharged
• Regulatory requirements of any existing industrial user permits, local
sewer use ordinances, POTW policy statements, or Federal regulations
and policies
• Any seasonal variations experienced in the industrial user's
manufacturing operations and wastewater flow
• Length of the industrial user's operating day or tne number of shifts
worked per day
• Industrial user's history of upsets or accidental spills or lack of
spill prevention plans for raw materials, process rfastewaters, or
chemicals stored onsite
• Reliability of the industrial user's pretreatment facilities
• Any scheduled discharges of unusual or extraordinary strength and/or
volume (i.e., batch discharges of process tanks or routine clean-up
periods scheduled each day, week, or month)
• Compliance (or noncompliance) history of the industrial user
• Expense of monitoring imposed on both the industrial user and the
Control Authority and the resources (labor and equipment) available.
The Control Authority may wish to develop a base level monitoring
frequency to be imposed on all industrial users and use the above factors to
increase or decrease the monitoring frequencies on a case by-case basis from
the established base monitoring frequency. EPA's Pretreat:ment Compliance
Monitoring and Enforcement Guidance contains recommended frequencies based on
five flow categories using flow as an indication of potential impact on the
treatment plant and ability of user to bear the monitoring cost (see Table
8-3, page 8-19). The Control Authority could also adopt i:he monitoring
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CHAPTER 8 MONITORING AND REPORTING REQUIREMENTS
frequency EPA used In developing categorical pretreatment standards
(generally, this frequency Is 10 times per nonth for Inorganics).
For pollutants not reasonably expected to be present, the permit writer
may decide to decrease monitoring frequencies to a minimum frequency of twice
per year. For example, the permit for a metal finisher that does not use
cadmium or cyanide and has never detected these pollutants In Its effluent may
provide for the minimum monitoring frequency of twice per year for those
pollutants. Such a condition provides a means of verifying the absence of
those pollutants and satisfies the regulatory requirement.
For operations that are seasonal, the permit writer may want to require
increased monitoring during peak operations. For batch discharges, monitoring
frequencies could be geared to the frequency of discharge. For example, the
permit writer could require a small electroplater which batch discharges once
a month to monitor once a month when the batch discharge occurs.
Table 8-4 (page 8-20) illustrates how monitoring frequencies can be
specified In the permit. Additional special monitoring requirements may be
placed with the monitoring requirements section of the permit or in the
special conditions section of the permit discussed in Chapter 10.
8.5 ANALYTICAL METHODS
The General Pretreatment Regulations [40 CFR 403.12] require that all
analyses to determine compliance with categorical pretreatment standards be
performed in accordance with 40 CFR Part 136, "Guidelines Establishing Test
Procedures for the Analysis of Pollutants under the Clean Water Act" and
amendments, or with any other test procedures approved by EPA. Analytical
techniques for additional pollutants not contained in Part 136 must be
performed by using validated analytical methods approved by EPA [40 CFR
403.12(g)(4)]. Requiring everyone to use these EPA-approved test
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CHAPTER 8 KONITORING AND REPORTING REQUIREMENTS
methods ensures that analytical data are obtained in a uniform and consistent
manner. These EPA-approved test methods should also be used to determine
compliance with State standards and local limits. This requirement to use
EPA-approved analytical methods should be specified in either the monitoring
and reporting section or the standard conditions section of the permit as
illustrated in Table 8-4 (page 8-20). The pernit writer may want to specify
the exact analytical method(s) to be used.
8.6 REPORTING REQUIREMENTS
Along with establishing self-monitoring requirements, the permit writer
needs to specify reporting requirements in the permit. Such reporting is
often overlooked by many Control Authorities because it is informally
understood or agreed upon between the Control Authority and the industrial
user. In cases where the Control Authority conducts all the monitoring or the
Control Authority analyzes the industrial user's self-collected samples, the
Control Authority has direct access to the analytical results and, thus, finds
no need for a monitoring report to be submitted by the user. If the Control
Authority has chosen this alternative, and Is collecting all of the data that
would ordinarily be required from the industrial user (e.g., flow data,
production data, etc.) and at a frequency which would be opected of the user
if it were self monitoring, then the Control Authority may waive the
requirement that the industrial user report continuing compliance [40 CFR
403.12(g)].
The Federal reporting requirements contained in 40 CFR 403.12 consist of
the following reports:
• Baseline monitoring report [40 CFR 403.12(b)]
• Reports on progress in meeting compliance schedules [40 CFR
403.12(c)]
• Report on final compliance (90-Day Report) [40 CFR 403.12(d)]
• Periodic reports on continued compliance [40 CFR 403.12(e)]
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CHAPTER 8 MONITORING AND REPORTING REQUIREMENTS
• Notice of slug loading [40 CFR 403.12(f)]
• Reports required for noncategorical industries [40 CFR 403.12(h)]
• Notice by the Industrial user of any violation within 24 hours of
becoming aware of such violation and submission of results of repeat
sampling within 30 days of said notice of violation [40 CFR 403.12(g)]
• Notice of anticipated substantial changes In the volume or character
of pollutants discharged [40 CFR 403.12(j)].
These reporting requirements are described In more detail in Table 8-5 (page
8-22). The permit writer should place these reporting requirements, where
appropriate, In the permit together with additional reporting he/she may
require pursuant to his/her local authority. Some examples of actual permit
reporting conditions are provided In Table 8-6 (page 8-24).
The Control Authority must also impose reporting requirements on
noncategorical Industrial users. The October 17, 1988, revisions to the
General Pretreatment Regulations state that the Control Authority shall
require appropriate reporting from those industrial users with discharges that
are not subject to categorical pretreatment standards [40 CFR 403.12(h)].
When drafting an industrial user's reporting requirements, the permit
writer should ensure that the permit contains the following information in
sufficient descriptive detail:
• What types of information are to be contained in each report (e.g.,
analytical data, flow data, or production data)
• When each report is to be submitted to the Control Authority
(specifying the dates and frequency for submission)
• Who Is responsible for signing the reports (e.g., an authorized
corporate official)
• Where the reports are to be sent, including the Control Authority's
address and, if appropriate, the name of the person responsible for
receipt of each report.
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CHAPTER 8 MONITORING AND REPORTING REQUIREMENTS
8.6.1. What Types of Information
Table 8-7 (page 8-27) provides the permit writer with the type of
Information recommended for the industrial user's periodic compliance reports.
These reporting requirements are generally Included in either the standard
conditions section or the reporting requirements section. Again, the format
and language for this provision and any other reporting requirements are left
to the Control Authority's discretion.
Further, if an industrial user is subject to a compliance schedule
contained in the permit, the permit writer should require t:he submission of
periodic reports on the progress of compliance schedule activities. These
reports should be submitted by the industrial user no later than 1A days after
each milestone date and should describe the progress made, any delays
experienced and the reasons for those delays, and steps taken to return to the
schedule established.
Finally, the permit writer must Impose any special reporting requirements
on categorical industrial users required by the specific categorical
pretreatment regulations. For example:
• Submission and implementation of a toxic organic management plan and
semiannual certification of compliance with TTO standards (metal
finishing, electroplating, and electrical and electronic components)
• Certification that chlorophenolic-containlng blocidfs are not used
(pulp, paper, and paperboard).
8.6.2. When Report is to be Submitted
The permit writer must require industrial users subject to categorical
pretreatment standards to submit reports at a minimum of twice per year unless
the Control Authority has elected to collect all of the information which
would otherwise be supplied by the industrial user [40 CFR 403.12(e) and (g)].
More frequent reporting can be required. In fact, it is a good policy to
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CHAPTER 8 MONITORING AND REPORTING REQUIREMENTS
require that reports be submitted soon after the industrial user self-
monitors. Whenever the industrial user samples in accordance with 40 CFR 136,
or EPA approved analytical methods, it must notify the Control Authority
within 24 hours of becoming aware of the violation and must resample within 30
days to ensure that the violation is not continuing [40 CFR 403.12(g)(2) and
53 FR 40562]. Frequency for submission of self-monitoring reports should be
established by the Control Authority based on the need to evaluate an
industrial user's compliance status and such factors as:
• Industrial user's size in terms of significance of its flow to the
POTW's treatment plant
• Nature of the industrial user's discharge (i.e., the quantity and
quality of the pollutants discharged)
• Industrial user's compliance history
• Industrial user's current self-monitoring frequency.
8.6.3. Who Signs Reports
The permit should contain a provision that requires reports to be signed.
Signatories must be of sufficient stature (e.g., a corporate officer) so as to
enable the Control Authority to hold the facility legally responsible for the
representations made in the compliance reports. EPA has established signature
requirements for reports by categorical industries [40 CFR 403.12(1)] as
follows:
(a) By a responsible corporate officer, if the Industrial User submitting the
reports is a corporation. For the purpose of this paragraph, a
responsible corporate officer means:
(i) a president, secretary, treasurer, or vice-president of the
corporation in charge of a principal business function, or any
other person who performs similar policy- or decision-making
functions for the corporation, or;
(ii) the manager of one or more manufacturing, production, or operation
facilities employing more than 250 persons or having gross annual
sales or expenditures exceeding $25 million (in second-quarter 1980
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CHAPTER 8 MONITORING AND REPORTING REQUIREMENTS
dollars), if authority to sign documents has been assigned or
delegated to the manager in accordance with corporate procedures.
(b) By a general partner or proprietor if the Industrial User submitting the
reports is a partnership or sole proprietorship respectively.
(c) The principal executive officer or director having responsibility for the
overall operation of the discharging facility if the Industrial User
submitting the reports is a Federal, State, or local governmental entity,
or their agents.
(d) By a duly authorized representative of the individual designated in
paragraph (a), (b) , or (c) of this section if:
(i) the authorization is made in writing by the individual described in
paragraph (a), (b), or (c);
(ii) the authorization specifies either an individual or a position
having responsibility for the overall operation of the facility
from which the Industrial Discharge originates, such as the
position of plant manager, operator of a well, DT a well field
superintendent, or a position of equivalent responsibility, or
having overall responsibility for environmental matters for the
company; and
(iii) the written authorization is submitted to the Control Authority.
(e) If an authorization under paragraph (d) of this sectian is no longer
accurate because a different Individual or position has responsibility
for the overall operation of the facility, or overall responsibility for
the environmental matters for the company, a new authorization satisfying
the requirements of paragraph (d) of this section must be submitted to
the Control Authority prior to or together with any reports to be signed
by an authorized representative.
8.6.A. Where Reports Are to be Sent
The reporting requirements section of the permit should also clearly
identify where the industrial user should submit all required reports by
specifying a Control Authority contact name and address. An example of the
format and language to require the submission of monitoring reports is
contained in Section I of Table 8-6 (page 8-26) .
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CHAPTER 8 MONITORING AND REPORTING REQUIREMENTS
TABLE 8-1. SPECIAL MONITORING AND/OR REPORTING REQUIREMENTS FOR
SPECIFIC CATEGORICAL PRETREATMENT STANDARDS
Aluminum Forming 140 CFR Part 4671:
Copper Forming (40 CFR Part 468]: and
Metal Holding and Casting 140 CFR Part 4641
• Hay as an alternative to monitoring for TTO meet the alternative oil
and grease standard and must monitor for oil and grease.
Coil Coating [40 CFR Part 4651
• May be exempted from cyanide monitoring if:
The first cyanide sample collected during the calendar year is less
than 0.07 mg/1 of cyanide; and,
The owner or operator certifies in writing that no cyanide is used.
• For subcategory D (canmaking), may as an alternative to monitoring for
TTO meet the alternative oil and grease standard and must monitor for
oil and grease using analytical method outlined in 40 CFR 465.03(c).
Electrical and Electronic Components [40 CFR Part 4691: and
Electroplating !40 CFR Part 4131
• Hay in lieu of routine monitoring for TTO certify that toxic organics
are not used in the facility or are controlled through a Toxic
Organics Management Plan (TOMP). The TOMP must be submitted to the
Control Authority and a certification statement must be submitted at
least twice per year.
Leather Tanning [40 CFR Part 4251
• Must use the special analytical method specified for sulfide in 40 CFR
425.03 for determination of sulfide in alkaline wastevaters.
• May be exempt from sulfide standard if Control Authority submits a
written certification to EPA that the sulfide does not interfere with
the treatment works.
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CHAPTER 8 MONITORING AND REPORTING REQUIREMENTS
TABLE 8-1. SPECIAL MONITORING AND/OR REPORTING REQUIREMENTS FOR
SPECIFIC CATEGORICAL PRETREATMENT STANDARDS
(Continued)
Metal Finishing [40 CFR Part 433]
0 Must monitor for compliance with the cyanide limit after cyanide
treatment and before dilution with other was test reams. If monitoring
the segregated cyanide wastestream cannot be done, ~.he samples of rhe
facility's final effluent may be taken, if the applicable cyanide
limitations are adjusted based on the dilution ratio of the cyanide
wastestream flow to the facility's effluent flow.
0 Hay in lieu of routine monitoring for TTO certify that toxic organic
are not used in the facility or are controlled through a Toxic
Organics Management Plan (TOMP). The TOMP must be submitted to the
Control Authority and a certification statement must be submitted at
least twice per year.
Nonferrous Metals Manufacturing 140 CFR Part 421J
• For Subpart C (Secondary Aluminum Smelting), must monitor for
compliance with the total phenolics limit for Delacc,uering Vet Air
Pollution control wastewater at the source of the phenolic
wastestream. At the source is defined as at or before the mixing of
the phenolic wastestream with other process or nonpiocess wastewaters.
If monitoring of the segregated phenolic wastestrean- cannot be done,
the samples of the facility's final effluent may be taken if the total
phenolics limit is adjusted based on the dilution ratio of the
phenolic wastestream flow to the facility's effluent flow.
• For Subpart C (Secondary Aluminum Smelting), must use 4-AAP analytical
method for total phenolics.
Petroleum Refining [40 CFR Part 4191
• The petroleum refining categorical pretreatment standards "apply to
the total refinery flow contribution to the POTU." Therefore, when
monitoring for compliance with these standards, dilution was test reams
do not have to be accounted for if end-of-pipe samples are taken at a
petroleum refining facility.
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CHAPTER 8 MONITORING AND REPORTING REQUIREMENTS
TABLE 8-1. SPECIAL MONITORING AND/OR REPORTING REQUIREMENTS FOR
SPECIFIC CATEGORICAL PRETREATMENT STANDARDS
(Continued)
Pharmaceutical Manufacturing 140 CFR Part 439]
• If all cyanide-containing wastestreams are passed through a cyanide
destruction unit, must monitor for compliance with total cyanide limit:
after cyanide treatment and before dilution with other wastestreams.
If facility's final effluent discharge is monitored, the total cyanide
standard must be adjusted to account for the presence of the other
dilution wastestreams. If the facility does not treat the cyanide-
containing wastewaters, monitor for compliance at the facility's final
effluent discharge point and adjust the total cyanide standard based
on the dilution ratio of the cyanide-contaminated wastestream flow to
the total process wastewater flow. If a facility does not use or
generate cyanide, then no monitoring for compliance with total cyanide
is required provided that the Control Authority obtains a
certification from the facility that it is not using or generating
cyanide.
Porcelain Enameling [40 CFR Part 466]
• Hay be exempted from chromium monitoring if:
The first sample collected during the calendar year is less than
0.08 mg/of chromium; and,
The owner or operator certifies in writing that chromium is not
used.
Pulp. Paper. Paperboard and Builders' Paper and Board Hills f4Q CFR Parts 430
and 4311
• Hay be exempt from pentachlorophenol and trichlorophenol limits if Che
facilities certify that they do not use chlorophenolic biocides.
• For Subpart H (Groundwood-Thermo-Mechanical), may be exempt from zinc
limits if the facilities certify that they do not use zinc
hydrosulfite.
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CHAPTER 8 MONITORING AND REPORTING REQUIREMENTS
TABLE 8-2. EXAMPLES OF SPECIFYING SAMPLING LOCATIONS IN PERMITS
EXAMPLE OF SPECIFYING SAMPLING LOCATION BY NARRATIVE DESCRIPTION
Pipe OlA Ls defined as the sampling site from the industry's process
wastewater discharge downstream from the existing pretreatment clarifier.
Note that after the upgraded pretreatment system becomes operational, the
sampling site will be the first manhole downstream from the sand filters.
EXAMPLE OF MULTIPLE SAMPLING LOCATIONS SPECIFIED BY NUMBER DESIGNATION
IV. SELF-MONITORING REQUIREMENTS
A. Sample Locations
1. Discharge from the Chemistry-Fine Arts Buildirg shall be sampled
at the Manhole No. 50
2. Discharge from the Duane Physics Building shall be sampled at the
Manhole No. 22
3. Discharge from the Research Lab No. 1 shall bt sampled at the
Manhole A.
EXAMPLE OF SAMPLING LOCATION SPECIFIED BY DIAGRAM
Part I Permit No. 001
Part I. Effluent Limitations and Monitoring Requirements
A. Description of Discharges
Pipe Description
01 Discharge Pipe - Discharge of wastewater generated by all regulated
metal finishing processes at the facility. Samples shall be
collected at the point indicated on the attached diagram.
Parshall Flume
Manhole
Adjustment
Tank
Pipe 01—I
Final pH
*Sampllng Point
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CHAPTER 8 MONITORING AND REPORTING REQUIREMENTS
TABLE 8-3. RECOMMENDED INDUSTRIAL SELF-MONITORING FREQUENCIES
DURING INITIAL COMPLIANCE PERIOD
Conventional Pollutants,
Inorganic Pollutants,
Industrial Flow Cyanide, and Phenol GC or GC/HS OrganLcs
(gpd)
0- 10,000 I/month 2/year
10,001- 50,000 2/month 4/year
50,001-100,000 I/week I/month
100,001-240,000 2/veek 2/month
>240,000 3/week 4/month
[Note: Industrial users subject to TTO standards in the Electrical and
Electronic Components, Electroplating, and Metal finishing categories may
elect to implement a toxic organic management plan and periodic certification
statements in lieu of performing TTO analyses. Industrial users subject to
TTO standards in the Aluminum Forming, Copper Forming, Coil Coating
(Canmaking), and Metal Molding and Casting categories may monitor for oil and
grease as an alternative to TTO monitoring.]
Excerpt from: EPA's Pretreatment Compliance Monitoring and Enforcement
Guidance
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CHAPTER 8
KONITORING AND REPORTING REQUIREMENTS
TABLE 8-4. EXAMPLE OF SETTING MONITORING REQUIREMENTS IN PERMITS
Permit No. 1
PART 2 - HONITORING AND REPORTING REQUIREMENTS
SECTION 1 - MONITORING REQUIREMENTS
A. From the period beginning on the effective date of this permit until
(Date) , the permittee shall monitor outfall 1 for
the folloving:
Parameter
Chromium
Copper
Lead
Nickel
Silver
Zinc
Cadmium
Cyanide
(Total)
(Total)
(Total)
(Total)
(Total)
(Total)
(Total)
(Total)
Flow
Total Toxic
Organics (TTO)
Notes:
Units
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
Frequency
1/veek (I)
3/veek (1)
1/6 mo. (1)
1/6 mo.
1/6 mo.
I/too.
1/mo.
(1)
(1)
(2)
(3)
Sample Type
(5)
(5)
(5)
(5)
(5)
(5)
1/6 mo. (4)
gal/day
Daily
Standard Units Continuous
mg/1
1/6 mo.
4 grab samples at
equal intervals
(but at lease 1
hour apart) over
period of
discharge.
Recorded from
elapsed time
meter on the sump
pump prior
to treatment
system.
Recorded
(6)
(1) The sample shall be taken on a day when these substances are likely to be
present in their maximum concentration, including spent chromating tank
and other periodic discharges to the sanitary sewer.
(2) The sample shall be taken on a day when zinc plating wastewaters are
discharged to the sanitary sewer and zinc is expected to be present in its
maximum concentration.
9/15/89
8-20
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CHAPTER 8 MONITORING AND REPORTING REQUIREMENTS
TABLE 8-4. EXAMPLE OF SETTING MONITORING REQUIREMENTS IN PERMITS
(Continued)
(3) The sample shall be taken on a day when cadmium plating vastevaters are
discharged to the sanitary sever and cadmium is expected to be present at
its maximum concentration.
(4) Monitoring for cyanide must be conducted after the cyanide treatment unit,
before dilution with other vastestreams, and when cyanide is expected to
be present at its maximum concentration.
(5) Flow proportional composite sample over dally duration of discharge.
(6) Implementation of approved toxic organic management plan and submission of
semiannual certification statement as specified by 40 CFR 413.03 shall be
used in lieu of monitoring for TTO. The City reserves the right to
require the permittee to monitor for TTO to determine compliance with the
TTO standard at any time.
B. All samples shall be collected, preserved, and analyzed in accordance with
the procedures established in 40 CFR Part 136 and amendments.
9/15/89 8-21
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CHAPTER 6
MONITORING AND REPORTING REQUIREMENTS
TMU 8-5.
INDUSTRIAL USE* EEraTIIK ttOUl
PER 40 CfR 403.12
REQUIRED REPORT AND
CITATION
•aaeline Monitoring
(•port
(•MR) 40 CFR
403.12(b)(1-7)
REPORT DUE DATE
UltMn 180
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CHAPTER 8
MONITORING AND REPORTING REQUIREMENTS
REQUIRED REPORT AND
CITATION
Periodic Compliance
Reports
40 CFR 403.12(«)
Notice of Slug
loading
40 CFR 403.12(f>
TABLE 8-5. INDUSTRIAL USE* REPORT IK REOUIRBCTTS
Kl 40 CFR 403.12 (Continued)
REPORT DUE DATE
Every June and December after
the final compliance date (or
after commencement of a
discharge for new sources)
unless frequency is increased by
the Control Authority.
Notification of POTW immediately
after occurrence of slug load,
or any other discharge that may
cause problem to the POTU.
PURPOSE Of REPORT
To provide the Control Authority
with current information on the
discharge of pollutants to the
POTU fro* categorical industries.
To alert the POTU to the potential
hazards of the discharge.
INFORMATION REQUIRED
Nature and concentration of all
regulated pollutants
Average and KaximuB daily flows
discharged to the POTU for reporting
period
Where mass based units are used, a
erasure of the mass of pollutants
discharged
For industries subject to production-
based standards an actual average
production rate for the reporting
period
For industries subject to equivalent
•ass or concentration livits limits
pursuant to 403.6(c) a reasonable
measure of the long term production
rate
Certification of validity of
information provided
Additional information as required by
the Control Authority.
None specified in General
Pretreatment Regulations; other
Federal, State, and local regulations
•ay address reporting requirement*.
Noncomptiance
Notification
40 CFR 403.12(g)(2)
Periodic Compliance
Reports for
Noncategorical Users
40 CFR 403.12(h)
Notification of
Changed Discharge
40 CFR 403.12(j)
Notification of POTU within 24
hours of becoming aware of
violation.
To be determined by the POTU.
In advance of any substantial
changes in the volume or
character of pollutants in the
discharge.
To alert the POTU of a known
violation and potential problems
which may occur.
To provide the POTU with current
information on the discharge of
pollutants to the POTU from
industrial users not regulated by
categorical standards.
To notify the POTU of anticipated
changes in wastewater
characteristics and flow which may
•ffect the POTU.
Nature and magnitude of the
violation. Other information as
determined by the POTU.
Information as determined by the
POTU.
All anticipated changes which My
iffect the character or volume of the
discharge.
9/15/89
8-23
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CHAPTER 8 MONITORING AND REPORTING REQUIREMENTS
TABLE 8-6. EXAMPLE OF REPORTING REQUIREMENTS IN PERMIT
SECTION 2 - REPORTING REOUIREHENTS
A. Periodic Compliance Reports
1. In accordance with 40 CFR 403.12(e) and Section 99.15 of the Any town
General Ordinance, the permittee shall, after the effective date of
the permit, submit to the Director of Public Works reports indicating
the nature and concentration of pollutants in the effluent which are
limited by the standards specified in Part 1 of the permit. The
reports are due each June 30 and December 31. The report shall
include a record of daily flow during each reporting period.
2. If the permittee monitors any pollutant more frequeitly than required
by this permit, in accordance with 40 CFR Part 136 ir other EPA
approved methods, the results of such monitoring shall be submitted
with the applicable periodic report.
3. Where the permittee is subject to production-based standards, the
permittee must submit the appropriate production data as specified
below:
a) If permittee is subject to equivalent mass or concentration
limits, the production data reported must be a reasonable measure
of the permittee's long term production rate, or
b) If permittee is subject to limits expressed onlr in terms of
allowable pollutant discharge per unit of production, the
production data reported must be the actual average production
rate for the reporting period.
B. New or Changed Uastewater Reporting
1. The permittee shall notify the City 90 days prior to the introduction
of any new wastestreams or pollutants, or any substantial increase or
decrease in the volume (i.e., 20 percent or greater variance from the
monthly average flow) or characteristics of existing wastestreams
discharged to Outfall 1, described above, or any otner outfall of the
permittee.
C. Prevention of Spills and Accidental Discharges
1. The permittee shall provide to the City, under Section 99.29, plans
showing facilities and operating procedures to provide protection
against spills or accidental discharges of prohibited or regulated
9/15/89 8-24
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CHAPTER 8 MONITORING AND REPORTING REQUIREMENTS
TABLE 8-6. EXAMPLE OF REPORTING REQUIREMENTS IN PERMIT
(Continued)
materials as established by Section 99 or this permit. Such plans
shall include, but are not limited to:
a) Diking systems for containment
b) Alarm systems including test frequency of alarms
c) Employee education programs
d) Manhole sealing and replping.
2. The permittee shall provide the spill prevention and accidental
discharge control plans shoving facilities and operating procedures to
the City for review within 30 days of the effective date of the
permit.
3. Plans shall be reviewed and approved by the City prior to construction
of any facilities.
D. Accidental Discharge Reporting
1. The permittee shall notify the City immediately upon the occurrence of
an accidental discharge, slug, spill, or any bypassing or overflow of
untreated wastewater containing substances regulated by Section 99 or
this permit, to the sanitary sever from the permittee's facility. The
notification shall be as specified in Section 99.02(7)(h).
E. Upset and Bypass Reporting
1. As specified in Section 99.04(8) and (9) of the ordinance, the
permittee shall notify the City within 24 hours of the first awareness
of an upset or unanticipated bypass experienced by the permittee of
its treatment that places it in a temporary state of noncompliance
with wastewater discharge limitations contained in this permit or
other limitations specified in Section 99. The following information
must be submitted:
a) A description of discharge and cause of noncompliance/bypass,
b) The period of noncompliance including exact dates and times or, if
not corrected, the anticipated time the noncompliance/bypass is
expected to continue, and
c) The steps being taken and/or planned to reduce, eliminate, and
prevent recurrence of the noncompliance/bypass.
9/15/89 8-25
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CHAPTER 8 MONITORING AND REPORTING REQUIREMENTS
TABLE 8-6. EXAMPLE OF REPORTING REQUIREMENTS "N PERMIT
(Continued)
A written report shall be submitted within five day., containing che
above information.
2. The permittee shall submit prior notice at least 10 days in advance of
a planned bypass that may result in violation of applicable
pretreatment standards.
F. Compliance Schedule Progress Reports
1. Not later than 14 days following each compliance schedule event in
Part 3, Sections Al and A2, the permittee shall issue a progress
report to the City Indicating whether or not the increment of progress
has been met, and if not, the reason for the delay tnd the date the
permittee expects to comply with the increment of progress.
G. Noncompliance Report
1. General Noncompliance Report
If self-monitoring reveals violation of any discharge limitations
specified herein, the permittee shall notify the City within 24 hours
of becoming aware of the violation. The permittee shall also repeat
the sampling and analysis and submit the results of the repeat
analysis to the City within 30 days after becoming asare of the
violation.
H. All reports required by this section shall be signed by a principal
executive officer of the permittee of at least the level of vice president
or other duly authorized representative.
I. All reports required by this permit shall be submitted to the City at the
following address:
City of Any town Public Works Department
Attention: Pretreatment Coordinator
123 Walnut Street
Anytown, USA 11111
9/15/89 8-26
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CHAPTER 8 MONITORING AND REPORTING REQUIREMENTS
TABLE 8-7. FUNDAMENTAL ELEMENTS OF AN INDUSTRIAL USER PERIODIC
COMPLIANCE REPORT
Basic Inforafffivn - Name of industrial user, address, and reporting period.
0 Wastewater Pollutant Sfttpling and Analysis Data - Pollutants monitored,
units in which pollutant results are recorded, the date(s) samples were
taken, and the concentration of pollutants
Where the industrial user must comply with monthly average standards .
calculation of the achieved averages must be made and reported
Where mass limits are imposed, the report must include information on
the mass/day discharges along with the supporting concentration and flow
data .
• Production Data - For industrial users subject to equivalent mass or
concentration limits calculated by the Control Authority, the report must
contain a reasonable measure of the user's long-term production rate. For
all other users subject to production based standards, the user must submit
the actual average production rate for the reporting period.
* Flov Data Reporting - By regulation, industrial users subject to
categorical pre treatment standards must submit average and daily maximum
flow data. These should include flow data for each flow rate used in
calculating the industrial user's limits (e.g., total flow and dilution
flow) .
• Signature of Authorized Representative - A signed statement by an
authorized representative that certifies the report's validity.
• Certification Statement - "I certify under penalty of law that this
document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information submitted. Based on
my inquiry of the person or persons who manage the system, or those persons
directly responsible for gathering the information, the information
submitted is, to the best of my knowledge and belief, true, accurate, and
complete. I am aware that there are significant penalties for submitting
false information, including the possibility of fine and imprisonment for
knowing violations."
9/15/89 8-27
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CHAPTER 8 MONITORING AND REPORTING REQUIREMENTS
TABLE 8-7. FUNDAMENTAL ELEMENTS OF AN INDUSTRIAL USER PERIODIC
COMPLIANCE REPORT
(Continued)
If an industrial user has certified to a particular condition of a
categorical standard, a statement should be Included ackiiovledging the
continuing applicability of this certification. for example, metal
finishers and electroplaters would provide the following certification
statement, to conform with alternatives for monitoring Tor.al Toxic Organics
(TTO) and its approved toxic organic management plan:
Based on my inquiry of the person or persons directly responsible for
managing compliance with the pretreatment standard for Total Toxic Organics
(TTO), I certify that, to the best of my knowledge and belief, no dumping
of concentrated toxic organlcs into the wastevater has occurred since
filing of the last semiannual compliance report. I further certify that
this facility is implementing the toxic organic management plan submitted
to the Control Authority.
• Other Data
Identification of all occurrences of noncompliance
Explanation of violations and corrective action(s) taken
Type of sample, sampling time and location, and persor taking sample
Date analysis was performed, analytical methods used, and person
performing analysis
Industrial user limits
Telephone number of contact person
Identification of any process or treatment changes.
9/15/89 8-28
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CHAPTER 9
STANDARD CONDITIONS
The standard conditions in an Industrial user's permit should set forth
the substantive administrative and procedural requirements that are applicable
to all industrial users of the POTW's collection and treatment system.
Standard conditions are an essential element of every permit and, considering
that they need only be developed once (and thereafter should be repeated
verbatim in every permit) should be carefully crafted, preferably with the
assistance of an attorney. Standard conditions often reiterate many
provisions contained in the sewer use ordinance. Such reiteration is the best
way of notifying the permittee of his responsibilities and the procedural and
administrative aspects of the permit program.
Standard conditions outline the general duties and responsibilities of
each industrial user. The order, language, and format of the standard
conditions In permits are left to the Control Authority's discretion, as
illustrated by the examples of different languages in Table 9-1 (page 9-5).
The permit writer should adhere to the general rule of using clear and
specific language to ensure an adequate understanding of the provisions by all
parties and to avoid alternative interpretations that may hinder
enforceability. The Control Authority should have its attorney review these
conditions before they are used in permits to ensure there is adequate
authority in the sewer use ordinance for each provision, and that they are
understandable and free of legal loopholes.
Depending on the amount of detail provided in the Control Authority's
sewer use ordinance, standard conditions for industrial user permits may be
taken verbatim from the Control Authority's sewer use ordinance, Incorporated
into permits through a specific reference to the ordinance sectlon(s) which
set forth these standard condition provisions, or derived for use In permits
(and specifically set forth therein) from broad grants of authority in the
9/15/89 9-1
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CHAPTER 9 STANDARD CONDITIONS
sewer use ordinance. The Control Authority should verify the enforceability
of incorporation by reference prior to its use.
Some of the standard conditions ordinarily contained ir an industrial
user's permit are briefly highlighted below. Illustrations of example
language used to specify such conditions are found in Appendix G.
• Definitions of terms used in the permit that may be considered
ambiguous or that need clarification. Terms that ma/ need to be
defined include: composite and grab samples; instantaneous
measurement; 4-day average, monthly average, or 30-day average; and
effluent data and upset.
• The industrial user's duty to comply with all provisions of the permit
and the local sewer use ordinance, including the duty to comply with
the general discharge prohibitions. (In some cases, the general
discharge prohibitions may be included verbatim as a separate standard
condition.)
• The industrial user's duty to comply with all applicable Federal
pretreatment standards including those which become
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CHAPTER 9 STANDARD CONDITIONS
• A severabilitv clause that allows the remaining parts of a permit to
remain in force should any portion of the permit be found invalid and
subsequently be suspended or revoked by a court of law.
• The industrial user's responsibility or duty to reapply for a new
permit prior to expiration of the current permit.
• Provisions requiring the installation and proper operation and
maintenance of wastewater pretreatment facilities by the industrial
user, including proper calibration and maintenance of all sampling
equipment.
• Provisions requiring the proper disposal of pretreatment or other
sludges and any hazardous wastes (e.g., spent chemicals) used or
generated at the industrial user's facility so as to prevent the
discharge of such materials to the POTW.
• A condition that prohibits the dilution of industrial user wastewaters
as a partial or complete substitute for treatment of the wastewaters
prior to discharge to the POTW.
• Monitoring requirements (in addition to those specified in other
portions of the permit) including:
An outline of specific records to be maintained during sampling
events (i.e., name of sampler, date, time and location of sampling,
name of laboratory analyst, date and time of analyses, and
analytical method used)
The requirement to follow EPA-approved sampling methods in 40 CFR
Part 136, or other EPA-approved methods
The requirement to implement QA/QC procedures such as proper
installation and maintenance of flow monitoring and sampling
equipment, periodic calibration of sampling and monitoring devices,
and laboratory QA/QC procedures.
The requirement to resample within 30 days of an identified effluent
violation
• Reporting requirements (in addition to those specified in other
portions of the permit), such as:
The name and address of Control Authority personnel to whom
applicable compliance monitoring reports are to be submitted
The requirement to notify the Control Authority of spills, slug
loadings, or accidental discharges of concern
9/15/89 9-3
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CHAPTER 9 STANDARD CONDITIONS
The requirement to notify the Control Authority of any planned
changes in industrial processes, production rates, or in the volume
or characteristics of wastewaters discharged to the Control
Authority.
Requirement that the Control Authority must be rotified within 24
hours of an identified effluent violation.
• A condition that requires the industrial user to maintain or retain
records related to industrial operations and wastevater discharges for
a minimun of three years.
• Specific signatory requirements for all reports submitted to the
Control Authority. In all cases, reports nust be signed in accordance
with 40 CFR 403.12(1).
• Provisions that address public access to industrial user records and
the maintenance of confidential information. It should be made clear
that at no time can wastewater effluent data be claimed or held as
confidential information.
• The right of entry or right of access of Control Authority personnel or
its representatives to the industrial user's property to perform
sampling and inspection activities and to examine c.nd copy industrial
user records.
• Legal remedies or enforcement measures including penalties available to
the Control Authority to address violations of permit conditions.
Neither the discussion above nor the list provided in Appendix G exhausts
all potential standard conditions that could be included in an industrial
user's permit. However, both lists represent some of the more important types
of conditions to be placed in the permit.
9/15/89 9-4
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CHAPTER 9 STANDARD CONDITIONS
TABLE 9-1. EXAMPLES OF DIFFERENT LANGUAGE USED TO INCORPORATE
STANDARD CONDITIONS INTO INDUSTRIAL USER PERMITS
PERMIT MODIFICATION OR REVISION
Example No. 1: The City reserves the right to amend this permit at any time.
in accordance with Chapter 13.16 Code of General Ordinances, to provide for
more stringent limitations or requirements.
Example No. 2: Terms and conditions of this permit may be modified by the
City if revision is necessary to meet City NPDES discharge permit
requirements, if substantial changes of the permittee's operations or
wastevater occur, if applicable Federal pretreatment standards are amended, or
if the Superintendent of the City's treatment works determines that there is
other good cause. To the extent otherwise permissable by law, changes or new
conditions in the permit shall include a reasonable schedule for compliance.
Example No. 3: The terms and conditions of this permit may be subject to
modification by the City at any time as identified in Section 29.03(5) of the
City's sewer use ordinance. Any new conditions in the permit shall include a
reasonable time schedule for compliance unless the modification incorporates a
new requirement that includes an alternative compliance schedule. The permit
may also be modified to incorporate special conditions resulting from the
issuance of a special order.
DILUTIOH OR EXCESSIVE DISCHARGE
Example No. 1: No industry shall increase the use of potable or process water
in any way or mix separate wastestreams for the purpose of diluting a
discharge as a partial or complete substitute for adequate treatment to
achieve compliance with any applicable Federal pretreatment standards, limits
in Section 29.02 of the City's Ordinance, or any other limitations set forth
in this permit.
Example No. 2: The permittee shall not increase the use of process water or,
in any way, attempt to dilute a discharge to achieve compliance with the
limitations contained in this permit.
PROPER DISPOSAL OF PRETREATHEVT SLUDGES AND HAZARDOUS WASTES
Example No. I; The disposal of sludges generated within wastewater
pretreatment systems shall be in accordance with applicable State and Federal
regulations, specifically Section 405 of the Clean Water Act and Subtitle C
and D of the Resource Conservation and Recovery Act and Section 319-333 of the
State Code.
Example No. 2: Solids, sludges, filter backwash, or other pollutants removed
in the course of treatment or control of wastewater shall be disposed of in a
manner such as to prevent any such materials from entering the Authority's
sewerage system.
9/L5/89 9-5
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CHAPTER 10
SPECIAL CONDITIONS
Special conditions are tailored to the particular permittee. They
typically address known or suspected problems (e.g., spills) by requiring the
industrial user to undertake a specific activity in order to reduce the
quantity of pollutants currently discharged or to prevent the discharge of new
or additional pollutants. These special requirements are typically described
in a separate section of the permit. Examples of a few special conditions
include compliance schedules, development and implementation of industrial user
management practices, and additional monitoring requirements.
Special conditions are based on the permit writer's professional judgment
and can take many forms. Because they are often based on generally worded
grants of authority in the local ordinance, and involve some exercise of
judgment on the part of the permit writer, special conditions are more likely
to be challenged. Therefore, the basis for them must be well documented and
their use should be based on the fundamental principle of "reasonableness."
10.1 COMPLIANCE SCHEDULES
A compliance schedule is a means of establishing milestones and deadlines
for carrying out specific actions required of an industrial user. For example,
a compliance schedule may be used to delineate the phases for construction or
installation of wastewater pollution control (pretreatment) technology or for
the submission of a spill plan. Each compliance schedule typically includes a
brief outline of the activities required and specific target dates to meet
major steps in the schedule. Table 10-1 (page 10-5) provides an example of a
compliance schedule.
A compliance schedule is often negotiated with the industrial user to
ensure that the adopted schedule is achievable. The permit writer cannot
establish a schedule for compliance with a Federal categorical pretreatment
9/15/8910-1
-------
CHAPTER 10 SPECIAL CONDITIONS
standard that extends beyond the compliance date Indicated by the applicable
Federal categorical pretreatment regulation [40 CFR 403.12(b)(7)]. In
addition, a permit compliance schedule does not relieve an industrial user of
its obligations to comply with applicable pretreatment standards and
requirements including the prohibitions against pass through and interference.
Once any Federally-established compliance deadline for a categorical
pretreatment standard has passed, the proper action for th«i Control Authority
is to initiate an enforcement proceeding which may, in appropriate instances,
involve issuance of an administrative enforcement order wi :h a compliance
schedule. Of course, the permit writer may develop more stringent compliance
schedules aimed at achieving compliance with Federal standards prior to Federal
deadlines. Compliance schedules should contain milestone dates which reflect
the shortest reasonable time in which compliance can be achieved. Finally, the
industrial user should be required to submit a progress report to the Control
Authority no later than 14 days following each milestone date in the compliance
schedule.
When establishing a compliance schedule for an industrial user's permit,
the permit writer should take into consideration the complexity of the
improvements or actions specified as well as any seasonal factors or legal
requirements that will affect the industrial user's efforts to comply with the
conditions outlined. For example, a compliance schedule requiring ground
breaking in January in areas where winter conditions will prevent such actions
from taking place is not reasonable.
10.2 INDUSTRIAL USER MANAGEMENT PRACTICES
An industrial user permit can also require the develcpment and
implementation of industrial user management practices to control or abate
discharges of pollutants. The industrial user management practices (e.g., slug
loading control plans, accidental discharge prevention plans, or toxic organic
management plans) are designed to prevent or to nitigate the release of
pollutants in significant amounts to the sewer system. Generally, these are
9/15/89 10-2
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CHAPTER 10 SPECIAL CONDITIONS
effective and inexpensive ways of addressing existing or potential problems.
They should be used to complement effluent limits rather than substitute for
them. The most likely candidates for management practices are process areas,
storage areas, and loading docks.
There are at least two ways to impose industrial user management practices
in permits: 1) by requiring the industrial user to develop and implement an
industrial user management practices procedures manual (either a comprehensive
plan or a plan addressing specific problems); or 2) by imposing site or
pollutant-specific requirements (e.g., the removal or sealing of floor drains
or the containment of stored chemicals). When incorporating these special
conditions in the permit, the permit writer should use language which clearly
identifies what specific activities must occur and when these activities must
occur or be completed. Examples are provided in Table 10-2 (page 10-6). The
industrial user management practices procedures manual should be reviewed when
submitted, but it is not generally necessary or advisable for the Control
Authority to approve the plan. Compliance with the plan cannot relieve the
industrial user of its liability should its discharge cause or contribute to
pass through or interference. Approval of the plan may be misconstrued as
Control Authority sanction even though the plan when implemented may not be
effective in controlling slug loads. Additional information on industrial user
management practices is contained in Appendix H. Further information can be
found in the following EPA manuals:
• Guidance Manual for Control of Slug Loadings to POTWs
• Guidance Manual for Implementing Total Toxic Oreanics (TTO)
Pretreatroent Standards
• NPDES Best Management Practices Guidance Document
• Guidance Manual on the Development and Implementation of Local
Discharge Limitations Under the Pretreatment Program
• EPA Region 10's Guidance Manual for the Development of an Accidental
Spill Prevention Program.
9/15/89 10-3
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CHAPTER 10 SPECIAL CONDITIONS
10.3 SPECIAL MONITORING REQUIREMENTS
The Control Authority may often Incorporate special monitoring
requirements into industrial user permits. Additional monitoring may be used
to confirm the presence of suspected pollutants of concern (e.g., pollutants
not regulated in an industrial user's permit). For example, the Control
Authority may impose biomonitoring or other toxicity testing to determine the
effluent's toxicity. This additional monitoring may then be used to evaluate
whether the permit should be revised to include additional effluent limits, to
require installation of pretreatraent technology, or to reject the wastewater
entirely. Examples of special monitoring conditions appear in Table 10-3 (page
10-8).
The Control Authority may, as illustrated in Table 10-3 (page 10-8),
require industrial users to perform additional monitoring of pollutants that
are regulated in their permits in response to noncorapliancij. Thus, the special
condition may trigger an increase in the user's self-monitoring frequency. The
increased monitoring allows the Control Authority to detect patterns of
continuing noncompliance and distinguish isolated violations from chronic
noncompliance. Naturally, the increased monitoring also draws the industrial
user's attention to the problem through the additional cosi:s incurred. It
thereby may act as a deterrent to future incidents of noncompliance.
9/15/89 10-4
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CHAPTER 10 SPECIAL CONDITIONS
TABLE 10-1. EXAMPLE OF INCORPORATING A COMPLIANCE SCHEDULE IN
SPECIAL CONDITION SECTION OP PERMIT
Permit No. 001
Page 3-1
PART 3 - PRETREATMENT AND MONITORING FACILITIES
COMPLIANCE SCHEDULE
A. In order Co comply with the effluent limitations identified in Part 1,
Section 2 C. and Section 3 A. 2 in a reasonable time period, the permittee
shall provide necessary wastevater pretreatment as required by Sections
13.16.170 and 13.16.180, Code of General Ordinances, in accordance with the
following schedule:
EVENT BY NO LATER THAN
1) New wastewater pretreatment plant design December 30, 1984
completed, clariflers ordered, and
building foundation begun.
2) Submit to the City a plant management plan April 19, 1985
for control of solvents and toxic organics.
3) Pretreatment plant building essentially June 30, 1985
complete, field-erected tank external
construction in place, and piping installation
begun.
4) Complete installation of new sampling devices September 15, 1985
and Palmer Bowlus flume.
5) Obtain full pretreatment plant operational February 15, 1986
status and achieve full compliance.
No later than 14 days following each date in the above schedule, the
permittee shall submit to the City a progress report including, at a minimum,
whether or not it complied with the increment of progress to be met on such
date and, if not, the date on which it expects to comply with the increment of
progress, the reasons for delay, and the steps being taken to return the
project to the schedule established in this permit.
9/15/89 10-5
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CHAPTER 10 SPECIAL CONDITIONS
TABLE 10-2. EXAMPLES OF IMPOSING INDUSTRIAL USER MANAGEMENT
PRACTICES IN PERMITS
EXAMPLE OF REQUIREMENT TO DEVELOP AND IMPLEMENT SLUG WADING CONTROL PLAN
V. OTHER REQUIREMENTS
1. The permittee shall develop a slug loading control plan designed to
prevent slug loading by the permittee. The plan shall include descriptions of
all chemical storage and transfer areas and all chemical process tanks.
The descriptions shall include a list of chemicals that are handled/stored
(and where more than one chemical is in the storage area a description of
chemical compatibility), the capacity of each tank and any secondary
containment, description of chemical transfer procedures, and the proximity of
each transfer or storage area to severs (Including drainage patterns). A spill
contingency plan must be developed for the facility and include:
(1) Procedures for routine inspection of potential spill sources
(2) Procedures for notifying the City Uastevater Department of any spill
(3) Abatement and containment plans for possible spil.ls based on areas of
chemical use and transfer, containment structures, and known drainage
patterns
(4) A list of equipment and materials available for spill response
activities and the location of each
(5) A listing of commercial (or other) suppliers of spill response
equipment and materials (indicating the types of equipment available)
and their telephone numbers
(6) A list of the facility personnel (by name and title) that have an
identified role to play in the implementation of a spill response
plan, indicating the responsibilities and authorities of each. In
particular, the following details should be identified: the primary
and secondary spill response coordinator (day/evening shifts) and rhe
persons having access and authority to commit existing and additional
resources to a spill response effort.
The plan containing all of the above prescribed elements must be submitted to
the City Wastevater Department by April 10, 1987.
9/15/89 10-6
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CHAPTER 10 SPECIAL CONDITIONS
TABLE 10-2. EXAMPLES OF IMPOSING INDUSTRIAL USER MANAGEMENT
PRACTICES IN PERMITS
(Continued)
2. The permittee shall achieve full implementation of the slug loading
control plan within four months of the effective date of this permit.
3. The permittee shall notify the City of any proposed changes to the plan by
submitting a proposed revised plan to the City and informing the City (in
advance) of the date upon which the proposed revised plan will take effect.
EIAHPLE OF INCORPORATING SLUG LOADING CONTROLS INTO SPECIAL CONDITION SECTION
OF PERMIT
Part D. SPECIAL REQUIREMENTS
The Permittee Must:
1. Provide PVC liners in Concrete Vastewater Sumps by 4-01-56,
2. Install Concrete Tank with PVC Liner for Excess Storage Capacity by
7-30-66.
3. Connect all Floor Drains to the North Sump by 10-01-86.
The permittee shall provide immediate written notice of any event that would
prevent any of the dates specified in this section from being met. The
permittee shall also provide written confirmation to the City Uastewater
Department when the above activities are completed.
9/15/89 10-7
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CHAPTER 10 SPECIAL CONDITIONS
TABLE 10-3. EXAMPLES OF INCORPORATING SPECIAL MONITORING REQUIREMENTS
IN PERMITS
EXAMPLE OF INCREASED MONITORING DUE TO VIOLATIONS
Increased Sampling in Response to Noncomplying Discharge
1. Frequency of sampling and analysis shall be increased according to the
schedule listed below whenever a discharge in violation of City/EPA limits
is detected. Only those parameters that are in noncompliance need to be
analyzed during the resampling period.
Parameter Samp1e TYDe Additional No. of Samples
Metals One-day composite One per day for two days
pH Grab Two per day for two days
2. Resampling of the noncomplying parameter shall commence within 68 hours or
on the first available weekday representative of normal metal finishing/
plating operations after a violation is discovered.
3. The results of this sampling and analysis shall be reported to the City
within 15 days of the sampling.
EXAMPLE OF SPECIAL MONITORING TO DETERMINE METAL CONCENTRATION AND TOIICITY OF
DISCHARGE
D. Intensive Sampling Period
1. Sampling and analysis requirements
PARAMETER SAMPLE TYPE
Chromium 24-hour flow-proportional composite
Copper 24-hour flow-proportional composite
Lead 24-hour flow-proportional composite
Mercury 24-hour flow-proportional composite
Nickel 24-hour flow-proportional composite
Zinc 24-hour flow-proportional composite
Toxicity 24-hour flow-proportional composite
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CHAPTER 10 SPECIAL CONDITIONS
TABLE 10-3. EXAMPLES OF INCORPORATING SPECIAL MONITORING REQUIREMENTS
IN PERMITS
(Continued)
2. Intensive sampling frequency
A 24-hour flow-proportional composite sample shall be taken on each day of
a 5 consecutive day sampling period (Monday-Friday) during the middle 10 veeks
of either Spring or Fall semester for each of the sample sites one through
eight listed in permit section IV.A.
3. Intensive sampling period
Time allowed for intensive sampling of sites one through eight shall extend
through Spring semester 1986.
E. Miscellaneous Self-Monitoring Requirements
1. Sample representativeness
All sampling shall be accomplished so as to obtain samples representative
of dally vastevater discharge and shall take place on days representative of
normal university operations. For purposes of this permit, university
holidays, vacations, and the veek preceding the final examination period shall
not be considered representative of normal university operations.
2. Toxicity analysis
Until toxicity test instrumentation is purchased, testing shall consist of
measuring oxygen depletion over a six-hour period using a dissolved oxygen
meter and a one-liter bottle or BOD bottle. The test shall compare oxygen
depletion rate of a standard vastevater bacteria culture versus vastevater
bacteria culture dosed vlth sample in question.
Toxicity limits may be developed and made part of this permit if deemed
necessary to prevent interference or inhibition of City biological vastevater
treatment processes.
9/15/89 10-9
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CHAPTER 10
SPECIAL CONDITIONS
TABLE 10-3. EXAMPLES OF INCORPORATING SPECIAL MONITORING REQUIREMENTS
IN PERMITS
(Continued)
EIAHPLE OF SPECIAL TOXICITY HONITORIHG REQUIREMENT
Industrial Discharge Permit
Page 9
III. Self-Monitoring Requirements
A. Samp line and Analysis for Lazoon Discharee Criteria
Parameter
COD
Electrolytic
Sample Location
Lagoon effluent
Lagoon effluent
Sample Type
Composite
Compos ite
Frequency
Daily
Daily
Respirometer
(six-hour
duration)
PH
Lagoon effluent
Grab
Daily
B. Electrolytic Respirometer Methodology
The Electrolytic Respirometer (ER) testing procedure as described in
Attachment A will be used. The accepted standard shall be 0-t, uptake of
vastevater sample greater than 02 uptake of control sample. Such procedure may
be reasonably modified by mutual agreement if the City demonstrates that a more
suitable testing procedure is available.
1. Initial ER testing should be set up by midnight with a normal
run, including purge, lasting until 7:00 a.m.
2. When obvious ER failure is noticed, the test should be halted and
a new one started immediately.
3. If the second ER meets the accepted standard, ,'agoon discharge
can begin. The test should be run to completion and the City
notified of results within six hours.
4. Though discharge can begin after the Initial EF test, discharge
can be stopped by the City at test completion cr sooner, if ER
has failed.
9/15/89
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CHAPTER 10 SPECIAL CONDITIONS
TABLE 10-3. EXAMPLES OF INCORPORATING SPECIAL MONITORING REQUIREMENTS
IN PERMITS
(Continued)
5. In the event of ER failure, the City shall be notified. When
City notification is necessary, please contact any of the
following people:
Industrial Pretreatment Coordinator
Superintendent
Lead Operator on Duty
9/15/89 10-11
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CHAPTER 11
DOCUHENTATION OF PERMIT DECISIONS
Once the permit has been drafted, It is very important to create a
permanent record of the procedures followed and the basis for the decisions
made during the permitting process. Although such documentation may initially
seem an unnecessary and time-consuming task, it will inevitably play a
critical role in any permit challenge and in the long run it can save the
permit writer a great deal of time and effort. Some of the principal reasons
for documenting permit decisions are:
• To document, in the event of permit challenge, that permit conditions
were developed in a reasonable, non-arbitrary manner and in accordance
with proper procedures
• To streamline future permitting issuances through the creation of a
complete file containing all information used in developing previous
permits which only need to be revised if circumstances change
• To create a permanent record of permit development
- In case personnel changes occur
- For "institutional memory"
- As an explanation of permit conditions to other personnel within the
pretreatment staff or in the event that the Control Authority and
the permittee disagree on the meaning of particular permit
conditions
• To explain permit conditions to the industrial user and to the public
• To facilitate a determination of the need for permit modification if
changes have occurred at the permittee's facility which may arguably
warrant modifying the permit
• To refresh the permit writer's memory at reissuance time about how the
permit was originally developed, particularly if the permit duration
was four or five years
• To satisfy possible Approval Authority requirements for documentation
of permitting rationale.
9/15/89 11-1
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CHAPTER 11 DOCUMENTATION OF PERMIT DECISIONS
11.1 FACT SHEET
The bases for decisions made during the permitting process are generally
summarized in a document commonly referred to as the "industry fact sheet."
The fact sheet briefly sets forth the significant factual, legal,
methodological, and policy questions considered in preparing the permit. The
fact sheet should be kept attached to a copy of the permit in the Control
Authority's files. The components of a fact sheet are presented in Table 11-1
(page 11-3), and an example is contained in Appendix I.
11.2 PERMIT RECORD
It is particularly important for the permit writer tc document all verbal
discussions with the public and/or permittee and to keep copies of all letters
exchanged. For example, an industrial user may not be able to measure the
flow of wastewater discharged to the POTW at the time of permit application or
may be measuring the flow after it is combined with nonprocess wastestreams.
The permit writer and the user may agree upon mutually acceptable wastewater
flows to be used in developing the effluent limits. Such discussion and
decision should be documented. The Control Authority should establish a file
where all records pertaining to the development and issuance of the permit are
kept throughout the development of the permit. Relevant documents to include
in this file are:
• Permit application form
• Draft permit and fact sheet
• All correspondence relating to the development of i:he permit
• Copies of any telephone conversations with interested parties
concerning the permit
• Record of any public hearing or meetings
• Copies of all comments received
• Copies of all replies or responses to comments received.
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CHAPTER 11 DOCUMENTATION OF PERMIT DECISIONS
TABLE 11-1. COMPONENTS OF A PERMIT FACT SHEET
1. Brief description of industrial user, Including:
• Name, address, and location of the facility
• Number of connections which the facility has to the sever system,
specifying the one(s) relevant to the fact sheet
• Type of operations in vhlch the facility is engaged (e.g., manufacture
of battery terminals)
0 Brief description of the plant processes or other sources of
generating vastevater
0 Categorical determination (if applicable).
2. Type and quantity of the discharge:
0 Rate or frequency of the discharge; the average and maximum daily flov
0 Daily maximum and monthly average discharge of any pollutants present
in significant quantities or subject to limitations or prohibition.
3. Basis for the permit limits, including:
0 Permit application documents
0 Analytical data for pollutants provided in both a complete and summary
form so that they can be easily reviewed and verified
0 Copies of or citations to Federal, State, and local regulations
0 Copies of literature information vhere used to develop the permit
limits (e.g., pages from the development documents, Treatability
Manual. etc.)
0 Plant layouts and process and vastevater flov diagrams.
4. Detailed discussion of any special conditions in the permit and the
rationale for pollutant selection and limits development.
5. Calculations shoving the actual numbers used to derive each limit,
including:
0 Combined vastestream formula or flov weighted average calculations
0 Equivalent mass or concentration-based limits calculations
0 Local limits allocation basis.
9/15/89 11-3
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PART III
PERMITTING WASTE HAULERS AND OVERVIEW OF REQUIREMENTS
REGARDING POTW RECEIPT OF HAZARDOUS WASTES
-------
CHAPTER 12
PERMITTING WASTE HAULERS
Federal regulations [40 CFR 403.5(a)(l)] prohibit nondomestlc discharges
of pollutants to a POTW, regardless of their node of entry, that would cause
pass through or interference. Waste hauler discharges to a POTW, fall within
the scope of the General Pretreatment Regulations [40 CFR 403). As a result, a
Control Authority must establish the legal authority and procedures necessary
to ensure that waste hauler discharges conply with Federal pretreatnent
standards contained in 40 CFR 403.5(a), (b), and (c) [40 CFR 403.8(f)(l) and
(2)]. These prohibitions apply not only to toxic pollutants, but also to
excessive concentrations of conventional and non-conventional pollutants. In
addition, if the load has originated from a categorical industry, it remains
subject to EPA's categorical pretreatment standards (i.e., it cannot be
introduced into the POTW unless it has been treated to the level prescribed by
the applicable categorical standards). If the hauled waste received by a POTW
is a "hazardous waste" as defined under the Federal Resource Conservation and
Recovery Act (RCRA), the POTW must comply with additional Federal requirements.
For a complete discussion of the legal, administrative, and technical methods
of controlling hauled hazardous wastes, see the Guidance Manual for the
Identification of Hazardous Wastes Delivered to Publicly Owned Treatment Works
by Truck. Rail, or Dedicated Pipeline.
A permit system is the most direct and efficient method of regulating
waste haulers that discharge to a POTW. Implementing a permit system provides
the opportunity to monitor and regulate haulers based on the treatment works'
operating conditions. A sample waste hauler's permit is presented in
Appendix J. Figure 12-1 (page 12-7) presents an overview of procedures
involved in implementing a waste hauler permit system.
9/15/89 12-1
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CHAPTER 12 PERMITTING WASTE HAULERS
12.1 LEGAL AUTHORITY
Generally, the legal authorities required for an effective waste hauler
permitting program are similar to those for regulating sources connected to the
POTW (see Chapter 3, Section 3.1). However, there are certf.in additional
provisions which should be included in the Control Authority's sewer use
ordinance, In particular the ordinance should contain the following
provisions:
• Requirement that the hauled discharge oust meet all applicable Federal,
State, and local pretreatment standards and requirements including
categorical standards developed for the waste generator's industrial
category. This authority should also be expanded to allow the Control
Authority to permit the original source of the hauled wastes
• The Control Authority may require septic and/or industrial waste
haulers to obtain a permit
• Waste haulers may only discharge loads at locations specifically
designated by the Control Authority
• The Control Authority may collect samples of each hauled load to ensure
compliance with applicable pretreatment standards
• No load may be discharged without prior consent of i;he Control
Authority
• The Control Authority may require the hauler to provide a waste
analysis of any load prior to discharge
• Waste haulers must use a manifest system.
12.2 PERMIT APPLICATION PROCEDURES
The first step in implementing a waste hauler permit svstem is to identify
all waste haulers, including septage haulers, that discharge waste materials
into the POTW. Waste haulers can be identified by using municipal or county
business license records or by consulting local telephone directories. Waste
haulers within the immediate and surrounding service area should be considered
9/15/89 12-2
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CHAPTER 12
PERMITTING WASTE HAULERS
potential dischargers to the POTW system and should be notified of the permit
system requirements.
Each waste hauler should be required to complete a permit application.
The permit application form should be designed to provide the Control Authority
with all information necessary to control waste haulers.
12.3 CONDITIONS FOR WASTE HAULER PERMITS
To protect a POTW from possible hazardous or problem-causing discharges
from waste haulers, certain conditions should be developed and applied to waste
haulers as part of the permitting system. The following is a list of
conditions that a Control Authority may wish to include in discharge permits
issued to waste haulers:
Right of Refusal to Accept Waste - The Control Authority should have
the right to refuse any hauled waste load.
Nondoroestlc Loads - The waste hauler should be limited to discharging
only domestic wastes if the POTW is not capable of treating any
nondomestic wastes. However, if a POTW can treat nondomestic wastes in
general or only certain nondomestic wastes, then provisions for these
discharges should be established. To account for the nondomestic
wastes it receives from waste haulers, the POTW should request a list
of customers from each hauler and the type(s) of waste(s) hauled from
each customer.
Prohibited Discharges - Waste haulers must always be prohibited from
discharging wastes which would violate any prohibited discharge
standards of the General Pretreatment Regulations [40 CFR 403.5(b)] or
any local prohibited discharges. The Control Authority may wish to
sample and analyze the hauled wastes or require that the hauler perform
such sampling and analysis to verify that such standards would not be
violated if the waste is discharged to the POTW. If the POTW does not
have permit-by-rule status (see Chapter 13) or is not otherwise
equipped to treat RCRA hazardous wastes, the permit should prohibit the
introduction of hazardous wastes to the POTW.
Federal Categorical Pretreatment Standards - If waste haulers are
allowed to discharge nondomestic wastes to the POTW, then it must be
determined whether the sources of these wastes are regulated by
National categorical pretreatment standards. To determine if wastes
9/15/89
12-3
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CHAPTER 12 _ PERMITTING WASTE HAULERS
collected by haulers are regulated by National categorical pretreatment
standards, the Control Authority should obtain information from both
the waste hauler and the facility from which the wastes were
collected. Questions that might be asked by the Control Authority to
determine applicability of any National categorical pretreatment
standard to the source(s) might include the following:
Were the wastes generated from regulated processes subject to
categorical pretreatment standards?
What types of pollutants are known or suspected to be present in
the hauled wastes? At what estimated or known levels?
If the hauled waste load is subject to categorical pretreatment
standards, is it in compliance with the standards?
Has the waste hauler collected wastes from mor<; than one location
or source such that domestic and industrial or different types of
industrial wastes have been mixed within the load?
Is the waste hazardous under the Resource Conservation and
Recovery Act (RCRA)? If so, is it a listed or a characteristic
waste?
• Local Limits - The permit should require compliance with any local
limits established by the Control Authority.
of Loads - If a POTW is susceptible to hydraulic or organic
overloading, it may wish to consider placing a limit: on the maximum
number of loads that a waste hauler can discharge over a specified
period of time.
Designated Disposal Site - The permit should clearly designate the
disposal site. Three primary factors should be considered in the
establishment of disposal sites for waste haulers: potential plant
impacts, monitoring ease, and accessibility. Ideally, there should be
one disposal site located on the treatment plant grounds so that POTW
personnel can monitor discharges at all times for recording purposes
and to ensure proper handling of waste materials. The discharge site
should be located in an area that will not interfere with normal
treatment plant traffic. If a treatment plant is prone to upsets from
slug loads, the acceptance of waste hauler discharges directly at the
head of the plant without equalization facilities is: not desirable.
The disposal site should be monitored at all times, if possible, to
prevent illegal discharges. For the sane reason, controlled access is
also desirable. If the site cannot be monitored at till times, it should
be readily accessible to POTW personnel for periodic spot checks.
9/15/89 12-4
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CHAPTER 12 PERMITTING WASTE HAULERS
• Tine Limitations - Specific days and/or hours that waste haulers are
allowed to discharge should be stated in the permit conditions. The
following are considerations that Control Authorities should keep in
mind when developing discharge tine limitations:
Days and hours per day that POTW personnel are available at the
disposal site
Time periods during each day that peak and low flows occur within
the collection system and at the treatment plant.
• Waste Tracking - The permit should contain a condition that requires
the waste hauler to provide documentation on the nature and origin of
the wastes being discharged. A manifest system or waste hauler log,
similar to those used for hazardous waste, is the most efficient means
to record this information. Examples of both are provided in the
Guidance Manual for the Identification of Hazardous Waste Delivered to
Publicly Owned Treatment Works by Truck. Rail, or Dedicated Pipeline.
This type of system would require a waste hauler to complete an entry
on the waste manifest form for each load he receives. The manifest
form should include information such as:
Name and address of each customer
Types of wastes collected
Approximate volume(s) received
Known or suspected pollutants
Certification that the waste is not hazardous.
Prior to each discharge, the Control Authority should require a
completed manifest form from the waste hauler. Each manifest sheet
should be completed in triplicate: one copy for the waste hauler, one
copy for the Control Authority's treatment plant's (or other
appropriate department's) file, and one copy for the Control
Authority's administrative/billing purposes. The Control Authority
will usually supply blank manifest forms to each waste hauler.
Additional requirements for hazardous waste haulers are discussed in
Chapter 13.
• Notification of Waste Type - The Control Authority may want to require
that any waste be approved prior to being hauled. The permit could
require the hauler to notify the POTW of new customers as well as
changes in the nature of wastewater originating from existing
customers.
9/15/89 12-5
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CHAPTER 12 PERMITTING WASTE HAULERS
• Random Sampling - The discharge permit should contain a condition
allowing for the random sampling of waste hauler loads prior to
discharge to the POTU. The permit could also require the hauler to
sample the waste where it is generated before it is pumped into the
truck or rail car. This will provide the Control Authority with a
mechanism for ensuring that discharges conform to appropriate standards
and regulations. Even domestic wastes have been found to contain high
concentrations of copper, lead, and zinc; therefore, it is important
that a surveillance monitoring program for septic waste haulers be
implemented.
• Standard Conditions - Many of the standard conditions placed in other
industrial user permits (see Chapter 9) should also be contained in the
waste hauler permits. A few of these are: modification of conditions.
nontransferabilitv. revocation of permit, and penalties/fines.
9/15/89 12-6
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CHAPTER 12
PERMITTING WASTE HAULERS
FIGURE 12-1. PROCEDURES OF A WASTE HAULER PERMIT PROGRAM
POTWmiqHCific
•
tf
POTW notifies wuxe baiter of
jjauiit syMou mpomncoo
POTW qiprovM pamM application
«d MOW dtoctaffe pennk
I
fonn
i
POTW tf time of diJcl)ir|B
WMe bwkr dactwfet» POTW
POTWiwdomly
POTW
ifpemitv
9/15/89
12-7
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CHAPTER 13
OVERVIEW OF REQUIREMENTS REGARDING FOTV RECEIPT OF HAZARDOUS WASTES
The Control Authority should be aware that if its treatment plant
accepts hazardous wastes by truck, rail, or dedicated pipeline within the
property boundary of the treatment plant(s), that POTW is a hazardous waste
treatment, storage, or disposal facility (TSDF) and is subject to regulation
under the Resource Conservation and Recovery Act (RCRA) , 42 USC 6901 e_t seq.
RCRA establishes a comprehensive program regulating the management of non-
exempt hazardous wastes from the time they are generated until ultimate
disposal (i.e., a "cradle to grave" management system). Under the RCRA
domestic sewage exclusion, mixtures of domestic sewage and other wastes
(including hazardous wastes) that mingle in the collection system prior to
reaching the POTW's property boundary are excluded from RCRA regulation.
However, wastes that are delivered by truck, rail, or dedicated pipeline do
not fall within this exclusion. Hazardous wastes received by these routes may
only be accepted by POTWs if the POTWs comply with RCRA "permit-by-rule"
requirements. State hazardous waste programs may also have laws governing
POTWs that accept hazardous waste for treatment.
The RCRA permit-by-rule regulations in 40 CFR 270.60(c) require the POTW
to:
• Have and comply with the conditions of a NPDES permit [40 CFR
270.60(c)(l) and (2)]
• Apply for an EPA identification number [40 CFR 264.11]
• Use a manifest system [40 CFR 264.71]
• Reconcile manifest discrepancies with the waste generator or
transporter [40 CFR 264.72]
• Keep a written operating record of wastes received and treatment,
storage, and disposal methods for the wastes [40 CFR 264.73(a) and (b)
(1)1
9/15/89 13-1
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CHAPTER 13 OVERVIEW OF REQUIREMENTS REGARDING POTW RECEIF: OF HAZARDOUS WASTES
• Submit a biennial report to the Regional Administrator (40 CFR 264.75]
• Submit a report to the Regional Administrator notifying EPA of any
unmanifested wastes at the time of receipt [40 CFR 264.76]
• Institute corrective action, as necessary, as specified in the POTW's
NPDES permit (for permits issued after November 8, 1984) [40 CFR
364.101]
• Require all wastes received to meet all Federal, State, and local
pretreatment requirements, as if the wastes were being conveyed to the
POTW by sewer, pipe, or similar conveyance [40 CFR 270.60(c)(4)].
A discussion of these requirements may be found in EPA's Guidance for
Implementing RCRA Permit-bv-Rule Requirements at POTWs.
A POTW can assume that it is receiving hazardous wastes by truck or rail
if the wastes are accompanied by the hazardous waste manifest used in the RCRA
program. If the waste hauler does not provide such a manifest, the POTW may
still wish to determine if the hauled wastes are considered hazardous since
RCRA responsibilities apply even if the POTW accepts such wastes unknowingly.
To be considered a hazardous waste, a waste must first be considered a "solid
waste" as defined in Section 6903(27) of RCRA. To determine if a solid waste
is regulated under Federal law as a hazardous waste, the POTW should determine
whether the waste in question falls into one of the following categories:
• It is listed as a hazardous waste in Subpart D of 40 CFR 261 (unless
it has been specifically delisted)
• It has not been listed, but it exhibits any of the characteristics of
a hazardous waste described in Subpart C of 40 CFR 261
• It is a mixture of a listed waste and a nonhazardous waste or is
derived from the treatment of a listed hazardous waste (unless it has
been specifically excluded under 40 CFR 261.3). (Nate: a mixture of
a characteristic waste and a nonhazardous solid waste, or the residue
from the treatment of a characteristic waste, is only considered
hazardous if it exhibits one or more of the hazardous waste
characteristics.)
9/15/89 13-2
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CHAPTER 13 OVERVIEW OF REQUIREMENTS REGARDING POTW RECEIPT OF HAZARDOUS WASTES
For more information on identifying and regulating hazardous wastes, see the
following EPA guidance materials:
• RCRA Information on Hazardous Wastes for Publicly Owned Treatment
Works
• RCRA Orientation Manual (prepared by the Office of Solid Waste)
• Guidance Manual for the Identification of Hazardous Waste Delivered to
Publicly Owned Treatment Works by Truck. Rail, or Dedicated Pipeline
• Guidance for Implementing RCRA Perait-bv-Rule Requirements at POTWs.
POTWs can choose not to accept the delivery of hazardous wastes by truck
rail or dedicated pipeline by:
• Strictly prohibiting the discharge of any hauled wastes
• Prohibiting the discharge of any industrial process wastes (i.e.,
accepting only domestic waste from haulers or dedicated pipelines)
• Prohibiting the discharge of hazardous waste (e.g., accept hauled
and/or dedicated pipeline industrial process wastes but only if
accompanied by sufficient documentation to demonstrate that wastes are
not hazardous).
Reliable monitoring must be conducted to ensure that these conditions are met.
The Control Authority should evaluate each of these methods before making a
decision as to which method is the most appropriate for its treatment
plant. Considerations such as local community practices should be taken into
account (e.g., is contract hauling of household and industrial septage wastes
common in the community or are most locations serviced by municipal sewer
collection systems?).
In addition to the RCRA requirements incorporated by reference into the
permit-by-rule requirements for POTWs, there may be other requirements which
apply as a matter of law. For example, Sections 3004(d), (e), and (g) of RCRA
prohibit the land disposal of hazardous waste in specified situations. These
9/15/8913-3
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CHAPTER 13 OVERVIEW OF REQUIREMENTS REGARDING POTW RECEIPT OF HAZARDOUS WASTES
requirements and others may apply to POTWs receiving hazardous waste by truck,
rail, or dedicated pipeline. See Appendix D of EPA's Guidance for
Implementing RCRA Permit-by-Rule Requirements at POTWs for other RCRA
requirements which may apply, to POTWs that receive hazardous wastes by truck,
rail, or dedicated pipeline.
In summary, the Control Authority should determine the applicability of
RCRA requirements and responsibilities if its treatment plant currently
accepts hauled wastes, especially if any of the hauled wastes are known or
suspected to have been collected from industrial sites. FOTWs not currently
accepting hauled or dedicated pipeline hazardous wastes, which are considering
doing so, should be aware of the RCRA responsibilities and potential
liabilities associated with such practices.
9/15/89 13-4
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PART IV
APPENDICES
-------
APPENDIX A
BIBLIOGRAPHY
-------
APPENDIX A
BIBLIOGRAPHY
North Carolina Department of Natural Resources and Community Development.
Permit Writing Guidance for Control Authorities. NC Report No. 85-12.
December 1985, revised October 1986.
North Carolina Department of Natural Resources and Community Development. NC
Pretreatment Monitoring and Reporting Guidance. NC Report No. 84-01.
February 1984.
U.S. EPA. Development Document for Effluent Limitations Guidelines and
Standards for the Aluminum Forming Point Source Category. EPA Report No.
440/1-84/073-VOL-l. June 1984.
U.S. EPA. Development Document for Effluent Limitations Guidelines and
Standards for the Aluminum Forming Point Source Category. EPA Report No.
440/1-84/073-VOL-2. June 1984.
U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Textile. Friction Materials and Sealing
Device? Segment of the Asbestos Manufacturing Point Source Category. EPA
Report No. 440/1-74/035-A. December 1974.
U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Building. Construction, and Paper Segment
of the Asbestos Manufacturing Point Source Category. EPA Report No. 440/1-
74/017-A. February 1974.
U.S. EPA. Development Document for Effluent Limitations Guidelines and
Standards for the Battery Manufacturing Point Source Category. EPA Report No.
440/1-84/067-VOL-l. September 1984.
U.S. EPA. Development Document for Effluent Limitations Guidelines and
Standards for the Battery Manufacturing Point Source Category. EPA Report No.
440/1-84/067-VOL-2. September 1984.
U.S. EPA. Development Document for Effluent Limitations Guidelines and
Standards for the Battery Manufacturing Point Source Category. EPA Report No.
440/1-82/067-B. October 1982.
U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Builders Paper and Roofing Felt Segment
of the Builders Paper and Board Mills Point Source Category. EPA Report No.
440/1-74/026-A. May 1974.
9/15/89 A-l
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APPENDIX A BIBLIOGRAPHY
U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Apple. Citrus and Potato Processing
Segment of the Canned and Preserved Fruits and Vegetables Point Source
Category. EPA Report No. 440/1-74/027-A. March 1974.
U.S. EPA. Development Document for Effluent Liaitations Guidelines and New
Source Performance Standards for the Fish Meal. Salmon. Bottom Fish. Clam.
Oyster. Sardine. Scallop. Herring, and Abalone S$gjen£ °^ the Canned and
Preserved Fish and Seafood Processing Industry Point Source Category. EPA
Report No. 440/1-75/041-A. September 1975.
U.S. EPA. Development Document for Effluent Limitations Guidelines and
Standards of Performance for the Catfish. Crab. Shrimp, and Tuna Segments of
the Canned and Preserved Seafood Processing Industry Point Source Category.
EPA Report No. 440/1-74/020-A. June 1974.
U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Cement Manufacturing Point Source
Category. EPA Report No. 440/1-74/005-A. January 1974.
U.S. EPA. Development Document for Final Effluent Limitations Guidelines. New
Source Performance Standards and Pretreatment Standards for the Coal Mining
Point Source Category. EPA Report No. 440/1-82/057. October 1982.
U.S. EPA. Development Document for Proposed Effluent Limitations Guidelines.
New Source Performance Standards and Pretreatment Standards for the Coal
Mining Point Source Category. EPA Report No. 440/1-81/0J7-B. January 1981.
U.S. EPA. Development Document for Effluent Limitations Guidelines and
Standards for the Canroaking Subcategorv of the Coil Coating Point Source
Category. EPA Report No. 440/1-83/071. April 1984.
U.S. EPA. Development Document for Effluent Limitations Guidelines and
Standards for the Coil Coating Point Source Category. E:3A Report No. 440/1-
82/071. November 1982.
U.S. EPA. Development Document for Effluent Limitations Guidelines and
Standards for the Coil Coating Point Source Category. El'A Report No. 440/1-
83/071-B. March 1983.
U.S. EPA. Development Document for Effluent Limitations Guidelines and
Standards for the Copper Forming Point Source Category. EPA Report No. 440/1-
84/074. March 1984.
U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Dairy Product Processing Point Source
Category. EPA Report No. 440/1-74/021-A. May 1974.
9/15/89 A-2
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APPENDIX A BIBLIOGRAPHY
U.S. EPA. Development Document for Effluent Limitations Guidelines and
Standards for the Electrical and Electronic Components Point Source Category.
EPA Report No. 440/1-83/075-B. February 1983.
U.S. EPA. Development Document for Effluent Limitations Guidelines and
Standards for the Electrical and Electronic Components Point Source Category.
EPA Report No. 440/1-82/075B. July 1982.
U.S. EPA. Development Document for Existing Source Pretreatraent Standards for
the Electroplating Point Source Category. EPA Report No. 440/1-79/003.
August 1979.
U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Copper. Nickel. Chromium, and Zinc
Segment of the Electroplating Point Source Category. EPA Report No. 440/1-
74/003-A. March 1974.
U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards -- Feedlots Point Source Category. EPA Report
No. 440/1-74/004-A. January 1974.
U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Smelting and Slag Processing Segments of
the Ferroalloy Manufacturing Point Source Category. EPA Report No. 440/1-
74/008-A. February 1974.
U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Formulated Fertilizer Segment of the
Fertilizer Manufacturing Point Source Category. EPA Report No. 440/1-75/042-
A. January 1975.
U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Basic Fertilizer Chemicals Segment of the
Fertilizer Manufacturing Point Source Category. EPA Report No. 440/1-74/011-
A. March 1974.
U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Pressed and Blown Glass Segment of the
Glass Manufacturing Point Source Category. EPA Report No. 440/1-75/034-A.
January 1975.
U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Insulation Fiberglass Manufacturing
Segment of the Glass Manufacturing Point Source Category. EPA Report No.
440/1-74/001-B. January 1974.
9/15/89 A-3
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APPENDIX A __ BIBLIOGRAPHY
U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Flat Glass Sag^ent of the Class
Manufacturing Point Source Category. EPA Report No. 440/1- 74/001 -C. January
1974.
U.S. EPA . Development DocuBynt f°r Effluent Limitations Guidelines and New
Source Performance Standards for the Animal Feed. Breakfast Cereal, and Wheat
Starch Segments of the Grain Mills Point Source Category. EPA Report No.
440/1 -74/039-A. December 1974.
U.S. EPA . Development Docuncnt for Effluent Limitations Guidelines and New
Source Performance Standards for the Grain Processing Segment of the Grain
Mills Point Source Category. EPA Report No. 440/1-74/028 -A. Karch 1974.
U.S. EPA. Development Document for Interim Final Effluent: Limitations.
Guidelines and Proposed New Source Performance Standards for the Hospital
Point Source Category. EPA Report No. 440/1 -76/060N. April 1976.
U.S. EPA . Development Document for Proposed Effluent Limitations Guidelines.
New Source Performance Standards and Pretreatment Standards for the Ink
Formulating Point Source Category. EPA Report No. 440/1 -79/090B. December
1979.
U.S. EPA. Development Document for Effluent Limitations Guidelines. New
Source Performance Standards and Pretreatment Standards for the Inorganic
Chemicals Manufacturing Point Source Category. Phase 2. KPA Report No. 440/1-
84/007. August 1984.
U.S. EPA . Development Document for Effluent Limitations Guidelines. New
Source Performance Standards and Pretreatment Standards for the Inorganic
Chemicals Manufacturing Point Source Category. EPA Report: No. 440/1-82/007.
June 1982.
U.S. EPA . Development Document for Proposed Effluent Limitations Guidelines.
New Source Performance Standards and Pretreataent Standards for the Inorganic
Chemicals Manufacturing Point Source Category. EPA Report No. 440/1 -80/007B.
June 1980.
U.S. EPA . Development Document f°r Effluent Limitations Cuidelinea and New
Source Performance Standards for the Major Inorganic Products Segaent of the
Inorganic Chemicals Manufacturing Point Source Category. EPA Report No.
440/1-74/007-A. March 1974.
U.S. EPA . Development Doymjynt for Effluent Limitations Guidelines. New
Source Performance Standards and Pretreatment Standards for the Iron and Steel
Manufacturing Point Source Category. EPA Report No. 440/1-82/024. May 1982.
9/15/89 A-4
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APPENDIX A BIBLIOGRAPHY
U.S. EPA. Development Docunent for Effluent Limitations Guidelines. New
Source Performance Standards and Pretreatment Standards for the Iron and Steel
Manufacturing Point Source Category. EPA Report No. 440/1-82/024-VOL-I. May
1982.
U.S. EPA. Development Document for Effluent Limitations Guidelines. New
Source Performance Standards and Pretreatnent Standards for the Iron and Steel
Manufacturing Point Source Category. EPA Report No. 440/1-82/024-VOL-II. May
1982.
U.S. EPA. Development Docunent for Effluent Limitations Guidelines. New
Source Performance Standards and Pretreatment Standards for the Iron and Steel
Manufacturing Point Source Category. EPA Report No. 440/1-82/024-VOL-III.
May 1982.
U.S. EPA. Development Docunent for Effluent Limitations Guidelines. New
Source Performance Standards and Pretreatment Standards for the Iron and Steel
Manufacturing Point Source Category. EPA Report No. 440/1-82/024-VOL-IV. May
1982.
U.S. EPA. Development Document for Effluent Limitations Guidelines. New
Source Performance Standards and Pretreatment Standards for the Iron and Steel
Manufacturing Point Source Category. EPA Report No. 440/1-82/024-VOL-V. May
1982.
U.S. EPA. Development Document for Effluent Limitations Guidelines. New
Source Performance Standards and Pretreatment Standards for the Iron and Steel
Manufacturing Point Source Category. EPA Report No. 440/1-82/024-VOL-VI. May
1982.
U.S. EPA. Development Document for Proposed Effluent Limitations Guidelines.
New Source Performance Standards and Pretreatnent Standards for the Iron and
Steel Manufacturing Point Source Category. EPA Report No. 440/1-80/024-B-V1.
December 1980.
U.S. EPA. Development Document for Proposed Effluent Limitations Guidelines.
New Source Performance Standards and Pretreatment Standards for the Iron and
Steel Manufacturing Point Source Category. EPA Report No. 440/1-80/024-B-V2.
December 1980.
U.S. EPA. Development Document for Proposed Effluent Limitations Guidelines.
New Source Performance Standards and Pretreatnent Standards for the Iron and
Steel Manufacturing Point Source Category. EPA Report No. 440/1-80/024-B-V3.
December 1980.
U.S. EPA. Development Docujnent for Proposed Effluent Limitations Guidelines,
New Source Performance Standards and Pretreatment Standards for the Iron and
Steel Manufacturing Point Source Category. EPA Report No. 440/1-80/024-B-V4.
December 1980.
9/15/89 A-5
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APPENDIX A BIBLIOGRAPHY
U.S. EPA. Development DoT'.UDfnt for Proposed Effluent Limitations Guidelines.
New Source Performance Standards and Pretreatnent Standards for the Iron and
Steel Manufacturing Point Source Category. EPA Report No. 440/1-80/024-B-V5.
December 1980.
U.S. EPA. Development Doc,vui¥,nT for Proposed Effluent Limitations Guidelines.
New Source Performance Standards and Pretreatment Standards for the Iron and
Steel Manufacturing Point Source Category. EPA Report No. 440/1-80/024-B-V6.
December 1980.
U.S. EPA. Development Document for Effluent Linitations Guidelines and New
Source Performance Standards for the Steel Making f?ftgije.nV P^ the Iron and
Steel Manufacturing Point Source Category. EPA Report No. 440/1-74/024-A.
June 1974.
U.S. EPA. Supplemental Development Document for Effluent Limitations
Guidelines and Standards for the Leather Tanning and Finishing Point Source
Category. EPA Report No. 440/1-88/016-S. February 1988.
U.S. EPA. Development Document for Effluent Limitations Guidelines and
Standards for the Leather Tanning and Finishing Point Source Category. EPA
Report No. 440/1-82/016. November 1982.
U.S. EPA. Development Doc|in|ent for Effluent Limitations Guidelines and New
Source Performance Standards for the Leather Tanning and Finishing Point
Source Category. EPA Report No. 440/1-74/016-A. March 1974.
U.S. EPA. Development Document for Effluent Linitations Guidelines and New
Source Performance Standards for the Renderer Segment of the Meat Products and
Rendering Processing Point Source Category. EPA Report No. 440/1-74/031-D.
January 1974.
U.S. EPA. Development Document for Effluent Linitations Guidelines and New
Source Performance Standards for the Red Meat Processing Sequent of the Meat
Product and Rendering Processing Point Source Category. EPA Report No. 440/1-
74/012-A. February 1974.
U.S. EPA. Development Document for Effluent Linitations Guidelines and
Standards for the Metal Finishing Point Source Category. EPA Report No.
440/1-83/091. June 1983.
U.S. EPA. Developnent Document for Proposed Effluent Liaitations Guidelines.
New Source Performance Standards for the Metal Finishing Point Source
Category. EPA Report No. 440/1-82/091B. August 1982.
U.S. EPA. Development Document for Effluent Limitations Guidelines and
Standards for the Metal Molding and Casting (Foundries). Point Source
Category. EPA Report No. 440/1-85/070. October 1985.
9/15/89 A-6
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APPENDIX A
BIBLIOGRAPHY
U.S. EPA . Development Do£Uj|yn,t for Interim Final Effluent Limitations
Guidelines and New Source Performance Standards for the Minerals for the
Ponstruction Industry Point Source Category. EPA Report No. 440/1-75/059.
October 1975.
U.S. EPA. Development Document for Final Effluent Limitations Guidelines and
New Source Performance Standards for the Mineral Mining and Processing Point
Source Category. EPA Report No. 440/1-76/059B. July 1979.
U.S. EPA . Development Docuuent for Effluent Limitations Guidelines and
Standards for the Nonferrous Metala Forming and Metal Powders: Point Source
Category. EPA Report No. 440/1-86/019. September 1986.
U.S. EPA . Development
Effluent Limitations Guidelines and
Standards for the Nonferrous Metals Forming and Metal Powders: Point Source
Category. EPA Report No. 440/1-86/019-1. September 1986.
U.S. EPA . Development Document for Effluent Limitations Guidelines and
Standards for the Nonferrous Metals Forming and Metal Powders: Point Source
Category. EPA Report No. 440/1-86/019-2. September 1986.
U.S. EPA . Development Document for Effluent Limitations Guidelines and
Standards for the Nonferrous Metals Forming and Metal Powders: Point Source
Category. EPA Report No. 440/1-86/019-3. September 1986.
U.S. EPA . Development Document for Effluent Limitations Guidelines and
Standards for the Nonferrous Metals Point Source Category. EPA Report No.
440/1-83/019-B-VOL-l. March 1983.
U.S. EPA . Development Document for Effluent Limitations Guidelines and
Standards for the Nonferrous Metals Point Source Category. EPA Report No.
440/1-83/019-B-VOL-2. March 1983.
U.S. EPA . Development Document for Effluent Limitations Guidelines and
Standards for the Nonferrous Metals Point Source Category. EPA Report No.
440/1-83/019-B-VOL-3. March 1983.
U.S. EPA . Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Primary AlujninVFP Smelting Subcategorv of
the Aluminum Segment of the Nonferrous Metals Manufacturing Point Source
Category. EPA Report No. 440/1 -74/019-D. March 1974.
U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Secondary Aluminum Smelting Subcategorv
of the Aluminum Segment of the Nonferrous Metala Manufacturing Point Source
Category. EPA Report No. 440/1-74/019-A. March 1974.
9/15/89
A-7
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APPENDIX A BIBLIOGRAPHY
U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Bauxite Refining Subcategory of the
Aluminum Segjpent of the Nonferrous Metals Manufacturing Point Source Category.
EPA Report No. 440/1-74/019-A. March 1974.
U.S. EPA. Development Doyujnent for Proposed Effluent Limitations Guidelines
and New Source Performance Standards for the Offshore Subcategory of the Oil
and Gas Extraction Point Source Category. EPA Report No. 440/1-85/055. July
1985.
U.S. EPA. Development Document for Proposed Effluent Limitations Guidelines
and New Source Performance Standards for the Ore Mining and Dressings Point
Source Category. EPA Report No. 440/1-82/061B. May 1982.
U.S. EPA. Development Document for Effluent Limitations and Guidelines for
the Ore Mining and Dressing Point Source Category. EPA Report No. 440/1-
78/061D. July 1978.
U.S. EPA. Development Document for Effluent Limitations and Guidelines for
the Ore Jlining and Dressing Point Source Category. EPA Report No. 440/1-
78/061E. July 1978.
U.S. EPA. Development Document for Jlffluent Imitations Guidelines and
Standardjs for the Organic ChemicalsL Plastics and Synthetic Fibers. EPA
Report No. 440/1-87/009. October 1987.
U.S. EPA. Development Document for Proposed Effluent Linitations^Guidelines
and New Source Performance Standards for the Organic Chemicals and Plastics
and Synthetic Fibers Industry. Point Source Category. EPA Report No. 440/1-
83/009B-VOL-1. February 1983.
U.S. EPA. Development Document for Proposed Effluent Limitations Guidelines
and New Source Performance Standards for the Organic Chemicals and Plastics
and Synthetic Fibers Industry. Point Source Category. EPA Report No. 440/1-
83/009B-VOL-2. February 1983.
U.S. EPA. Development Document for Proposed Effluent Limitations Guidelines
and New Source Performance Standards for the Organic Chemicals and Plastics
and Synthetic Fibers Industry. Point Source Category. EPA Report No. 440/1-
83/009B-VOL-3. February 1983.
U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Major Organic Products Segjent of the
Organic Chemicals Manufacturing Point Source Category. EPA Report No. 440/1-
74/009-A. April 1974.
Standards for the Pesticide Point Source Category. EPA Raport No. 440/1-
85/079. October 1985.
9/15/89 A-8
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APPENDIX A BIBLIOGRAPHY
U.S. EPA. Development Document for Expanded Best Practicable Control
Technology. Best Conventional Pollutant Control Technology. Best Available
Technology. New Source Performance Technology, and Pretreatment Technology in
the Pesticide Chemicals Industry. EPA Report No. 440/1-82/079B. November 7
1982.
U.S. EPA. Development Document for Effluent Limitations Guidelines for the
Pesticide Chenicals Manufacturing Point Source Cateeorv. EPA Report No.
440/1-78/060E. April 1978.
U.S. EPA. Development Document for Effluent Limitations Guidelines. New
Source Performance Standards and Pretreatment Standards for the Petroleum
Refining Point Source Category. EPA Report No. 440/1-82/014. October 1982.
U.S. EPA. Development Document for Proposed Effluent Limitations Guidelines.
New Source Performance Standards and Pretreatment Standards for the Petroleum
Refining Point Source Category. EPA Report No. 440/1-79/014-B. December
1979.
U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Petroleum Refining Point Source Category.
EPA Report No. 440/1-74/014-A. April 1974.
U.S. EPA. Development Document for Final Best Conventional Technology
Effluent Limitations Guidelines for the Pharmaceutical Manufacturing Point
TSource Category. EPA Report No. 440/1-86/084. December 1986.
U.S. EPA. Development Document for Final Effluent Limitations Guidelines. New
Source Performance Standards and Pretreatment Standards for the Pharmaceutical
Manufacturing Point Source Category. EPA Report No. 440/1-83/084. September
1983.
U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Phosphorus Derived Chemicals Segment of
the Phosphate Manufacturing Point Source Category. EPA Report No. 440/1-
74/006-A. January 1974.
U.S. EPA. Development Document for Effluent Limitations Guidelines and
Standards for the Plastics Molding and Forming Point Source Category. EPA
Report No. 440/1-84/069. December 1984.
U.S. EPA. Development Document for Effluent Limitations Guidelines and
Standards for the Plastics Molding and Forming Point Source Category. EPA
Report No. 440/1-84/069-B. February 1984.
U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Synthetic Polymer Segment of the Plastics
and Synthetic Materials Manufacturing Point Source Category. EPA Report No.
440/1-75/036-B. January 1975.
9/15/89A^9
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APPENDIX A BIBLIOGRAPHY
U.S. EPA . Development DgtUBCnt for Effluent Limitations Guidelines and New
Source Performance Standard* for the Synthetic Resins Sagaant of the Plastics
and Synthetics Materials Manufacturing Point Source Category. EPA Report No.
440/1-74/010-A. March 1974.
U.S. EPA. Development Dpc.uje.nt for Proposed Effluent Limitations Guidelines
and Standards for the Porcelain flnajfl] ing Point Source Category. EPA Report
No. 440/1 -81/072B. January 1981.
U.S. EPA. Development Document for Best Conventional Pollutant Control
Technology Effluent Limitations Guidelines for the Pulp. Paper, and Paoerboard
and the Builders' Paper and Board Mills Point Source Categories. EPA Report
440/1-86/025. December 1986.
U.S. EPA . Development Ppgujent for Effluent Limitations Guidelines. New
Source Performance Standards and Pre treatment Standards for the Pulp. Paper.
and Paperboard and the Builders' Paper and Board Mills Point Source Category.
EPA Report No. 440/1-82/025. October 1982.
U.S. EPA . Development Document for Proposed Effluent Limitations Guidelines
and Standards for the Pulp. Paper and Paperboard and the Builders' Paper and
Board Mills Point Source Categories. EPA Report No. 440/1-80/025B. December
1980.
U.S. EPA . Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Unbleached Kraft and Semichemical Pulp
Segment of the Pulp. Paper, and Paperboard Mills Point Source Category . EPA
Report No. 440/1-74/025-A. May 1974.
U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Fabricated and Reclaimed Rubber Segment
of the Rubber Processing Point Source Category. EPA Report No. 440/1-74/030-
A. December 1974.
U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Tire and Synthetic Segment of the Rubber
Processing Point Source Category. EPA Report No. 440/1-74/013-A. February
1974.
U.S. EPA . Development Document for Effluent Limitations Guidelines and New
Source Performance Standards Soap and Detergent Manufacturing Point Source
Category. EPA Report No. 440/1-74/018-A. April 1974.
U.S. EPA . Development Document for Proposed Effluent Limitations Guidelines.
New Source Performance Standards and Pre treatment Standards for the Steam
Electric Point Source Category. EPA Report No. 440/1 -80/D29B. September
1980.
9/15/89 A-10
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APPENDIX A BIBLIOGRAPHY
U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Steam Electric Power Generating Point
Source Category. EPA Report No. 440/1-74/029-A. October 1974.
U.S. EPA. Development Dot'.yaent for Effluent Limitations Guidelines and New
Source Performance Standards for the Cane Sugar Refining Segment of the Sugar
Processing Point Source Category. EPA Report No. 440/1-74/002-C. March 1974.
U.S. EPA. Development Docujent for Effluent Limitations Guidelines Standards
of Performance for New Sources. Beet Sugar Processing Subcategory of the
Sugar Processing Point Source Category. EPA Report No. 440/1-74/002-B.
January 1974.
U.S. EPA. Development Document for Effluent Limitations Guidelines and
Standards for the Textile Mills Point Source Category. EPA Report No. 440/1-
82/022. September 1982.
U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Textile Mills Point Source Category. EPA
Report No. 440/1-74/022-A. June 1974.
U.S. EPA. Development Document for Effluent Limitations Guidelines. New
Source Performance Standards and Pretreatment Standards for the Timber
Products Processing Point Source Category. EPA Report No. 440/1-81/023.
January 1981.
U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Plywood. Hardboard and Wood Preserving
Segment of the Timber Products Processing Point Source Category. EPA Report
No. 440/1-74/023-A. April 1974.
U.S. EPA. Development of Case-by-Case Discharge Permits Under the NPDES and
Pretreatment Programs (Draft). U.S. EPA, Region 8. October 1986.
U.S. EPA. Development of Industrial User Permits Under the Pretreatment
Program (Draft). U.S. EPA, Region 8. August 1985.
U.S. EPA. FY 1990 Guidance for Reporting and Evaluating POTW Noncoapliance
With Pretreatnent Requirements. September 1989.
U.S. EPA. Guidance for Implementing Permit-bv-Rule Requirements at POTWs.
Draft. November 1987.
U.S. EPA. Guidance Manual for Battery Manufacturing Pretreatroent Standards.
August 1987.
U.S. EPA. Guidance Control for Control of Slug Loadings to POTW's.
September 1988.
9/15/89 A-11
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APPENDIX A __ BIBLIOGRAPHY
U.S. EPA . Guidance Manual for Electroplating and Metal Finishing
Pretreatment Standards. February 1984.
U.S. EPA . Guidance Manual for Implementing Total Toxic 0:rganics (TTO)
Pretreatment Standards. Permits Division, September 1985.
U.S. EPA . Guidance Manual for Iron and Steel Manufacturing Pretreatment
Standards. September 1985.
U.S. EPA . Guidance Manual for Leather Tanning and Finishing Pretreatment
Standards . September 1986.
U.S. EPA . Guidance Manual for PQTW Pretreataent Program Development .
October 1983.
U.S. EPA. Guidance Manual for Preventing Interference at POTWs . Prepared for
U.S. EPA by James M. Montgomery, Consulting Engineers, Inc. under Contract No.
68-03-1821. September 1987.
U.S. EPA . Guidance Manual for Pulp Paper, and Paperboard and Builder's Paper
and Board Mills Pretreatment Standards. July 1984.
U.S. EPA . Guidance Manual for the Development of an Accidental Spill
Prevention Program. Prepared for U.S. EPA, Region 10, by Science Applications
International Corporation under Contract No. 68-01-7043. February 1986.
U.S. EPA . Guidance Manual for the Identification of Hazardous Waste Delivered
to Publicly Owned Treatment Works bv Truck. Rail, or Dedicated Pipeline.
Draft, April 1987.
U.S. EPA . Guidance Manual for the Use of Production-Based Pretreatment
Standards and the Combined Wastestream Formula. September 1985.
U.S. EPA . Guidance Manual on the Development and Implementation of Local
Discharge Limitations Under the Pretreatment Program. December 1987.
U.S. EPA. "Guidelines Establishing Test Procedures for the Analysis of
Pollutants Under the Clean Water Act, Final Rule, and Interim Final Rule, and
Proposed Rules." 40 CFR Part 136. Federal Register. 4? FR 43234, October
26, 1984; 50 FR 690, January 4, 1985; 51 FR 23693, June 20. 1986; and, 52 FR
33543, September 3, 1987.
U.S. EPA . Handbook for Sampling and Sample Preservation of Water and
Wastewater. EPA Report No. 600/4-82-029. September 198',:. (NTIS No.
PB83-124503).
U.S. EPA . Industrial Pretreatment Prygf-ap Inspection Manual (Draft) . U.S.
EPA Region 8. November 1984.
9/15/89 A-12
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APPENDIX A BIBLIOGRAPHY
U.S. EPA. NPDES Best Management Practices Guidance Document. June 1981.
U.S. EPA. NPDES Compliance Inspection Manual. Hay 1988.
U.S. EPA. Pretreatnent Compliance Monitoring and Enforcement Guidance.
September 1986.
U.S. EPA. Pretreataent Facility Inspection. Prepared for U.S. EPA by
California State University, Sacramento, CA under Assistance ID No. CT-
901589-01-D. 1988.
U.S. EPA. RCRA Information on Hazardous Wastes for Publicly Owned Treatment
Works. September 1985.
U.S. EPA. RCRA Orientation Manual. EPA Report No. 530-SW-86-001.
January 1986.
U.S. EPA. Training Manual for NPDES Permit Writers. September 1986.
U.S. EPA. Treatabilitv Manual. Volumes I. II. III. IV. and V. EPA Report No.
600/2-82-001.
9/15/89 A-13
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APPENDIX A BIBLIOGRAPHY
PUBLICATIONS ORDERING INFORMATION
Publications of Development Documents that are "final" can be obtained by
purchasing them from either of the following resources:
U.S. Government Printing Office
Attn: Superintendent of Documents
Washington, D.C. 20402
Order Desk Phone Number: (202) 783-3238
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22151
Sales Desk Phone Number: (703) 487-4600
(NTIS Access Number is required when ordering)
Requests for publications that have been prepared or distributed by the
Industrial Technology Division, but are not "final", are available in limited
supply from EPA by writing to:
Mary Platt
Office of Water Regulations and Standards
Environmental Protection Agency
Industrial Technology Division
401 M Street, S.W.
Washington, D.C. 20460
Phone Number: (202) 382-7113
Pretreatment Guidance Documents that have been prepared by EPA Headquarters
are availabe in limited supply from EPA by writing to:
John Hopkins
Office of Water Enforcement Permits
Permits Division (EN-336)
401 M Street, S.W.
Washington, D.C. 20460
Phone Number: (202) 475-9532
Pretreatment Guidance Documents that have been prepared by EPA Regions or
States may be available in limited supply by contacting the Regional or State
Pretreatment Coordinator.
9/15/89 A-14
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APPENDIX B
LIST OF STATE AND EPA PRETREATMENT COORDINATORS
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APPENDIX B
PRETREATMENT COORDINATORS
U.S. EPA Headquarters and Regional Contacts - 1989
EPA Regional Contacts
Region Address
1 U.S. Environmental Protection Agency
Region 1
Water Division
Permits Compliance Section
Room 2103
John F. Kennedy Federal Building
Boston, MA 02203
(617)565-3490
Contact and Phone
Mr. John (Jack) Stoecker
(WCC2103)
Environmental Engineer
(617)565-3492
Ms. Joan Serra
Environmental Engineer
General Regional Information
(617)565-3400
U.S. Environmental Protection Agency
Region 2
26 Federal Plaza
Room 845A
New York, NY 10278
Mr. Phil Sweeney (2WM-WPC)
Chief, Permits Management
Section
(212)264-2676
Mr. John S. Kushwara
Pretreatment Compliance
Coordinator
(212)264-9826
General Regional Information
(212)264-2525
U.S. Environmental Protection Agency
Region 3
841 Chestnut Building
Philadelphia, PA 19107
General Regional Information
(212)597-9800
Mr. John Lovell (3WM-50)
Pretreatment Coordinator
(215)597-6279
9/15/89
B-l
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APPENDIX B
PRETREATMENT COORDINATORS
Region Address
4 Water Management Division
Facilities Performance Branch
U.S. Environmental Protection Agency
Region 4
345 Courtland Street, N.E.
Atlanta, GA 30365
Contact and Phone
Mr. Albert Herndon (4WM-FP)
Chief, Pretreatnent (O&MUnit)
(404)347-2211
General Regional Information
(404)881-4727
U.S. Environmental Protection Agency
Region 5
230 Dearborn Street
Chicago, IL 60604
ALL FEDERAL EXPRESS
111 V. Jackson Street
8th Floor
Chicago, IL 60604
Mr. Dave Rankin (WQP-TUB-8)
Pretreatment Coordinator
(312)386-6111
Gener.il Regional Information
(312)353-2000
U.S. Environmental Protection Agency
Region 6
1445 Ross Avenue
Dallas, TX 75202
Mr. Lee Bonne (6V-PM)
Regional Pretreatment
Coordinator
(214)655-7175
Mr. Bob Goodfellow (6W-EO)
Enforcement Coordinator
(214)655-6470
General Regional Information
(214)767-2600
U.S. Environmental Protection Agency
Region 7
726 Minnesota Avenue
Kansas City, KS 66101
Mr. Lee Duvall (WACM)
Pretreatment Coordinator
(913)236-2817
Mr. Paul Marshall (UACM)
Environmental Engineer
(913)236-2817
General Regional Information
(913)236-2800
9/15/89
B-2
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APPENDIX B
PRETREATMENT COORDINATORS
Region Address
8 U.S. Environmental Protection Agency
Region 8
1 Denver Place
999 18th Street, Suite 500
Denver, CO 80202-2405
Contact and Phone
Mr. Marshall Fischer(8WM-C)
Industrial Pretreatment
Progran Coordinator
(303)293-1592
Ms. Dana Allen (8WM-C)
Associate Industrial
Pretreatnent Program
Coordinator
(303)293-1593
General Regional Information
(303)293-1603
U.S. Environmental Protection Agency
Region 9
215 Fremont Street
San Francisco, CA 94105
Mr. Frank Laguna (W-5-2)
Pretreatnent Coordinator
(415)974-8298
Ms. Juliet Hannafin
(W-4-1)
Pretreatment Compliance
Coordinator
(415)974-7271
General Regional Information
(415)974-8071
10 U.S. Environmental Protection Agency
Region 10
Permits Branch
1200 Sixth Avenue
Seattle, VA 98101
Mr. Robert Robichaud
(M/S 521)
Pretreatnent Coordinator
(206)442-1448
General Regional Information
(206)442-5810
9/15/89
B-3
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APPENDIX B
PRETREATMENT COORDINATORS
EPA Headquarter* Contact!
Address
U.S. Environnental Protection Agency
Office of Water Enforcement and Permits
401 M Street, S.W.
Washington, D.C. 20460
Contact and Phone
Mr. Janes R. Elder (EN-335)
Director, Office of Water
Enforcement: and Permits
Room 220, N.K. Mall
(202)475-8488
Permits Division
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Ms. Cynthia Dougherty (EN-336)
Director, Permits Division
Room 214, N.3. Mall
(202)475-9543
Mr. Ephraim King (EN-336)
Chief, Program Implementation Branch
Room 211, N.E. Mall
(202)475-953?
Mr. Jeffrey tape (EN-336)
Chief, Program Section
Room 212, N.E. Mall
(202)475-9525
Enforcement Division
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Mr. Richard Kozlowski (EN-338)
Director, Enforcement Division
Room 216, N.E. Mall
(202)475-8304
9/15/89
B-4
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APPENDIX B
PRETREATMENT COORDINATORS
Address
Contact and Phone
Industrial Technology Division
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Mr. Thomas P. O'Farrell (WH-552)
Director, ITD
Room £911C
(202)382-7120
Mr. Emst P. Hall (WH-552)
Chief, Metala Industry Branch
Room E905C
(202)382-7126
Mr. Marvin Rubin (WH-552)
Chief, Chemicals Branch
Room E901C
(202)382-7124
Office of General Counsel
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Ms. Ruth Bell (LE-132W)
Asst. General Counsel
Office of General Counsel -
Water Division
Room W503
(202)382-7706
9/15/89
B-5
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APPENDIX B
PRETREATMENT COORDINATORS
State
REGION 1
CT
MA
ME
NH
RI
STATE PRETREATMENT CONTACTS
Address Contact and Phone
Department of Environmental
Protection
Division of Water Compliance
122 Washington Street
Hartfort, CT 06106
Department of Environmental
Quality and Engineering
Division of Water Pollution Control
1 Winter Street
Boston, MA 02108
Department of Environmental
Protection
21 Vocational Drive
South Portland, ME 04106
Department of Environmental
Services
Water Supply and Pollution Control
Division
P.O. Box 95
Concord, NH 03301
Department of Environmental
Management
Water Resources Division
Permits and Planning Section
291 Promenade Street
Providence, RI 02908
Mr. Mike Harder
Assistant Director
(203)5l>6-3245
Mr. Janes Grier
Principal Sanitary Engineer
(203)57-4761
Mr. Dan Allen
Supervisor, Industrial
Pretreatment Program
(603)2/1-2052
Ms. Christine Volkay-Hilditch
Sanitary Engineer
(401)2/7-6519
Ms. Eileen Gleber
Senior Environmental Scientist
(401)277-6519
Ms. Gina Natale-Friedman
Junior Environmental Engineer
(401)277-6519
9/15/89
B-6
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APPENDIX B
PRETREATMENT COORDINATORS
State Address
REGION 1 (Continued)
VT Agency of Natural Resources
Department of Environmental
Conservation
103 S. Maine Street
Waterbury, VT 05676
Contact and Phone
Mr. Gary Shokes
Environmental Engineer
(802)244-5674
REGION 2
NJ
NY
Department of Environmental
Protection
Division of Water Resources
Office of Sludge Management and
Industrial Pretreatment
401 E. State Street (CN-029)
Trenton, NJ 08625
State Department of Environmental
Conservation
50 Wolf Road
Albany, NY 12233-0001
Ms. Mary Jo Aiello
Chief - Industrial
Pretreatment Section
(609)633-3823
Mr. Robert Cronin
Chief, Compliance Section
Room 320
(518)457-3790
Mr. Angus Eaton
Senior Sanitary Engineer
Room 318
(518)457-6716
Mr. Robert E. Townsend
Senior Sanitary Engineer
Room 320
(518)457-3790
REGION 3
DE
Department of Natural Resources and
Environmental Control
Edward Tatnell Building
89 Kings Highway
P.O. Box 1401
Dover, DE 19901
Mr. Paul Janiga
Environmental Engineer
Water Resources Section
(302)736-5731
Mr. Frank Henshaw
Environmental Engineer
Point Source Control Program
(302)736-3829
9/15/89
B-7
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APPENDIX B
PRETREATMENT COORDINATORS
State Address
REGION 3 (Continued)
ND Department of the Environment
Pretreataent Division
State of Maryland
2500 Broening Highway
Baltimore, HD 21224
PA Bureau of Water Quality Management
Department of Environmental
Resources
P.O. Box 2063
Harrisburg, PA 17120
VA State Water Control Board
Office of Engineering Application
P.O. Box 11143
2111 N. Hamilton Street
Richmond, VA 23230
WV Department of Natural Resources
1201 Greenbrier Street
Charleston, WV 25311
Contact and Phone
Ms. Karen Irons
Chief, Pretreatment Division
(301)333-7480
Mr. Gary Kelman
Section Head, Pretreatment
Division
(301)333-7480
Mr. Tim Carpenter
Chief, Operation Section
Division of Sewerage & Grants
(717)737-8184
Mr. Peter Slack
Chief, Permits Section
(717)7*7-8184
Ms. LaVern Corkran
Pretrentment Program Director
(804)367-6313
Mr. Donald Richwine
Prograii Manager
(804)3(57-6389
Mr. Pravin Sangani
Engineer
(304)3'»8-4086
Mr. Dave Montali
Engineur
(304)348-4086
REGION 4
AL
Department of Environmental
Management
Water Division
State Office Building
1751 Federal Drive
Montgomery, AL 36130
Mr. John Pool
Chief, Industrial Branch
(205)271-7700
Mr. Curt Johnson
Environmental Engineer II
(205)271-7700
9/15/89
B-8
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APPENDIX B
PRETREATMENT COORDINATORS
State Address
REGION 4 (continued)
FL Facilities Planning Section
Department of Environmental
Regulations
Twin Towers Office Building
2600 Blair Stone Road
Tallahassee, FL 32301
GA Water Quality Control
Environmental Protection Division
Department of Natural Resources
205 Butler Street, E. Tower
Atlanta, GA 30334
KY Permit Review Branch
Division of Water
Natural Resources and Environmental
Protection Cabinet
18 Reilly Road
Frankfort, KY 40601
MS Department of Natural Resources
Bureau of Pollution Control
P.O. Box 10385
Jackson, MS 39209
NC Department of Natural Resources
and Community Development
P.O. Box 27687
512 North Salisbury Street
Raleigh, NC 27611-7687
Contact and Phone
Mr. Noel Jack
(904)488-8163
Mr. Alan Hallun
Manager Municipal Permitting
Program
(404)656-7400
Mr. Michael Welch
Pretreatment Coordinator
(502)564-3410
Mr. Louis Lavallee
Chief, Pretreatment Section
(601)961-5171
Mr. Doug Finan
Supervisor
Pretreatnent Unit
(919)733-5083
Mr. Nile Testerman
Environmental Engineer
(919)733-5083
Ms. Dana Folley
Environmental Scientist
(919)733-5083
MB. Suzanne Hoover
Environmental Scientist
(919)733-5083
9/15/89
B-9
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APPENDIX B
PRETREATMENT COORDINATORS
State Address
REGION A (Continued)
SC
TN
Department of Health and
Environmental Control
2600 Bull Street
Columbia, SC 29201
Department of Health and
Environment
Division of Water Polution Control
150 9th Avenue North
Terra Building, 2nd Floor
Nashville. TN 37219-5405
Contact and Phone
Mr. Russ Sherer
Domestic Uastewater Division
(803)734-5296
Mr. Brian Rivers
Pretreatment Coordinator
(803)734-5319
Mr. Ro,;er Leemasters
Pretre.itment Coordinator
(615)7-*1-0633
Mr. Ro^er Slayden
(615)741-0633
Mr. Scott Crabtree
(615)7^1-0633
REGION 5
IL
IN
MI
Division of Water Pollution Control
Illinois Environmental Protection
Agency
2200 Churchhill Road
Springfield, IL 62706
Department of Environmental
Management
Office of Water Management
105 South Meridian
Indianapolis, IN 46225
Department of Natural Resources
P.O. Box 30028
Lansing, MI 48909
Ms. Candy Morin
Pretreatment Coordinator
Permits Section
(217)782-0610
Mr. Phil Preston
Indiana Pretreatment
Coordinator
(317)23:>-8728
Mr. Paul Blakeslee
Pretreatment Coordinator
Industrial Pretreatment
Program
(517)372-4624 & 4625
9/15/89
B-10
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APPENDIX B
PRETREATMENT COORDINATORS
State Address
REGION 5 (continued)
Contact and Phone
MN
OH
WI
Pollution Control Agency
Water Quality Division
520 Lafayette road, North
St. Paul, MN 55155
Ohio Environmental Protection Agency
1800 Watermark Drive
P.O. Box 1049
Columbus, OH 43266-0149
Department of Natural Resources
P.O. Box 7921
Madison, WI 53707
Mr. Randy Dunnette
Pretreatment Coordinator
(612)296-8006
Mr. John Albrecht
Supervlsor-Pretreatment Unit
(614)644-2028
Mr. Stan Klelnert
Chief, Permit and Pretreatment
Section
(608)267-7635
Mr. Randy Case
Pretreatment Unit Leader
(608)267-7639
REGION 6
AR
LA
NM
OK
Department of Pollution Control
and Energy
8001 National Drive
Little Rock, AR 72009
Department of Environmental Quality
Office of Water Resources
Water Pollution Control Division
P.O. Box 44091
Baton Rouge, LA 70804-4091
Environmental Improvement Division
Surface Water Quality Bureau
P.O. Box 968
Santa Fe, NM 87504-0968
State Department of Health
1000 N.E. 10th Street
Oklahoma City, OK 73152
Ms. Donna Parks
Pretreatment Coordinator
Enforcement Division
(501)562-7444
Ms. Barbara Romanowski
Regulations Unit Coordinator
(504)342-6363
Ms. Ann Young
Environmental Scientist
(505)827-2796
Mr. Ted Williamson
Pretreatment Engineer
(405)271-7335
9/15/89
B-ll
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APPENDIX B
PRETRZATMENT COORDINATORS
State Address
REGION 6 (Continued)
TX Water Commission
1700 North Congress
P.O. Box 13087
Capital Station
Austin, TX 78711-3087
Contact .md Phone
Ms. Ann McGinley
Chief, Uastewater Permits
Section
(512)463-7788
Mr. Randy Palachek
Environmental Scientist
(512)463-8420
REGION 7
IA
KS
MO
NE
Department of Natural Resources
Henry A. Wallace Building
900 East Grand
Des Moines, IA 50319
Department of Health and
Environment
Water Pollution Control Section
6700 S. Topeka Blve.
Building 740 - Forbes Field
Topeka, KS 66620
Department of Natural Resources
Division of Environmental Quality
P.O. Box 176
Jefferson City, MO 65101
Department of Environmental
Control
Water Pollution Control Division
Box 94877, Statehouse Station
301 Centennial Mall, South
Lincoln, NE 68509
Mr. Steve Williams
Environmental Specialist
Wastewater Permits Branch
(515)281-8884
Mr. Don Carlson
Chief. Industrial Unit
(913)296-1500
Mr. Steve Casper
Environmental Technician
(913)296-5551
Mr. Elborn Mendenhall
Chief, Pretreatment Unit
(913)296-5552
Mr. Richard Kuntz
Environmental Engineer
(314)751-6996
Mr. Jay Ringenberg
Environmental Specialist
(402)471-2186
Mr. Jim Yeggy
Pretreatment Coordinator
Environmental Specialist
(402)471-4239
9/15/89
B-12
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APPENDIX B
PRETREATMENT COORDINATORS
State
REGION 8
CO
MT
ND
SD
UT
WY
Address
Department of Health
Water Quality Control Division
4210 E. llth Avenue
Denver, CO 80220
Water Quality Bureau
Department of Health
CapltoL Station
Helena, MT 59601
State Department of Health
1200 Missouri Avenue
Bismarck, ND 58505
Department of Water and Natural
Resources
Foss Building, Room 416
Pierre, SD 57501
Department of Health
Division of Environmental Health
Water Pollution Control
P.O. Box 16690
Salt Lake City, UT 84116-0690
Department of Environmental
Quality
122 West 25th Street
Cheyenne, WY 82002
Contact and Phone
Mr. Phil Hegeman
Industrial Pretreatment
Coordinator
(303)331-4564
Mr. Fred Shewman
Sanitary Engineer
(406)444-2406
Ms. Sheila McClenathen
Permits
(701)224-4578
Mr. Brad Archibald
Natural Resource Engineer
(605)773-3351
Ms. Mary Koltenuk
Pretreatment Coordinator
(801)538-6146
Mr. John Wagner
Technical Supervisor
Water Quality Division
(307)777-7781
REGION 9
AZ
Department of Environmental
Quality
Office of Water Quality
2655 E. Magnolia
Phoenix, AZ 85034
Mr. Charles Ohr
Quality Assurance Officer
(602)392-4003
9/15/89
B-13
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APPENDIX B
PRETREATMENT COORDINATORS
State Address
REGION 9 (Continued)
CA State Water Resource Control Board
901 P Street
Box 100
Sacramento, CA 95801
HI State Department of Health
P.O. Box 3378
Honolulu, HI 96801
NV Department of Environmental
Protection
201 S. Fall Street
Capitol Complex
Carson City, NV 89710
Contact and Phone
Mr. Scott McFarland
Water Resource Control
Engineer
Division of Water Quality
(916)223-1033
Mr. Charley Oumi
Chief of NPDES Section
(808)548-6410
Mr. Jce Livak
Pretreatment Coordinator
(702)885-4670
REGION 10
OR
WA
Department of Environmental
Quality
Executive Building
811 Southwest 6th Avenue
Portland, OR 97204
State Department of Ecology
Mail Stop PV-11
Olympia, WA 98504
Mr. John Harrison
Supervisor, Source Control
(503)229-5371
Mr. Joe Subsits
Pretreatment Coordinator
(206)438-7777
General Information
(206)459-6000
9/15/89
B-14
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APPENDIX C
GLOSSARY OF TERMS
-------
APPENDIX C
GLOSSARY OF TERMS
This glossary includes a collection of some of the terms used in this manual
and an explanation of each tern. To the extent that explanations provided in
this glossary differ from those in EPA regulations or other official
documents, they are intended for use in understanding this manual only.
Approval Authority - The Director in an NPDES state with an approved State
Pretreatment Program and the appropriate EPA Regional Administrator in a
non-NPDES State or NPDES State without an approved State pretreatment program
[40 CFR 403.3(c)].
Baseline Monitoring Report (BMR) - A report submitted by categorical
industrial users within 180 days after the effective date of an applicable
categorical standard which indicates the compliance status of the user with
the categorical standard (40 CFR 403.12(b)].
Best Professional Judgment (BPJ) - The highest quality technical opinion of a
permit writer, after consideration of all reasonably available and pertinent
data or information, forming the basis for the terms and conditions of a
permit.
Categorical Pretreatment Standards - Limitations on pollutant discharges to
POTWg promulgated by EPA in accordance with Section 307 of the Clean Water
Act, that apply to specified process wastewaters of particular industrial
categories [40 CFR 403.6 and Parts 405-471).
Categorical Industrial User - An industrial user subject to categorical
pretreatment standards.
Clean Water Act (CWA) - (Otherwise known as the Federal Water Pollution
Control Act) enacted by Public Law 92-500, October 18, 1972, 33 USC 1251 et
seq: as amended by PL 95-217, December 28, 1977; PL 97-117, December 29, 1981;
PL 97-440, January 8, 1983; and PL 100-04, February 4, 1987.
Combined Vastestream Formula (CVF) - Procedure for calculating alternative
discharge limits at industrial facilities where a regulated wastestream from a
categorical industrial user is combined with other wastestreams prior to
treatment [40 CFR 403.6(e)].
Concentration Limit - A limit based on the mass of pollutant per unit volume,
usually expressed in milligrams per liter.
Control Authority - A POTW with an approved pretreatment program or the
Approval Authority in the absence of a POTW pretreatment program [40 CFR
403.12 (a)].
9/15/89 C-l
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APPENDIX C __ GLOSSARY OF TERMS
Conventional Pollutants - As defined by Federal law, these include BOD, TSS,
fecal coliform bacteria, oil and grease, and pH [40 CFR 401.16].
Daily Maximum Limit - The maximum allowable discharge of pollutant during a
calendar day. Where daily maximum limitations are expressed in units of mass,
the daily discharge is the total mass discharged over the course of the day.
Where daily maximum limitations are expressed in terms of a concentration, the
daily discharge is the arithmetic average measurement of :he pollutant
concentration derived from all measurements taken that day.
Development Document - Detailed report of studies conducted by the U.S. EPA
for the purpose of developing categorical pretreatment standards.
Dilute Vastestream - For purposes of the combined wastestream formula, the
average daily flow (at least a 30-day average) from: (a) boiler blowdown
streams, non-contact cooling streams, storm water streams, and demineralizer
backwash streams (provided, however, that where such stre.uns contain a
significant amount of a pollutant, and the combination of such streams, prior
to treatment, with an industrial user's regulated process wastestream(s) will
result in a substantial reduction of that pollutant, the Control Authority,
upon application of the industrial user, may exercise its discretion to
determine whether such stream(s) should be classified as diluted or
unregulated. In its application to the Control Authority, the industrial user
must provide engineering, production, sampling and analysis, and such other
information so that the Control Authority can make its determination) ; or (b)
sanitary wastestreams where such streams are not regulated by a categorical
pretreatment standard; or (c) from any process wastestreams which were, or
could have been, entirely exempted from categorical pretreatment standards
pursuant to paragraph 8 of the NRDC v. Costle Consent Decree (12 ERC 1833) for
one or more of the following reasons (see Appendix D of 40 CFR 403):
a. The pollutants of concern are not detectable In the effluent from the
Industrial user [paragraph(S) (a) (111) ]
b. The pollutants of concern are present only In trace amounts and are
neither causing nor likely to cause toxic effects [paragraph
c. The pollutants of concern are present in amounts too small to be
effectively deduced by technologies known to the Administrator
[paragraph (8)(a)(ill)] ; or
d. The wastestream contains only pollutants which are compatible with the
POTW [paragraph (8)(b)(i)] [40 CFR 403. 6(e)].
Director - The chief administrative officer of a State or Interstate water
pollution control agency with an NPDES permit program and state pretreatment
program approved pursuant to Section 402 (b) of the Clean Water Act.
9/15/89 C-2
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APPENDIX C GLOSSARY OF TERMS
Plov Proportional Composite Sample - A sampling nethod which combines discrete
aliquots of a sample collected over time, based on the flow of the wastestream
being sampled. There are two methods used to collect this type of sample.
One method collects a constant sample volume at time intervals which vary
based on the stream flow [e.g., 200 milliliters (nl) sample collected for
every 5,000 gallons discharged]. The other method collects aliquots of
varying volume, based on stream flow, at constant time intervals.
Flow Weighted Averaging Formula (FVA) - A procedure used to calculate
alternative limits where wastestreams regulated by a categorical pretreatment
standard and nonregulated wastestreams combine after treatment but prior to
the monitoring point.
Grab Sample - A sample which is taken from a waste stream on a one-time basis
with no regard to the flow of the waste stream and without consideration of
time.
Indirect Discharge - The introduction of pollutants into a POTV from any
nondomestic source regulated under Section 307(b), (c), or (d) of the Clean
Water Act.
Industrial User (IU) or User - A source of nondomestic waste. Any nondomestic
source discharging pollutants to a POTW.
Industrial User Management Practices - Schedules of activities, prohibitions
or practices, maintenance procedures, and other management practices designed
to prevent or reduce pollution discharges. These practices may address
treatment requirements, operating procedures, and practices to control spills
or leaks, sludge or waste disposal, or drainage from raw material storage.
Instantaneous Maximum Limit - The maximum allowable concentration of a
pollutant determined from the analysis of any discrete or composited sample
collected, independent of the industrial flow rate and the duration of the
sampling event.
Interference - A discharge which, alone or in conjunction with a discharge or
discharges from other sources, both:
a. Inhibits or disrupts the POTW, its treatment processes or operations or
its sludge processes, use, or disposal; and
b. Therefore is a cause of a violation of any requirement of the POTW's
NPDES permit (including an increase in the magnitude or duration of a
violation) or of the prevention of sewage sludge use or disposal in
compliance with the following statutory provisions and regulations or
permits issued thereunder (or more stringent State or local regu-
lations) : Section 405 of the Clean Water Act, the Solid Waste Disposal
Act (SWDA) (including Title II, more commonly referred to as the
Resource Conservation and Recovery Act (RCRA) and including State
9/15/89 (T~3
-------
APPENDIX C GLOSSARY OF TERMS
regulations contained in any State sludge managenent plan prepared
pursuant to Subtitle D of the SWDA), the Clean Air Act, the Toxic
Substances Control Act, and the Marine Protection, Research, and
Sanctuaries Act [40 CFR 403.3].
Monthly Average Limit - The maximum allowable value for the average of all
observations obtained during one calendar month.
National Pretreatment Standard or Pretreatacnt Standard - Any regulation
promulgated by the EPA in accordance with Section 307(b) and (c) of the Clean
Water Act which applies to a specific category of industrial users and
provides limitations on the introduction of pollutants ini:o POTWs. This term
includes the prohibited discharge standards under 40 CFR 403.5, Including
local limits [40 CFR 403.3(j)].
National Prohibited Discharges - Prohibitions applicable t:o all nondomestic
dischargers regarding the introduction of pollutants into POTWs set forth at
40 CFR 403.5.
Net/Gross Calculations - An adjustment to Categorical Pretreatment Standards
to reflect the presence of pollutants in the industrial user's intake water
[40 CFR 403.15] .
Ninety (90)-day Compliance Report - A report submitted by a categorical
industrial user, within 90 days following the date for final compliance with
applicable categorical standards, or, in the case of a New Source, following
commencement of the introduction of wastewater into the POTV, that documents
and certifies the compliance status of the user [40 CFR 403.12(d)].
Nonconventional Pollutants - All pollutants which are not included in the
list of conventional or toxic pollutants in 40 CFR Part 401.
Nondonestic User - Any person who discharges causes or permits the discharge
of wastewater from any facility other than a residential unit.
Pass Through - A discharge which exits the POTV into waters of the United
States in quantities or concentrations which, alone or in conjunction with a
discharge or discharges from other sources, is a cause of a violation of any
requirement of the POTW's NPDES permit (including an increase in the magnitude
or duration of a violation) [40 CFR 403.3(n)].
Periodic Compliance Report - A report on compliance status submitted by
categorical industrial users to the Control Authority at It^ast semiannually
[40 CFR 403.12(e)].
Pretreataent - The reduction of the amount of pollutants, the elimination of
pollutants, or the alteration of the nature of pollutant properties in
wastewater prior to or in lieu of discharging or otherwise introducing such
pollutants into a POTW [40 CFR 403.3(q)].
9/15/89 C-4
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APPENDIX C _ GLOSSARY OF TERMS
Pretreataent Standard* for Existing Sourcts (PSES) - Categorical standards and
requirements applicable to industrial sources that began construction prior to
the publication of the proposed pretreataent standards for that industrial
category. (See individual categorical standards in 40 CFR Parts 405-471 for
specific dates. )
Pretreatment Standards for New Sources (PSNS) - Categorical Standards and
requirements applicable to industrial sources that began construction after
the publication of the proposed pretreatnent standards for that industrial
category. (See individual categorical standards in 40 CFR Parts 405-471 for
specific dates.)
Process Vastevater - Any water which, during manufacturing or processing,
comes into direct contact with or results from the production of or use of any
raw material, intermediate product, finished product, byproduct, or waste
product .
Production-based Standard - A discharge limitation expressed in terms of
allowable pollutant mass discharge per unit of production.
Publicly Owned Treatment Work* (POTV) - A treatment works as defined by
Section 212 of the Clean Water Act which is owned by the State or
municipality. This definition includes any devices and systems used in the
storage, treatment, recycling, and reclamation of municipal sewage or
industrial wastes of a liquid nature. It also includes sewers, pipes, and
other conveyances only if they convey wastewater to a POTW treatment plant [40
CFR 403.3(0)] .
Regulated tfastestreaa - An industrial process wastestream regulated by a
national categorical pretreatment standard.
Resource Conservation and Recovery Act (RCRA) - A Federal statute regulating
the management of hazardous waste from its generation through ultimate
disposal. The Act contains requirements for waste generators, transporters,
and owners and operators of treatment, storage, and disposal facilities (42
USC 6901 a fifia. ] .
Self -monitoring - Sampling and analyses performed by the industrial user to
ensure compliance with the permit or other regulatory requirements [40 CFR
403.12 (b) and (g)] .
Significant Industrial Dser (SIU) - (a) all categorical industrial users and
(b) any noncategorical industrial user that (i) discharges 25,000 gallons per
day or more of process wastewater ("process wastewater" excludes sanitary,
noncontact cooling, and boiler blowdown wastewaters) , or (ii) contributes a
process wastestream which makes up five percent or more of the average dry
weather hydraulic or organic (BOD, TSS, etc.) capacity of the treatment plant,
or (lii) has a reasonable potential, in the opinion of the Control or Approval
9/15/89 C-5
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APPENDIX C GLOSSARY OF TERMS
Authority to adversely affect the POTW operation (inhibition, pass through of
pollutants, sludge contamination, or endangement of POTW workers).
Slug Load - Any pollutant (including Biochemical Oxygen Demand) released in a
discharge at a flow rate or concentration which will caus>3 a violation of the
specific discharge prohibitions in 40 CFR 403.5(b) to 403.12(f).
Spill Prevention and Control Plan - A plan prepared by an industrial user to
minimize the likelihood of a spill and to expedite control and cleanup
activities should a spill occur.
Split Sample - Portion of a collected sample given to the industry or to
another agency to verify or compare laboratory results.
Standard Industrial Classification (SIC) Code - A classification scheme based
on the type of manufacturing or commercial activity at a rfacility: some
facilities have several activities which will cause them 1:0 have more than one
code number.
Standard Industrial Classification Manual - Prepared by the Executive Office
of the President, Office of Management and Budget 1987 (NTIS Order No. PB 87-
10001Z).
Time Proportional Composite Sample - A sampling method wh:ch combines discrete
sample allquots of constant volume collected at constant uirne intervals (e.g.,
200 milliliter (ml) samples collected every half hour for a 24-hour period).
This method provides representative samples only where thi; sampled stream flow
is constant, or where the volume is manually adjusted basfd on stream flow
variation prior to being added to the composite sample container.
Total Toxic Organlcs (TTO) - The sum of the masses or concentrations of the
specific toxic organic compounds regulated by specific categorical
pretreatment regulations which is found in the discharge fit specific
quantifiable concentrations. (Refer to the specific categorical regulations
to identify which compounds are regulated, what numeric vtlue is considered
"quantifiable," and what sampling or certification alternatives nay be
available.)
Toxic Organic Management Plan - Written plan submitted by industrial users in
accordance with some categorical pretreatment standards as an alternative to
TTO monitoring which specifies the toxic organic compounds used, the method of
disposal used, and procedures for assuring that toxic organics do not
routinely spill or leak into wastewater discharged to the POTW.
Toxic Pollutant - Any pollutant or combination of pollutants listed as toxic
in regulations promulgated by the Administrator of EPA under the provision of
the Clean Water Act 307(a) [40 CFR Part 403 Appendix B].
9/15/89 C-6
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APPENDIX C GLOSSARY OF TERMS
Treatability Manual - Guidance prepared by the U.S. EPA that provides detailed
descriptions of industrial processes, potential pollutants from each process,
appropriate treatment technologies, and cost estimating procedures.
Unregulated Vastestream - For purposes of the combined wastestream formula, a
wastestream that is not regulated by a national categorical pretreatraent
standard and is not considered a dilute wastestream.
Upset - An exceptional incident in which there is unintentional and temporary
noncompliance with the categorical pretreatraent standards because of factors
beyond the reasonable control of the Industrial User. An upset does not
include noncompliance to the extent caused by operational error, improperly
designed treatment facilities, Inadequate treatment facilities, lack of
preventive maintenance, or careless or improper operation [40 CFR 403.16(3)].
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APPENDIX D
SAMPLE SEVER USE ORDINANCE PROVISIONS FOR PERMITS
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APPENDIX D
SAMPLE SEVER USE ORDINANCE PROVISIONS FOR PERMITS
Readers are cautioned that this Appendix only addresses permit-related
provisions of a sever use ordinance. It does not contain provisions for the
adoption of Federal, State, or local pretreatment standards; compliance
monitoring and reporting activities or enforcement response. Since these
sample provisions are not complete, they must not be substituted for a
municipality's entire existing ordinance.
1.0 APPLICABILITY
1.1 This ordinance shall apply to all nondomestic users of the [name of
City's] publicly owned treatment works (the "POTW") which discharge
directly or indirectly into the POTW's sanitary sewer system. In
addition, it should be unlawful for any nondomestic user located outside
the City limits to continue discharges to the POTW except as provided in
Section 3.4.
2.0 DEFINITIONS
In addition to the terms below, the sever use ordinance should define the
following additional terms, including but not limited to: pass through,
superintendent, industrial user, nondomestic user, interference, liquid
waste hauler, and nondomestic waste.
2.1 Operator: means the person responsible for the overall operation of a
facility.
2.2 Owner: means the person who owns a facility or part of a facility.
2.3 Person: means any individual, association, partnership, corporation,
municipality, State, Federal agency or any agent or employee thereof.
2.4 Significant Industrial User (SIU): means
a. All dischargers subject to Categorical Pretreatment standards under
40 CFR Chapter I, Subchapter N; and
b. All noncategorical dischargers that, in the opinion of the City, have
a reasonable potential to adversely affect the POTW's operation, or
that contribute a process wastestream which makes up 5 percent or
more of the average dry weather hydraulic or organic capacity of the
POTW treatment plant, or that discharge an average of 25,000 gallons
per day or more of process wastewater to the POTW. However, the City
need not designate as Significant any noncategorical Industrial User
9/15/89"iTI
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APPENDIX D SAMPLE SEVER USE ORDINANCE PROVISIONS FOR PERMITS
that, in the opinion of the City and with the agreement of the
Approval Authority, has no potential for adversely affecting the
POTW's operation or for violating any pretreatment standard or
requirement. Any noncategorical Industrial User designated as
Significant may petition the City to be deleted from the list of
Significant Industrial Users on the grounds that it has no potential
for adversely affecting the POTW's operation or violating any
pretreatment standard or requirement.
3.0 PERMIT REQUIREMENTS
3.1 All nondomestic users must notify the Superintendent of the nature and
characteristics of their wastewater prior to commencing their discharge.
The Superintendent is authorized to prepare a form for this purpose.
3.2 It shall be unlawful for significant industrial users to discharge
wastewater, either directly or indirectly, into the City's sanitary sewer
system without first obtaining an industrial user pretreatment permit
from the POTW Superintendent. Any violation of the i:erms and conditions
of an industrial user pretreatment permit shall be deemed a violation of
this chapter. Obtaining an industrial user pretreatnent permit does not
relieve a permittee of its obligation to obtain other permits required by
Federal, State, or local law.
3.3 The Superintendent may require that other industrial users, including
liquid waste haulers, obtain industrial user pretreatment permits as
necessary to carry out the purposes of this chapter.
3.4 Any industrial user located beyond the city limits shall submit a permit
application in accordance with Section 4.0 below within [number of days]
of the effective date of this ordinance. New industrial users located
beyond the city limits shall submit such applications to the
Superintendent [number of days] prior to discharging into the sanitary
sewer. Upon review and approval of such application, the Superintendent
may enter into a contract with the user which requires the user to
subject itself to, and abide by this Chapter, including all permitting,
compliance monitoring, reporting, and enforcement provisions herein.
3.5 Existing Connections: Any significant industrial user which discharges
nondomestic waste into the sanitary sewer system prior to the effective
date of this ordinance and who wishes to continue sucn discharges in the
future, shall, within ninety (90) days after said date, apply to the City
for an industrial user pretreatment permit and shall not cause or allow
discharges to the POTW to continue after one hundred •sighty (180) days
from and after the effective date of this ordinance except in accordance
with a permit issued by the Superintendent.
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APPENDIX D SAMPLE SEWER USE ORDINANCE PROVISIONS FOR PERMITS
3.6 New Connections: Any significant industrial user proposing to begin or
recommence discharging nondonestic wastes into the sanitary sewer system
aust obtain a pretreatment permit prior to beginning or recommencing such
discharge. An application for this permit must be filed at least
[Control Authority should include the number of days] days prior to the
anticipated start up date.
4.0 PERMIT APPLICATION
4.1 In order to be considered for a pretreatment permit, all Industrial users
required to have a permit must submit the following information on an
application form approved by the Superintendent:
a. Name, address, and location (if different from the address)
b. Standard Industrial Classification (SIC) code of both the industry as
a whole and any processes for which Federal categorical standards
have been promulgated
c. Vastewater constituents and characteristics including any pollutants
in the discharge which are limited by any Federal, State, or local
standards. Sampling and analysis will be undertaken in accordance
with 40 CFR Part 136
d. Time and duration of the discharge
e. Daily maximum, daily average, and monthly average wastewater flow
rates, including daily, monthly, and seasonal variations, if any
f. Description of activities, facilities, and plant processes on the
premises, including a list of all raw materials and chemicals used at
the facility which are or could accidentally or intentionally be
discharged to the POTW
g. The site plans, floor plans and mechanical and plumbing plans and
details to show all sewers, floor drains, and appurtenances by size,
location and elevation
h. Each product produced by type, amount, process or processes and rate
of production
i. Type and amount of raw materials processed (average and maximum per
day)
j. Number and type of employees, and hours of operation, and proposed or
actual hours of operation of the pretreatment system
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APPENDIX D SAMPLE SEWER USE ORDINANCE PROVISIONS FOR PERMITS
k. Whether additional operation and maintenance (O&M) and/or additional
pretreatment is required for the user to meet all applicable Federal,
State, and local standards. If additional pretreatment and/or O&M
will be required to meet the standards, then the Industrial user
shall indicate the shortest time schedule necessary to accomplish
installation or adoption of such additional treatment and/or O&M.
The completion date in this schedule shall not be longer than the
compliance date established for the applicable pretreatment standard.
The following conditions apply to this schedule:
(I) The schedule shall contain progress increments in the form of
dates for the commencement and completion of major events
leading to the construction and operation of additional
pretreatment required for the user to meet the applicable
pretreatment standards (such events include hiring an engineer,
completing preliminary plans, completing final plans, executing
contracts for major components, commencing construction,
completing construction, beginning operation, and conducting
routine operation). No increment referred to in (a) above
shall exceed nine (9) months, nor shall the total compliance
period exceed eighteen (18) months
(ii) No later than 14 days following each date in the schedule and
the final date for compliance, the user shall submit a progress
report to the Superintendent including, as a minimum, whether
or not it complied with the increment of progress, the reason
for any delay, and if appropriate, the steps being taken by the
user to return to the established schedule. In no event shall
more than nine (9) months elapse between such progress reports
to the Superintendent
1. Any other information as may be deemed by the Superintendent to be
necessary to evaluate the permit application.
4.2 All plans required in Section 4.1 must be certified for accuracy by a
State registered professional engineer.
4.3 All applications must contain the following certification statement and
be signed in accordance with Sections (a), (b), (c) or (d) below:
"I certify under penalty of law that this document and all
attachments were prepared under my direction or supervision in
accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my
inquiry of the person or persons who manage the system, or those
persons directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief,
9/15/89 D-4
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APPENDIX D SAMPLE SEVER USE ORDINANCE PROVISIONS FOR PERMITS
true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility
of fine and imprisonment for knowing violations."
a. By a responsible corporate officer, if the Industrial User submitting
the reports is a corporation. For the purpose of this paragraph, a
responsible corporate officer means:
(i) A president, secretary, treasurer, or vice-president of the
corporation in charge of a principal business function, or any
other person who performs similar policy- or decision-making
functions for the corporation, or
(ii) The manager of one or more manufacturing, production, or
operation facilities employing more than 250 persons or having
gross annual sales or expenditures exceeding $25 million (in
second-quarter 1980 dollars), if authority to sign documents
has been assigned or delegated to the manager in accordance
with corporate procedures
b. By a general partner or proprietor if the Industrial User submitting
the reports is a partnership or sole proprietorship respectively
c. The principal executive officer or director having responsibility for
the overall operation of the discharging facility if the Industrial
User submitting the reports is a Federal, State, or local
governmental entity, or their agents.
d. By a duly authorized representative of the individual designated in
paragraph (a), (b) or (c) of this section if:
(i) The authorization is made in writing by the individual
described in paragraph (a), (b) or (c)
(11) The authorization specifies either an individual or a position
having responsibility for the overall operation of the facility
from which the Industrial Discharge originates, such as the
position of plant manager, operator of a well, or well field
superintendent, or a position of equivalent responsibility, or
having overall responsibility for environmental matters for the
company; and
(111) The written authorization is submitted to the City
e. If an authorization under paragraph (d) of this section is no longer
accurate because a different individual or position has
responsibility for the overall operation of the facility, or overall
responsibility for environmental matters for the company, a new
9/15/89 D-5
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APPENDIX D SAMPLE SEWER USE ORDINANCE PROVISIONS FOR PERMITS
authorization satisfying the requirements of paragraph (d) of this
section oust be submitted to the City prior to or together with any
reports to be signed by an authorized representative.
4.4 The Superintendent will evaluate the data furnished by the industrial
user and may require additional information. After evaluation of the
data furnished, the Superintendent may issue an industrial user
pretreatment permit subject to terms and conditions provided herein.
5.0 PRETREATMENT PERMIT CONTENTS
5.1 Pretreatment permits shall include such conditions a* are reasonably
deemed necessary by the superintendent to prevent pass through or
interference, protect the quality of the water body receiving the POTU's
effluent, protect worker health and safety, facilitate POTW sludge
management and disposal, protect ambient air quality, and protect against
damage to the POTW collection system or plant. Permits may contain, but
need not be limited to, the following:
a. Limits on the average and/or maximum rate of discharge, time of
discharge, and/or requirements for flow regulation and equalization
b. Limits on the average and/or maximum concentration, mass, or other
measure of identified wastewater constituents or properties
c. Requirements for the installation of pretreatment technology or
construction of appropriate containment devices, «stc., designed to
reduce, eliminate, or prevent the introduction of pollutants into the
treatment works
d. Development and implementation of spill control plans or other
special conditions including additional management: practices
necessary to adequately prevent accidental, unanticipated, or routine
discharges
e. The unit charge or schedule of user charges and fees for the
management of the wastewater discharged to the POTW
f. Requirements for installation and maintenance of Inspection and
sampling facilities
g. Specifications for monitoring programs which may include sampling
locations, frequency of sampling, number, types, and standards for
tests, and reporting schedules
h. Compliance schedules
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APPENDIX D SAMPLE SEWER USE ORDINANCE PROVISIONS FOR PERMITS
i. Requirements for submission of technical reports or discharge reports
j. Requirements for maintaining and retaining plant records relating to
wastewater discharge as specified by the Superintendent and affording
the Superintendent, or his representatives, access thereto
k. Requirements for notification of any new introduction of wastewater
constituents or of any substantial change in the volume or character
of the wastewater being introduced into the POTW
1. Requirements for the notification of any change in the manufacturing
and/or pretreatment process used by the permittee
m. Requirements for notification of excessive, accidental, or slug
discharges
n. Other conditions as deemed appropriate by the Superintendent to
ensure compliance with this ordinance, and State and Federal laws,
rules, and regulations
o. A statement that compliance with the permit does not relieve the
permittee of responsibility for compliance with all applicable
Federal pretreatment standards, including those which become
effective during the term of the permit.
6.0 PERMIT ISSUANCE PROCESS
6.1 Permit Duration: Permits shall be issued for a specified time period,
not to exceed five (5) years. A permit may be issued for a period less
than five (5) years, at the discretion of the Superintendent.
6.2 Public Notification: The Superintendent will publish [in an official
government publication and/or daily newspaper(s)j, notice of intent to
issue a pretreatment permit, at least fourteen (14) days prior to
issuance. The notice will indicate a location where the draft permit may
be reviewed and an address where written comments may be submitted.
6.3 Permit Appeals: The Superintendent will provide all Interested persons
with notice of final permit decisions. Upon notice by the
Superintendent, any person, including the industrial user, may petition
to appeal the terms of the permit within thirty (30) days of the notice.
a. Failure to submit a timely petition for review shall be deemed to be
a waiver of the appeal
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APPENDIX D SAMPLE SEWER USE ORDINANCE PROVISIONS FOR PERMITS
b. In its petition, the appealing party Bust indicate the permit
provisions objected to, the reasons for this objection, and the
alternative condition, if any, it seeks to be placed in the permit
c. The effectiveness of the permit shall not be stayed pending a
reconsideration by the Board. If, after considering the petition and
any arguments put forth by the Superintendent, the Board determines
that reconsideration is proper, it shall remand the permit back to
the Superintendent for reissuance. Those permit provisions being
reconsidered by the Superintendent shall be stayed pending reissuance
d. A Board of Directors' decision not to reconsider a final permit shall
be considered final administrative action for purposes of judicial
review
e. Aggrieved parties seeking judicial review of the final Control
Authority action must do so by filing a complaint with the [name of
court] for [name of County] within [Insert appropriate State Statute
of Limitations].
6.4 Permit Action: The superintendent may modify the permit for good cause
including, but not limited to, the following:
a. To incorporate any new or revised Federal, State, or local
pretreatment standards or requirements
b. Material or substantial alterations or additions to the discharger's
operation processes, or discharge volume or character which were not
considered in drafting the effective permit
c. A change in any condition in either the industrial user or the POTW
that requires either a temporary or permanent reduction or
elimination of the authorized discharge
d. Information indicating that the permitted discharge poses a threat to
the Control Authority's collection and treatment systems, POTW
personnel or the receiving waters
e. Violation of any terms or conditions of the permit
f. Misrepresentation or failure to disclose fully all relevant facts in
the permit application or in any required reporting
g. Revision of or a grant of variance from such categorical standards
pursuant to 40 CFR 403.13; or
h. To correct typographical or other errors in the permit
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APPENDIX D SAHPLE SEWER USE ORDINANCE PROVISIONS FOR PERMITS
i. To reflect transfer of the facility ownership and/or operation to a
new owner/operator
j. Upon request of the pernittee, provided such request does not create
a violation of any applicable requirements, standards, laws, or rules
and regulations.
The filing of a request by the permittee for a permit modification, revocation
and reissuance, or termination, or a notification of planned changes or
anticipated noncompliance, does not stay any permit condition.
6.5 Permit Transfer: Permits may be reassigned or transferred to a new owner
and/or operator with prior approval of the Superintendent:
a. The permittee must give at least thirty (30) days advance notice to
the Superintendent
b. The notice must include a written certification by the new owner
which:
(i) States that the new owner has no immediate intent to change the
facility's operations and processes
(ii) Identifies the specific date on which the transfer is to occur
(iii) Acknowledges full responsibility for complying with the
existing permit.
6.6 Permit Termination: Pretreatment permits may be terminated for the
following reasons:
a. Falsifying self-monitoring reports
b. Tampering with monitoring equipment
c. Refusing to allow timely access to the facility premises and records
d. Failure to meet effluent limitations
e. Failure to pay fines
f. Failure to pay sewer charges
g. Failure to meet compliance schedules.
6.7 Permit Reissuance: The user shall apply for permit reissuance by
submitting a complete permit application a minimum of ninety (90) days
prior to the expiration of the user's existing permit.
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APPENDIX D SAMPLE SEWER USE ORDINANCE PROVISIONS FOR PERMITS
6.8 Continuation of Expired Permits: An expired permit will continue to be
effective and enforceable until the permit is reissued if:
a. The industrial user has submitted a complete permit application at
least ninety (90) days prior to the expiration date of the user's
existing permit
b. The failure to reissue the permit, prior to expiration of the
previous permit, is not due to any act or failure to act on the part
of the industrial user.
6.9 Special Agreements: Nothing in this ordinance shall be construed as
preventing any special agreement or arrangement between the POTW and any
user whereby wastewater of unusual strength or character is accepted into
the POTW and specially treated and subject to any payments or user
charges, as may be applicable. However, no discharge which violates
pretreatment standards will be allowed under the terms of such special
agreements. If, in the opinion of the Superintendent, the
wastewater may have the potential to cause or result in any of the
following circumstances, no such special agreement will be made:
a. Pass through or interference
b. Endanger municipal employees or the public.
[In addition, there will need to be special provisions In the
ordinance addressing the unique concerns of permitting liquid waste
haulers.]
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APPENDIX E
SAMPLE PERMIT APPLICATION FORM
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APPENDIX E SAMPLE PERMIT APPLICATION FORM
Page 1 of 24
APPENDIX E
SAMPLE PERMIT APPLICATION FORM
Note: Please read all attached instructions prior to completing this
application.
SECTION A - GENERAL INFORMATION
1. Facility Name:
a. Operator Name:
b. Is the operator identified in L.a., the owner of the facility?
Yes [ ] No [ ]
If no, provide the name and address of the operator and submit a copy
of the contract and/or other documents indicating the operator's
scope of responsibility for the facility.
Facility Address:
Street:
City: State: Zip:
Business Mailing Address:
Street or P.O. Box:
City: State: Zip:
Designated signatory authority of the facility:
[Attach similar information for each authorized representative]
Name:
Title:
Address:
City: State: Zip: _
Phone #:
Designated facility contact:
Name: _
Title:
Phone #:
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APPENDIX E
SAMPLE PERMIT APPLICATION FORM
Page 2 of 24
SECTION B - BUSINESS ACTIVITY
1. If your facility enploys or will be employing processes in any of the
industrial categories or business activities listed below (regardless of
whether they generate wastewater, waste sludge, or hazardous wastes),
place a check beside the category of business activity (check all that
apply).
Industrial Categories*
Aluminum Forming
Asbestos Manufacturing
Battery Manufacturing
Can Making
Carbon Black
Coal Mining
Coil Coating
[ ] Copper Forming
[ ] Electric and Electronic Components Manufacturing
[ ] Electroplating
[ ] Feedlots
[ ] Fertilizer Manufacturing
[ ] Foundries (Metal Molding and Casting)
[ ] Glass Manufacturing
[ ] Grain Mills
[ ] Inorganic Chemicals
[ ] Iron and Steel
[ ] Leather Tanning and Finishing
[ ] Metal Finishing
[ ] Nonferrous Metals Forming
[ ] Nonferrous Metals Manufacturing
Organic Chemicals Manufacturing
Paint and Ink Formulating
Paving and Roofing Manufacturing
Pesticides Manufacturing
Petroleum Refining
Pharmaceutical
Plastic and Synthetic Materials Manufacturing
Plastics Processing Manufacturing
Porcelain Enamel
Pulp, Paper, and Fiberboard Manufacturing
Rubber
Soap and Detergent Manufacturing
Steam Electric
Sugar Processing
Textile Mills
Timber Products
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E-2
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APPENDIX E SAMPLE PERMIT APPLICATION FORM
Page 3 of 24
A facility with processes inclusive in these business areas nay be
covered by Environmental Protection Agency's (EPA) categorical
pretreatment standards. These facilities are termed "categorical users".
2. Give a brief description of all operations at this facility including
primary products or services (attach additional sheets if necessary):
3. Indicate applicable Standard Industrial Classification (SIC) for all
processes (If more than one applies, list in descending order of
importance.):
a.
b.
c.
d.
e.
4. PRODUCT VOLUME:
PAST CALENDAR YEAR ESTIMATE THIS CALENDAR YEAR
PRODUCT Amounts Per Day Amounts Per Day
(Brandname) (Daily Units) (Daily Units)
(levels with others
(and no u.l) Average Maximum Average Maximum
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APPENDIX E SAMPLE PERMIT APPLICATION FORM
Page 4 of 24
SECTION C - WATER SUPPLY
1. Water Sources: (Check as many as are applicable)
[ ] Private Well
[ ] Surface Water
[ ] Municipal Water Utility (Specify City):
[ ] Other (Specify):
2. Naae on the water bill:
Name:
Street:
City: State: Zip:
3. Water service account number:
4. List average water usage on prenlses:
[New facilities may estimate]
Indicate
Average Water Estimated (E) or
TYDB Usage (GPD) Measured (M)
a. Contact cooling water
b. Non-contact cooling water
c. Boiler feed
d. Process
e. Sanitary
f. Air pollution control
g. Contained in product
h. Plant and equipment washdown
1. Irrigation and lawn watering
j . Other
k. TOTAL OF A-J
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APPENDIX E SAMPLE PERMIT APPLICATION FORM
Page 5 of 24
SECTION D - SEVER INFORMATION
1. a. For an existing business:
Is the building presently connected to the public sanitary sewer system?
[ ] Yes: Sanitary sewer account number
[ ] No: Have you applied for a sanitary sewer hookup? [ ] Yes { ] No
b. For a new business:
(i). Will you be occupying an existing vacant building (such as in
an industrial park)? [ ] Yes [ ] No
(ii). Have you applied for a building permit if a new facility will
be constructed? [ ) Yes [ ] No
(iii). Will you be connected to the public sanitary sewer system?
( ] Yes ( ] No
2. List size, descriptive location, and flow of each facility sewer which
connects to the City's sewer system. (If more than three, attach
additional information on another sheet.)
Descriptive Location of Sewer Average
Sewer Size Connection or Discharge Point Flow (GPP)
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APPENDIX E SAMPLE PERMIT APPLICATION FORM
Page 6 of 24
SECTION E - VASTEVATER DISCHARGE INFORMATION
1. Does (or will) this facility discharge any wastevater other than from
restrooms to the City sewer?
[ ] Yes If the answer to this question is "yes", complete the remainder
of the application.
[ ] No If the answer to this question is "no", skip to Section I.
2. Provide the following information on wastewater flow rate.
[New facilities may estimate]
a. Hours/Day Discharged (e.g., 8 hours/day):
M T W TH F SAT SUN
b. Hours of Discharge (e.g., 9 a.m. to 5 p.m.):
M T W TH F SAT SUN
c. Peak hourly flow rate (GPD)
d. Maximum daily flow rate (CPD)
e. Annual daily average (GPD)
3. If batch discharge occurs or will occur, indicate:
[New facilities may estimate]
a. Number of batch discharges per day
b. Average discharge per batch (GPD)
c. Time of batch discharges at
(days of week) (hours of day)
d. Flow rate gallons/minute
e. Percent of total discharge
9/15/89 E-6
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APPENDIX E SAMPLE PERMIT APPLICATION FORM
Page 7 of 24
(4. Schenatic Flow Diagram - For each major activity in which vastewater is
or will be generated, draw a diagraa of the flow of materials, products.
water, and wastewater from the start of the activity to its completion,
shoving all unit processes. Indicate which processes use water and which
generate wastestreans. Include the average daily volume and maximum
daily volume of each wastestream [new facilities may estimate]. If
estimates are used for flow data this must be indicated. Nmjber efl^h
unit process having wastewater discharges to the community sewer. Use
these numbers when showing this unit processes in the building layout in
Section H. This drawing must be certified by a State Registered
Professional Engineer.
9/15/89 E-7
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APPENDIX E SAMPLE PERMIT APPLICATION FORM
Page 8 of 24
Facilities that checked activities in question 1 of Section 8 are considered
Categorical Industrial Users and should skip to question 6.
5. For Non-Categorical Users Only: List average wastewater discharge,
maximum discharge, and type of discharge (batch, continuous, or both),
for each plant process. Include the reference number from the process
schematic that corresponds to each process. [New facilities should
provide estimates for each discharge].
Average Maximum Type of Discharge
No. Process Description Flow (GPP) Flow (GPP) (batch.continuous.none)
ANSWER QUESTIONS 6 & 7 ONLY IF YOU ARE SUBJECT TO CATEGORICAL PRETREATMENT
STANDARDS
6. For Categorical Users: Provide the wastewater discharge flows for each
of your processes or proposed processes. Include the reference number
from the process schematic that corresponds to each process. [New
facilities should provide estimates for each discharge].
Average Maximum Type of Discharge
No. Regualted Process Flow (GPD) Flow (GPP) (batch.continuous.none)
Average Maximum Type of Discharge
No. Unregulated Process Flow (GPP) Flow (GPP) (batch.continuous.none)
Average Maximum Type of Discharge
No. Pilution Flow (GPP) Flow (GPP) (batch.continuous .none)
9/15/89 E-8
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APPENDIX E SAMPLE PERMIT APPLICATION FORM
Page 9 of 2U
7. For Categorical Users Subject To Total Toxic Organic (TTO) Requirements:
Provide the following (TTO) Information.
a. Does (or will) this facility use any of the toxic organlcs that are
listed under the TTO standard of the applicable categorical
pretreatment standards published by EPA?
I ] Yes
I ) No
b. Has a baseline monitoring report (BMR) been submitted which contains
TTO information?
[ 1 Yes
[ ] No
c. Has a toxic organics management plan (TOMP) been developed?
[ ] Yes, (Please attach a copy)
[ 1 No
8. Do you have, or plan to have, automatic sampling equipment or continuous
wastewater flow metering equipment at this facility?
Current: Flow Metering [ ] Yes [ ) No [ ] N/A
Sampling Equipment ( ] Yes [ ] No [ ] N/A
Planned: Flow Metering ( ] Yes [ ] No [ ] N/A
Sampling Equipment [ ] Yes [ ] No [ j N/A
If so, please indicate the present or future location of this equipment
on the sewer schematic and describe the equipment below:
9. Are any process changes or expansions planned during the next three
years that could alter wastewater volumes or characteristics? Consider
production processes as well as air or water pollution treatment
processes that may affect the discharge.
[ ] Yes
[ ] No, (skip question 10)
9/15/89E^
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APPENDIX E SAMPLE PERMIT APPLICATION FORM
Page 10 of 24
10. Briefly describe these changes and their effects on the waatewater
voluae and characteristics: (Attach additional sheets if needed.)
11. Are any materials or water reclamation systems in use or planned?
[ J Yes
[ ] No, (skip question 12)
12. Briefly describe recovery process, substance recovered, percent
recovered, and the concentration in the spent solution. Submit a flow
diagram for each process: (Attach additional sheets if needed.)
SECTION P - CHARACTERISTICS OF DISCHARGE
All current industrial users are required to submit monitoring data on all
pollutants that are regulated specific to each process. Use the tables
provided in this section to report the analytical results. DO NOT LEAVE
BLANKS. For all other (nonregulated) pollutants, indicate whether the
pollutant is known to be present (P), suspected to be present (S) , or known
not to be present (0), by placing the appropriate letter in the column for
average reported values. Indicate on either the top of each table, or on a
separate sheet, if necessary, the sample location and type of analysis used.
Be sure methods conform to 40 CFR Part 136; if they do not, indicate what
method was used.
Nev dischargers should use the table to indicate what pollutants will be
present or are suspected to be present in proposed wastestreams by placing a P
(expected to be present), S (may be present), or 0 (will not be present) under
the average reported values.
9/15/89 E-10
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APPENDIX E SAMPLE PERMIT APPLICATION FORM
Page 11 of 24
Detection Maximun Average Number
Pollutant Level Daily of of
Used Value Analyses Analyses Units
Cone. Mass Cone. Mass Cone. Mass
Acenaphthene
Acrolein
Acrylonitrile
Benzene
Benzidine
Carbon tetrachloride
Chlorobenzene
1,2,4-Trichlorobenzene
Hexachlorobenzene
1,2-Dichloroethane
1,1,1-Trichloroe thane
Hexachloroethane
1,1-Dichloroe thane
1,1,2-Trichloroethane
1,1,2,2-Tetrachloroethane
Chloroethane
Bis(2-chloroethyl) ether
17 Bis (chloro methyl) ether,
2-Chloroethyl vinyl ether
2 -Chloronaphthalene
2,4,6-Trichlorophenol
Parachloroneta cresol
Chloroform
2-Chlorophenol
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
3,3-Dichlorobenzldine
1,1-Dichloroethylene
1,2-Trans-dichloroethylene
2,4-Dichloropheno
1,2-Dichloropropane
1,2-Dichloropropylene
1,3-Dichloropropylene
9/15/89 E-ll
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APPENDIX E SAMPLE PERMIT APPLICATION FORM
Page 12 of 2U
Detection Maxinua Average Number
Pollutant Level Daily of of
Used Value Analyses Analyses Units
Cone. Mass Cone. Mass Cone. Has*
2,4-DlMthylphenol
2,4-Dinitrotoluene
2,6-Dinitrotoluene
1,2-Diphenylhydrazlne
Ethylbenzene
Fluoranthene
4-Chlorophenyl phenyl ether
4-Broaophenyl phenyl ether
Bis(2-chlorisopropyl) ether
Bis(2-chloroethoxy) methane
Methylene chloride
Methyl chloride
Methyl broaide
Bronofom
Dichlorobronoaethane
Chlorodibroaoaethane
Hexachlorobutadiene
Hexachlorocyclopentadiene
Isophorone
Naphthalene
Nitrobenzene
Nitrophenol
2-Nitrophenol
it -Nitrophenol
2,4-Dlnitrophcnol
4,6-Dinitro-o-cresol
N-nitrosodimethylanlne
N-nitrosodlph«nylaaine
N-nitrosodi-n-propylanine
Pentachlorophenol
Phenol
Bis(2-ethylhexyl) phthalate
Butyl benzyl phthalate
Di-n-butyl phthalate
9/15/89 E-12
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APPEND I X_E SAMPLE PERMIT APPLICATION FORM
Page 13 of 24
Detect ion Maximum Average Number
Pollutant Level Daily of of
Used Value Analyses Analyses
Cone. Mass Cone. Mass Cone. Mass
Di-n-octyl phthalate
Diethyl phthalate
Dimethyl phthalate
Benzo(a)anthracene
Benzo(a)pyrene
3,4-benzofluoranthene
Benzo(k) fluoranthane
Chrysene
Acenaphthylene
Anthracene
Benzo(ghi)perylene
Fluorene
Phenanthrene
Dibenzo(a.h)anthracene
Indeno(l,2,3-cd)pyrene
Pyrene
Tetrachloroethylene
Toluene
Trichloroethylene
Vinyl chloride
Aldrin
Dieldrin
Chlordane
i4.it' - DDT
4,4'-DDE
4,4'-ODD
Alpha -endosulfan
Beta-endosulfan
Endosulfan sulfate
Endrin
Endrln aldehyde
Heptachlor
9/15/89 E'13
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APPENDIX E SAMPLE PERMIT APPLICATION FORM
Page 14 of 24
Detection Max1nun Average Nuaber
Pollutant Level Dally of of
Used Value Analyses Analyses Units
Cone. Haas Cone. Mass Cone. Mass
Heptachlor epoxide
Alpha-BHC
B«ta-BHC
CaiMA-BHC
Delta-BHC
PCB-1242
PCB-1254
PCB-1221
PCB-1232
PCB-1248
PCB-1260
PCB-1016
Toxaphene
(TCDD)
Asbestos
Acidity
Alkalinity
Bacteria
BODS
COD
Chloride
Chlorine
Flouride
Hardness
Hagnesiun
KH3-N
Oil and Crease
TSS
TOC
KJeldahl N
Nitrate N
Nitrite N
Organic N
Orthophosphate P
Phosphorous
9/15/89 E-14
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APPENDIX E SAMPLE PERMIT APPLICATION FORM
Page 15 of 24
Detection MaxiouB Average Nuaber
Pollutant Level Daily of of
Used Value Analyses Analyses Units
Cone. Mass Cone. Mass Cone. Mass
Sodlu*
Specific Conductivity
Sulfate (S04)
Sulfide (S)
Sulfite (SOj)
Antiaony
Arsenic
Bariua
Beryllium
Cadaiua
ChroaiuB
Copper
Cyanide
Lead
Mercury
Nickel
Seleniua
Silver
Thalllua
Zinc
9/15/89 E-15
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APPENDIX E SAMPLE PERMIT APPLICATION FORM
Page 16 of 24
SECTION G - TREATMENT
1. Is any form of wastewater treatment (see list below) practiced at this
faci 1 ity?
[ .' Yes
; : NO
2. Is anv form of wastewater treatment (or changes to a existing wastewater
treatment) planned for this facility within the next three years?
Yes, describe:
No
Treatment devices or processes used or proposed for treating wastewater
or sludge (check as many as appropriate)
[ ] Air flotation
[ ] Centrifuge
[ } Chemical precipitation
[ J Chlorination
[ ] Cyclone
[ ! Filtration
i ] Flow equalization
[ ] Grease or oil separation, type:
[ ] Grease trap
[' ] Grinding filter
( ] Grit removal
i ] Ion exchange
[ j Neutralization, pH correction
i ] Ozonation
[ I Reverse osmosis
[ ] Screen
[ j Sedimentation
[ ] Septic tank
[ ] Solvent separation
[ ] Spill protection
[ ] Sump
[ ] Biological treatment, type:
] Rainwater diversion or storage
] Other chemical treatment, type:
] Other physical treatment, type:.
] Other, type:
9/15/89 E-16
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APPENDIX E
SAMPLE PKRMIT APPLICATION FORM
Page 17 of 24
Descr ipt i on
Describe Che pollutant loadings, flow rates, design capacity, physical
sixe, and operating procedures of each treatment facility checked above
Attach a process flow diagram for each existing treatment rystem.
Include process equipment, by-products, by-product disposal method,
waste and by-product volumes, and design and operating conditions.
Describe any changes in treatment or disposal methods planned or under
roust ruction for the wastewater discharge to tho sanitary sewer. Please
include estimated completion dates.
9.
Do you have a treatment operator?
(if Yes,)
Name :
Title:
Phone:
Full time:
Part time:
] Yes
No
(specify hours)
(specify hours)
Do you have a manual on the correct operation of your treatment
equipment?
[ ] Yes [ ] No
Do you have a written maintenance schedule for your treatment equipment?
( i Yes [ ] No
9/15/89
E-17
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APPENDIX E SAMPLE PERMIT APPLICATION FORM
Page 18 of 24
SECTION H - FACILITY OPERATIONAL CHARACTERISTICS
1. Shift Information
Work Days [ ] [ ] [ ] [ ] [ ] [ ] [ ]
Mon. Tues. Wed. Thur. Frl. Sat. Sun.
Shifts
per work
day:
Eapl's
per
shift:
Shift
start
and
end
times:
1st
2nd
3rd
1st
2nd
3rd
2. Indicate whether the business activity Is:
[ ] Continuous through the year, or
[ ) Seasonal - Circle the months of the year during which the business
activity occurs:
JFMAMJJASOND
COMMENTS:
3. Indicate whether the facility discharge Is:
[ ] Continuous through the year, or
[ ] Seasonal - Circle the months of the year during which the business
activity occurs:
JFMAMJJASOND
COMMENTS:
9/15/89 E-18
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APPENDIX E SAMPLE PERMIT APPLICATION FORM
Page 19 of 24
4. Does operation shut down for vacation, maintenance, or other reasons?
[ ] Yes, indicate reasons and period when shutdown occurs:
( ] No
5. List types and anounts (mass or volume per day) of raw materials used or
planned for use (attach list if needed):
6. List types and quantity of chemicals used or planned for use (attach
list if needed). Include copies of Manufacturer's Safety Data Sheets
(if available) for all chemicals identified:
Chemical Quantity
9/15/89 E-19
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APPENDIX E
SAMPL?'. PERM IT APPLICATION FORM
Page
>f
Building I.avout - Draw to scale the location of each building on t he
premises. Show map orientation and location of all water meters, storm
drains, numbered unit processes (from schematic flow diagram), public
sewers, and each facility sewer line connected to the public sewers.
N'umher each sewer and show existing and proposed sampling locations.
Th i s drawing must be certified bv a State Registered Prof ess ion.i i
Engi neer.
A blueprint or drawing of the facilities showing the above items
attached in Meu of submitting a drawing on t h i s sheet.
be
9/15/89
E-20
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APPENDIX F. SAMPLE PERMIT APPLICATION FORM
Page 21 of 24
SECTION I - SPILL PREVENTION
1. Do you have chemical storage containers, bins, or ponds at your
facility? ; ] Yes [ ] No
If yes, please give a description of their location, contents, size,
type, and frequency and method of cleaning. Also indicate in a diagram
or comment on the proximity of these containers to a sewer or storm
drain. Indicate if buried metal containers have cathodic protection.
2. Do you have floor drains in your manufacturing or chemical storage
art-a(s)? ' ' Ye.s [ ; No If yes; Where do thev discharge to?
3. If vou have chemical storage containers, bins, or ponds in manufacturing
area, could an accidental spill lead to a discharge to: (check all that
applv).
an onsite disposal system
public sanitary sewer system (e.g. through a floor drain)
storm drain
to ground
other, specify:
• ] not applicable, no possible discharge to any of the above routes
Do vou have an accidental spill prevention plan (ASPP) to prevent spills
of chemicals or slug discharges from entering the Control Authority's
collection systems?
[ } Ye.s - [Please enclose a copy with the application]
I 1 No
[ ] N/A, Not applicable since there are no floor drains and/or the
facility discharge(s) only domestic wastes.
Please describe below any previous spill events and remedial measures
taken to prevent their reoccurrence.
9/15/89 E-21
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APPENDIX E SAMPLE PERMIT APPLICATION FORM
Page 22 of 24
SECTION J - NON-DISCHARGED WASTES
1. Are any waste liquids or sludges generated and not disposed of in the
sanitary sewer system?
[ ] Yes, please describe below
[ ] No, skip the remainder of Section J.
Waste Generated Quantity (per year) Disposal Method
2. Indicate which wastes identified above are disposed of at an off-site
treatment facility and which are disposed of on-site.
3. If any of your wastes are sent to an off-site centralized waste
treatment facility, identify the waste and the facility.
4. If an outside firm removes any of the above checked wastes, state the
name(s) and address(es) of all waste haulers:
b.
Permit No. Permit No.
(if applicable): (if applicable):.
5. Have you been issued any Federal, State, or local environmental permits?
I 1 Yes
[ ] No
If yes, please list the permit(s):
9/15/89 E-22
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APPENDIX E SAMPLE PERMIT APPLICATION FORM
Page 23 of 24
SECTION K - AUTHORIZED SIGNATURES
Compliance certification:
1. Are all applicable Federal, State, or local pretreataent standards and
requirements being net on a consistent basis?
Yes [ ] No [ ] Not yet discharging [ ]
2. If No:
a. What additional operations and maintenance procedures are being
considered to bring the facility into compliance? Also, list
additional treatment technology or practice being considered in order
to bring the facility into compliance.
b. Provide a schedule for bringing the facility into compliance.
Specify major events planned along with reasonable completion dates.
Note that if the Control Authority issues a permit to the applicant,
it may establish a schedule for compliance different from the one
submitted by the facility.
Milestone Activity Completion Date
9/15/89 E-23
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APPENDIX E lAMP_Lr. Pi'.r'.M 1 T AiTLK'AT 1 f).N FORM
P.i;-.- . . of :'.i
Authorized Representative Statement:
I certify under penalty of law that this c!ocu;i.ent and all attachments
were prepared under my direction or supervision in accordanro with n sv;, tem
designed to assure that qualified personnel properlv gather ami evaluate the
information submitted. Based on my inquiry of the person or persons vho
manage the system, or those persons directly responsible for gathering t ;;••
information, the information submitted is, to the best of my knowli dt;.' ,r.'.
belief, true, accurate, and complete. I am aware that there are s i gn i f i c ,i:-.t
penalties for submitting false information, including the possibility of 'in*
and imprisonment for knowing violations.
Name(s) Title
Signature Date Phone
9/15/89 E-24
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APPENDIX E SAMPLE PERMIT APPLICATION FORK
Page 1 of 7
INSTRUCTIONS TO FILL OUT WASTEWATER DISCHARGE PERMIT APPLICATION
All questions must be answered. DO NOT LEAVE BLANKS. If you answer "no" to
question E.I., you may skip to Section I. Otherwise, if a question is not
applicable, indicate so on the form. Instructions to some questions on the
permit application are given below.
SECTION A - INSTRUCTIONS (GENERAL INFORMATION)
1. Enter the facility's official or legal name. Do not use a colloquial
name.
a. Operator Name: Give the name, as it is legally referred to, of the
person, firm, public organization, or any other entity which operates
the facility described in this application. This may or may not be
the same name as the facility.
b. Indicate whether the entity which operates the facility also owns it
by marking the appropriate box:
(i) If the response is "No", clearly indicate the operator's name
and address and submit a copy of the contract and/or other
documents indicating the operator's scope of responsibility for
the facility.
2. Provide the physical location of the facility that is applying for a
discharge permit.
3. Provide the mailing address where correspondence from the Control
Authority may be sent.
4. Provide all the names of the authorized signatories for this facility
for the purposes of signing all reports. The designated signatory is
defined as:
a. A responsible corporate officer, if the Industrial User submitting
the reports is a corporation. For the purpose of this paragraph, a
responsible corporate officer means:
(i) a president, secretary, treasurer, or vice-president of the
corporation in charge of a principal business function, or any
other person who performs similar policy- or decision-making
functions for the corporation, or
9/15/89 E-25
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SAMPLE PERMIT APPLICATION FORM
Page 2 of 7
(ii) the manager of one or note manufacturing, production, or
operation facilities espioying aore than 250 persons or having
gross annual sales or expenditures exceeding $25 million (in
second-quarter 1980 dollars), if authority to sign documents
has been assigned or delegated to the manager in accordance
with corporate procedures.
b, A general partner or proprietor If the Industrial User subalttlng the
reports is a partnership or sole proprietorship respectively.
c. The principal executive officer or director having responsibility for
the overall operation of the discharging facility if the Industrial
User submitting the reports is a Federal, State, or local
governmental entity, or their agents.
d. A duly authorized representative of the individual designated in
paragraph (a), (b), or (c) of this section if:
(i) the authorization is made in writing by the individual
described in paragraph (a), (b), or (c);
(ii) the authorization specifies either an individual or a position
having responsibility for the overall operation of the facility
from which the Industrial Discharge originates, such as the
position of plant manager, operator of a well, or well field
superintendent, or a position of equivalent responsibility, or
having overall responsibility for environmental matters for the
company; and
(iii) the written authorization is submitted to the City.
e. If an authorization under paragraph (d) of this section is no longer
accurate because a different individual or position has
responsibility for the overall operation of the facility, or overall
responsibility for environmental matters for the company, a new
authorization satisfying the requirements of paragraph (d) of this
section must be submitted to the City prior to or together with any
reports to be signed by an authorized representative.
5. Provide the name of a person who is thoroughly familiar with the facts
reported on this form and who can be contacted by the Control Authority
(e.g., the plant manager).
9/15/89 E-26
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APPENDIX E SAMPLE PERMIT APPLICATION FORM
Page 3 of 7
SECTION B - INSTRUCTIONS (BUSINESS OPERATIONS)
1. Check off all operations that occur or will occur at your facility. If
you have any questions regarding how to categorize your business
activity, contact the Control Authority for technical guidance.
3. For all processes found on the premises, indicate the Standard
Industrial Classification (SIC) Code Number, as found in the most recent
Edition of Standard Industrial Classification Manual prepared by the
Executive Office of the President, Office of Management and Budget. This
document is available from the Government Printing Office in Washington
D.C., or in San Francisco, California. DO NOT USE PREVIOUS EDITIONS OF
THE MANUAL. Copies of the manual are also available at most public
libraries.
4. List the types of products, giving the common or brand naae and the
proper or scientific name. Enter from your records the average and
maximum amounts produced daily for each operation for the previous
calendar year, and the estimated total daily production for this
calendar year. Be sure to specify the daily units of production. Attach
additional pages as necessary.
SECTION C - INSTRUCTIONS (WATER SUPPLY)
A. Provide daily average water usage within the facility. Contact cooling
water is cooling water that during the process comes into contact with
process materials, thereby becoming contaminated. Non-contact cooling
water does not come into contact with process materials. Sanitary water
includes only water used in restrooms. Plant and equipment washdown
includes floor washdown. If sanitary flow is not metered, provide an
estimate based on 15 gallons per day (gpd) for each employee.
SECTION E - INSTRUCTIONS (VASTEVATER DISCHARGE INFORMATION)
1. If you answer "no" to this question, skip to Section I, otherwise
complete the remainder of the application.
9/15/89 E-27
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APPENDIX E
SAMPLE PERMIT APPLICATION FORM
4 of
A schematic flow diagram is required to be completed and certified for
accuracy by a State registered professional engineer. Assign a
sequential reference number to each process starting with No. 1. An
example of a drawing is shown below in Figure 1. To determine your
average daily volume and maximum daily volume of wastewater flow, vou
:r.av have to read water meters, sewer meters, or make estimates of
volumes that are not directly measurable.
FIGURE 1. SCHEMATIC FLOW DIAGRAM
9/15/1
'0000 OPO
1 _
1 (
Fffm.ro
Opmom
SoM WM»
57VWM
39
900.000 OPO ttme* 9u»
1 WM* SupPr R**r
* In nnr, r.pn 1 '0.000 OPO
1 *SO 000 OPO 1 ' 1 WhMOOTittM*
M.OOO 1.000 FOTTUMO*
OPO Product La* OarrB QPO r« >iti« «»•••!
""*** Q»f '''**" * °*""""
6000 QPO 1
Mi.QOO GPO Sowi BraT 1
* »JOO OTO 29.000 OPO 5 000 OPO *
ID POTW
10.000 Nturaaaon ' • M 000 OPO
SPD * '•« *"
Non-Cofna
CflOlnfl 100.000 GPO
KH .000 OPO
• i
EaudBttan ^ / Pnmarir \ Amon ^ Scaondvy \ 2 '00 000 GPO _
® SAMPlf POINTS
Htr&ftta CO**q . ff^ttNl
StamiMMr Mu 20.000 QPO
BtaAw PO^ B^aoMa^
20.00C GPO ***•• 20.000 OPO *"
^"~"~"^ ,\\ SCHEMATIC OF WAlhK ROW
"•'• "') Acme Drug, Inc
''^•".'.""-y Qty, County, State
E-28
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APPENDIX E SAMPLE PERMIT APPLICATION FORM
Page 5 of 7
'). Non-categorical users should report average daily and maximum daily
wastewat.er flows from each process, operation, or activity present at
the facility. Categorical users should skip to question 6.
6. Categorical users should report average daily and maximum daily
wastewater flows from every regulated, unregulated, and dilution
process. A regulated wastestream is defined as wastewater from an
industrial process that is regulated for a particular pollutant by a
categorical pretreatment standard. Unregulated wastestreams are
waste-streams from an industrial process that arc not regulated bv a
categorical pretreatment standard and are not defined as a dilution
was test ream. Dilution wastestreams include sanitarv wastewater, boiler
blowdown, noncontact cooling water or blowdown, stormwater streams,
demineralizer backwash streams and process wastestreams from certain
industrial subcategories exempted by EPA from categorical pretrealment
standards. [For further details see 40 CFR 40'?.6 (e).;
/'. Total Toxic Organics (TTO) means the sum of the masses or concentrations
of specific toxic organic compounds found in the industrial user's
process discharge The individual organic compounds that make up the
TTO value and the minimum reportable quantities differ according to the
particular industrial category [see applicable categorical pre t reat :r,ent
standards, 40 CFR Parts 405-471'.
SECTION H - INSTRUCTIONS (FACILITY OPERATIONAL CHARACTERISTICS)
2. Indicate whether the business activity is continuous throughout the vear
or if it. is seasonal. If the activity is seasonal, circle the months of
the year during which the discharge occurs. Make any comments you feel
are required to describe the variation in operation of your business
ac t ivi tv.
4. Indicate any shut downs in operation which may occur during the vear and
indicate the reasons for shutdown.
r3 . Provide a listing of all primary raw materials used (or planned) in the
facility's operations. Indicate amount of raw material used in daily
uni ts.
6. Provide a listing of all chemicals used (or planned) in the facility's
operations. Indicate the amount used or planned in daily units. Avoid
the use of trade names of chemicals. If trade names are used, also
provide chemical compounds. Provide copies of all available
manufacturer's safety data sheets for all chemicals identified.
9/15/89 E-29
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APPENDIX E
SAMPLE PERMIT APPLICATION FORM
Page 6 of 7
7. A building layout or plant site plan of the premises is required to be
conpleted and certified for accuracy by a State registered professional
engineer. Approved building plans nay be substituted. An arrow showing
North as well as the map scale must be shown. The location of each
existing and proposed sampling location and facility sewer line must be
clearly identified as well as all sanitary and wastewater drainage
plumbing. Number each unit process discharging wastewater to the public
sewer. Use the same numbering system shown in Figure 1, the schematic
flow diagram. An example of the drawing required is shown below.
FIGURE 2. BUILDING LAYOUT
FIGURE 2
ANYBODY'S MCAT CO.
I* MOO')
hUNMOui m. i
MJHt/Mt
J
ILJ®1
sL
^
3* Wtti
*
i
310 3nr«r N«.
QfftCg
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9/15/89
E-30
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APPENDIX E SAMPLE PERMIT APPLICATION FORM
Page 7 of 7
SECTION I - INSTRUCTIONS (SPILL PREVENTION)
5. Describe how the spill occurred, what was spilled, when the spill
happened, where it occurred, how much was spilled, and whether or not
the spill reached the sewer. Also explain what measures have been taken
to prevent a reoccurrence or what neasures have been taken to limit
damage if another spill occurs.
SECTION J - INSTRUCTIONS (NON-DISCHARGED WASTES)
1. For wastes not discharged to the Control Authority's sewer, indicate
types of waste generated, aaount generated, the way in which the waste
is disposed (e.g. incinerated, hauled, etc.), and the location of
disposal.
2. Onsite disposal system could be a septic system, lagoon, holding pond
(evaporative-type), etc.
5. Types of permits could be: air, hazardous waste, underground injection,
solid waste, NPDES (for discharges to surface water), etc.
SECTION K - INSTRUCTIONS (AUTHORIZED SIGNATURES)
See instructions for question A in Section A, for a definition of an
authorized representative.
9/15/89 E-31
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APPENDIX F
SAMPLE INDUSTRIAL USER PERMIT
-------
APPENDIX F
SAMPLE INDUSTRIAL USER PERMIT
TRANSMITTAL LETTER
(Control Authority Letterhead with Address Should Be Used)
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Name of Responsible Official at Industry
Title
Name of Industrial User
Mailing Address
RE: Issuance of Industrial User Permit to [name of the Industrial User] by
the [name of Control Authority].
Permit No. [cite permit number].
Dear [name of Responsible Official at Industry]:
Your application for an industrial user pretreatment permit has been reviewed
and processed in accordance with [cite specific section of ordinance].
The enclosed [cite permit number] covers the wastewater discharged from the
facility located at [Location Address] into the [name of Control Authority]
sewer system. All discharges from this facility and actions and reports
relating thereto shall be in accordance with the terms and conditions of this
permit.
If you wish to appeal or challenge any conditions imposed in this permit, a
petition shall be filed for modification or reissuance of this permit in
accordance with the requirements of [cite specific section of ordinance],
within 30 days of your receipt of this correspondence. Pursuant to [cite
specific section of ordinance], failure to petition for reconsideration of the
permit within the allotted time is deemed a waiver by the permittee of his
right to challenge the terms of this permit.
[Official Seal of Control Authority]
By: [Signature!
[Name and Title]
Issued this [Date] day of [Month], 19
9/15/89 FT
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APPENDIX F SAMPLE INDUSTRIAL USER PERMIT
Page 1 of 9
COVER PAGE
Permit No. [cite permit number]
INDUSTRIAL USER PERMIT
In accordance with the provisions of [cite specific section of ordinance]
Industrial User's Name
Location address
Mailing address (optional)
is hereby authorized to discharge industrial wastewater from the above
identified facility and through the outfalls identified herein into the [name
of Control Authority] sewer system in accordance with the conditions set forth
in this permit. Compliance with this permit does not relieve the permittee of
its obligation to comply with any or all applicable pretreatment regulations,
standards or requirements under local, State, and Federal laws, including any
such regulations, standards, requirements, or laws that may become effective
during the term of this permit.
Noncompliance with any term or condition of this permit shall constitute a
violation of the [name of Control Authority] sewer use ordinance.
This permit shall become effective on [Date] and shall expire at midnight on
[Date].
If the permittee wishes to continue to discharge after the expiration date of
this permit, an application must be filed for a renewal permit in accordance
with the requirements of [cite specific section of ordinance], a minimum of 90
days prior to the expiration date.
[Official Seal of Control Authority]
By: fSignature]
Superintendent
Issued this [Date] day of [Month], 19
9/15/89 F-2
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APPENDIX F SAMPLE INDUSTRIAL USER PERMIT
Page 2 of 9
PART 1 - EFFLUENT LIMITATIONS
A. During the period of [effective date of permit] to [expiration date of
permit] the permittee is authorized to discharge process wastewater to the
[name of Control Authority] sever system from the outfalls listed below.
Description of outfalls:
Outfall Descriptions
001 [The permit writer muat clearly identify the
outfalls using brief detailed narrative
002 descriptions and diagrams as necessary]
B. During the period of [Date] to [Date] the discharge from outfall 001 shall
not exceed the following effluent limitations. Effluent from this outfall
consists of [the permit writer should provide a description of the
discharges which are combined at this sampling location].
EFFLUENT LIMITATIONS
Parameter Daily maximum (ng/1) Monthly average (mg/1)
-- (gpd) -- (gpd)
[The permit writer must determine the applicable local. State, and Federal
standards that apply to the permittee and specify the most stringent
applicable effluent limits for each regulated pollutant.]
9/15/89 F-3
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APPENDIX F SAMPLE INDUSTRIAL USER PERMIT
Page 3 of 9
C. During the period of [Date] to [Date] the effluent fron outfall 002 shall
be of domestic or nonprocess vastewater only and shall comply with [cite
•pacific section of ordinance containing prohibited discharges and local
limits].
D. [The following specific discharge prohibitions may appear in the Effluent
Limits section or in the Standard Conditions section of the permit]. The
permittee shall not discharge wastewater containing any of the following
substances from any of the outfalls:
1. Fats, wax, grease, or oils of petroleum origin, whether emulsified or
not, in excess of one hundred (100) mg/1 or containing substances
which may solidify or become viscous at temperatures between 32
degrees F (0 degrees C) and 140 degrees F (60 degrees C);
2. Any gasoline, benzene, naphtha, fuel oil or other flammable or
explosive liquids, solids or gases;
3. Any effluent having a temperature higher than 104 degrees F (40
degrees C);
4. Any ashes, hair, cinders, sand, mud, straw, shavings, metal, glass,
rags, feathers, tar, plastics, wood, paunch, manure, or any other
solids capable of passing through [cite mesh screen size] or solid or
viscous substances capable of causing obstructions or other
interferences with proper operation of the sewer system;
5. Any pollutant, including oxygen demanding pollutants (BOD etc.) at
flow rate and/or concentration which will cause the pollutant to pass
through to the receiving waters or Interfere with the [name of Control
Authority] wastewater treatment facility. For the purpose of this
section, the terms "pass through" and "interference" have the same
definitions as appear in the City ordinance [cite specific section of
ordinance].
E. All discharges shall comply with all other applicable laws, regulations,
standards, and requirements contained in [cite specific section of
ordinance] and any applicable State and Federal pretreatment laws,
regulations, standards, and requirements including any such laws,
regulations, standards, or requirements that may become effective during
the term of this permit.
9/15/89 F-4
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APPENDIX F
SAMPLE INDUSTRIAL USER PERMIT
Page 4 of
PART 2 - MONITORING REQUIREMENTS
From the period beginning on the effective date of the permit until
[Date], the permittee shall monitor outfall [cite outfall number] for the
following parameters, at the indicated frequency:
[The following parameters are an example of vhat might be Included In this
section of the permit. The permit writer must Include all parameters
Identified in Part IB.]
Sample
Parameter (units)
Flow (gpd)
BOD
TSS
Arsenic
Cacimi urn (rag/1 )
Chromium (mg/1)
Copper (mg/1)
Lead (mg/1)
Mercury(mg/1)
Nickel (mg/1)
Zinc (mg/1)
Tri chlorophenol
(rag/1)4
Pent achlorophenol
(mg/1)4
PH
Measurement
Location
See
See
See
See
See
See
See
See
See
See
See
note
note'
note
note*
note'
note
note
note
note
note'
note
See note
See note
See note'
Frequency
Cont inuous
I/Year
I/Year
I/Year
1/Month
I/Month
I/Week
1/Month
I/Year
1/Month
I/Week
I/Quarter"5
I/Quarter5
Continuous
Sample Type
Meter'
Grab
Grab
24-hr
24-hr
24-hr
24-hr
24-hr
24-hr
24-hr
24-hr
Compos i te"
Compos i te'
Compos i t e1
Compos i te1
Composi te'
Compos i t e
Compos it e'
Compos i t e"
Grab
Grab
Meter6
[The permit writer needs to Include a diagram or narrative description
of sample locations.]
Daily flows are to be recorded from the permittee's flow meter.
Definitions of sample types. [The permit writer must determine the type
of composite sample (time or flow proportioned) and the sampling
duration (i.e., 8-hour, 12-hour, 24-hour) that Is most appropriate for
the Industrial user, and define It either here or In the standard
conditions.]
9/15/89
F-5
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APPENDIX F SAMPLE INDUSTRIAL USER PERMIT
Pago 5 of 9
4 The permittee may choose to submit a certification statement annually
due by [Date] stating that chlorophenolic containing biocides and
slimicides are not used at the facility rather than monitoring for
trichlorophenol and pentachlorophenol. [This provision applies only If
the user Is subject to the pulp and paper categorical standards].
5 Quarterly samples are to be analyzed once every three (3) months and
shall consist of three (3) samples collected in a (?) week period.
5 pH will be monitored and recorded continuously on the permittee's pH
meter.
All handling and preservation of collected samples and laboratory analyses
of samples shall be performed in accordance with 40 CFR Part 136 and
amendments thereto unless specified otherwise in the monitoring condi-
tions of this permit. [As an alternative, this requirement may be put in
the standard conditions section.]
PART 3 - REPORTING REQUIREMENTS
A. Monitoring Reports
Monitoring results obtained shall be summarized and reported on an
Industrial User Monitoring Report Form once per month. The reports are
due on the [specify date] day of each month. The first report is due on
[Date]. The report shall indicate the nature and concentration of all
pollutants in the effluent for which sampling and analyses were performed
during the calendar month preceding the submission of each report
Including measured maximum and average daily flows.
B. If the permittee monitors any pollutant more frequently than required by
this permit, using test procedures prescribed in 40 CFR Part 136 or
amendments thereto, or otherwise approved by EPA or as specified in this
permit, the results of such monitoring shall be included in any
calculations of actual daily maximum or monthly average pollutant
discharge and results shall be reported in the monthly report submitted to
the [name of Control Authority]. Such increased monitoring frequency
shall also be indicated in the monthly report. [As an alternative, this
requirement may be put in the standard conditions section.]
9/15/89 F-6
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APPENDIX F SAMPLE INDUSTRIAL USER PERMIT
Page 6 of 9
C. Automatic Resampling
If the result* of the permittee's wastewater analysis indicates that a
violation of this permit has occurred, the permittee must:
1. Inform the {name of Control Authority] of the violation within 24
hours; and
2. Repeat the sampling and pollutant analysis and submit, in writing, the
results of this second analysis within 30 days of the first violation.
D. Accidental Discharge Report
1. The permittee shall notify the [name of Control Authority] immediately
upon the occurrence of an accidental discharge of substances
prohibited by [cite specific section of ordinance] or any slug loads
or spills that may enter the public sewer. During normal business
hours the [name of Control Authority] should be notified by telephone
at [telephone number]. At all other times, the [name of Control
Authority] should be notified by telephone at either [telephone
number] or [telephone number] after 5 p.m. Monday - Friday or weekends
and holidays. The notification shall include location of discharge,
date and time thereof, type of waste, including concentration and
volume, and corrective actions taken. The permittee's notification of
accidental releases in accordance with this section does not relieve
it of other reporting requirements that arise under local, State, or
Federal laws.
Within five days following an accidental discharge, the permittee
shall submit to the [name of Control Authority] a detailed written
report. The report shall specify:
a. Description and cause of the upset, slug load or accidental
discharge, the cause thereof, and the impact on the permittee's
compliance status. The description should also include location of
discharge, type, concentration and volume of waste.
b. Duration of noncompllance, including exact dates and times of non-
compliance and, if the noncompliance is continuing, the time by
which compliance is reasonably expected to occur.
9/15/89 F-7
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Page 7 of 9
c. All steps taken or to be taken to reduce, eliminate, and/or prevent
recurrence of such an upset, slug load, accidental discharge, or
other conditions of noncompliance.
[A* an alternative, this requirement may be put in the standard
conditions section.]
E. All reports required by this permit shall be submitted to the [name of
Control Authority] at the following address:
[name of Control Authority]
Attn: [name of Pretreatment Coordinator]
Address
PART 4 - SPECIAL CONDITIONS
SECTION 1 - ADDITIONAL/SPECIAL MONITORING REQUIREMENTS.
[The permit writer needs to include any additional or special monitoring
requirements that are applicable to the permittee. Examples are provided
below.]
Examples:
A. One time monitoring for specific pollutants to verify absence (e.g., The
permittee shall submit by [Date] sampling data for pentachlorophenol and
trichlorophenol).
B. Biomonitoring or other toxicity to determine the toxicity of the
discharge.
C. Development of sludge disposal plan, slug loading control plan, or
industrial user management practices.
D. Additional monitoring of pollutants that are limited in the permit in
response to noncompliance.
SECTION 2 - REOPENER CLAUSE
[The permit writer should describe here any causes for modifying the permit
arising out of facts that are not common to all industrial users which will or
are likely to occur during its effective period. Examples are set out below.
(The more general reasons for modifying a permit may be stated in the standard
conditions section.)]
9/15/89F^8
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APPENDIX F
SAMPLE INDUSTRIAL USER PERMIT
Page 8 of
Examples :
A. This permit may he reopened and modified to incorporate any new or revised
requirements contained in a National categorical pretreatment standard
promulgated for the pesticide industrial category (40 CFR Part
This permit may be reopened and modified to incorporate any new or revised
requirements resulting from the [name of Control Authority] reevaluat ion
of its local limit for copper.
This permit may be reopened and modified to incorporate any new or revised
requirements developed by [name of Control Authority] as are necessary to
ensure POTV compliance with applicable sludge management requirements
promulgated by EPA (40 CFR 503).
SECTION 3 - COMPLIANCE SCHEDULE [Sample Compliance Schedule]
A. The permittee shall accomplish the following tasks in the designated time
period:
Event
1. New wastewater pretreatment plant design
completed
2. Equipment and materials ordered
3. Develop, and submit a copy to the [name of
Control Authority] slug loading control
plan to eliminate or minimize
the accidental spill or slug discharge of
pollutants into the sewer system
4. Implement the slug loading control
plan
5. Complete installation of wastewater pretreatment
plant
6. Obtain full pretreatment plant operational
status and achieve full compliance
No Later Thar.
[Date]
[Date]
[Date]
[Date]
[Date ]
[Date]
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F-9
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APPENDIX F SAMPLE INDUSTRIAL USER PERMIT
Page 9 of 9
B. Compliance Schedule Reporting
No later than 14 days following each date in the above schedule, the
permittee shall submit to the [name of Control Authority] a report
including, at a minimum, whether or not it complied with the increment of
progress to be met on such date and, if not, the date on which it expects
to comply with the increment of progress, the reasons for delay, and the
steps being taken to return the project to the schedule established.
PART 5 - STANDARD CONDITIONS
[The reader is referred to Appendix G for a List of standard conditions which
may be placed in industrial user permits.]
9/15/89 F-10
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APPENDIX C
SAMPLE STANDARD CONDITIONS FOR PERMITS
-------
APPENDIX G
SAMPLE STANDARD CONDITIONS FOR PERMITS
[This Appendix is to b« used in conjunction vith the sample permit in Appendix
F. The Control Authority should select (and modify if necessary) the standard
conditions listed here which best suit its needs.]
SECTION A. GENERAL CONDITIONS AND DEFINITIONS
1. Severability
The provisions of this permit are severable, and if any provision of this
permit, or the application of any provision of this permit to any
circumstance, is held invalid, the application of such provision to other
circumstances, and the remainder of this permit, shall not be affected
thereby.
2. Duty to Comply
The permittee must comply with all conditions of this permit. Failure to
comply with the requirements of this permit may be grounds for administrative
action, or enforcement proceedings including civil or criminal penalties,
injunctive relief, and summary abatements.
3. Duty to Mitigate
The permittee shall take all reasonable steps to minimize or correct any
adverse impact to the public treatment plant or the environment resulting from
noncompliance with this permit, including such accelerated or additional
monitoring as necessary to determine the nature and impact of the noncomplying
discharge.
4. Permit Modification
This permit may be modified for good causes including, but not limited to, the
following:
a. To incorporate any new or revised Federal, State, or local
pretreatment standards or requirements
b. Material or substantial alterations or additions to the discharger's
operation processes, or discharge volume or character which were not
considered in drafting the effective permit
9/15/89 G-l
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APPENDIX G SAMPLE STANDARD CONDITIONS FOR PERMITS
c. A change in any condition in either the industrial user or the POTU
that requires either a tenporary or permanent reduction or elimination
of the authorized discharge
d. Information indicating that the permitted discharge poses a threat to
the Control Authority's collection and treatment systems, POTW
personnel or the receiving waters
e. Violation of any terms or conditions of the permit
f. Misrepresentation or failure to disclose fully all relevant facts in
the permit application or in any required reporting
g. Revision of or a grant of variance from such categorical standards
pursuant to 40 CFR 403.13; or
h. To correct typographical or other errors in the permit
i. To reflect transfer of the facility ownership and/or operation to a
new owner/operator
j. Upon request of the permittee, provided such request does not create a
violation of any applicable requirements, standards, laws, or rules
and regulations.
The filing of a request by the permittee for a permit modification, revocation
and re issuance, or termination, or a notification of planned changes or
anticipated noncompliance, does not stay any permit condition.
5. Permit Termination
This permit may be terminated for the following reasons:
a. Falsifying self-monitoring reports
b. Tampering with monitoring equipment
c. Refusing to allow timely access to the facility premises and records
d. Failure to meet effluent limitations
e. Failure to pay fines
f. Failure to pay sewer charges
g. Failure to meet compliance schedules.
6. Permit Appeals
The permittee may petition to appeal the terms of this permit within thirty
(30) days of the notice.
9/15/89 G-2
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APPENDIX G SAMPLE STANDARD CONDITIONS FOR PERMITS
This petition nust be in writing; failure to submit a petition for review
shall be deemed to be a waiver of the appeal. In its petition, the permittee
must indicate the pernit provisions objected to, the reasons for this
objection, and the alternative condition, if any, it seeks to be placed in the
pernit.
The effectiveness of this permit shall not be stayed pending a reconsideration
by the Board. If, after considering the petition and any arguments put forth
by the Superintendent, the Board determines that reconsideration is proper, it
shall remand the permit back to the Superintendent for reissuance. Those
permit provisions being reconsidered by the Superintendent shall be stayed
pending reissuance.
A Board of Directors' decision not to reconsider a final permit shall be
considered final administrative action for purposes of judicial review. The
permittee seeking judicial review of the Board's final action must do so by
filing a complaint with the [nane of court] for [name of County] within
[insert appropriate State Statute of Limitations].
7. Property Rights
The issuance of this permit does not convey any property rights of any sort,
or any exclusive privileges, nor does it authorize any injury to private
property or any invasion of personal rights, nor any violation of Federal,
State, or local laws or regulations.
8. Limitation on Permit Transfer
Permits may be reassigned or transferred to a new owner and/or operator with
prior approval of the Superintendent:
a. The permittee must give at least thirty (30) days advance notice to
the Superintendent
b. The notice must include a written certification by the new owner
which:
(i) States that the new owner has no immediate intent to change the
facility's operations and processes
(ii) Identifies the specific date on which the transfer is to occur
(iii) Acknowledges full responsibility for complying with the existing
permit.
9/15/89 G-3
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APPENDIX G SAMPLE STANDARD CONDITIONS FOR PERMITS
9. Duty to Reapplv
If Che permittee wishes to continue an activity regulated by this permit after
the expiration date of this permit, the permittee must submit an application
for a new permit at least 90 days before the expiration date of this permit.
[Alternatively, this requirement may appear on the Cover Page.]
10. Continuation of Expired Permits
An expired permit will continue to be effective and enforceable until the
permit is reissued if:
a) The permittee has submitted a complete permit application at least
ninety (90) days prior to the expiration date of the user's existing
permit.
b) The failure to reissue the permit, prior to expiration of the previous
permit, is not due to any act or failure to act on the part of the
permittee.
11. Dilution
The permittee shall not increase the use of potable or process water or, in
any way, attempt to dilute an effluent as a partial or complete substitute for
adequate treatment to achieve compliance with the limitations contained in
this permit.
12. Definitions
a) Daily Maximum - The maximum allowable discharge of pollutant during a
calendar day. Where daily maximum limitations are expressed in units
of mass, the daily discharge is the total mass discharged over the
course of the day. Where daily maximum limitations are expressed in
terms of a concentration, the daily discharge is the arithmetic
average measurement of the pollutant concentration derived from all
measurements taken that day.
b) Composite Sample - A sample that is collected over time, formed either
by continuous sampling or by mixing discrete samples. The sample may
be composited either as a time composite sample: composed of discrete
sample aliquots collected in one container at constant time intervals
providing representative samples irrespective of stream flow; or as a
flow proportional composite sample: collected either as a constant
sample volume at time intervals proportional to stream flow, or
collected by increasing the volume of each aliquot as the flow
increases while maintaining a constant time interval between the
aliquots. [The permit writer should determine the most appropriate
composite sampling method to be used by the permittee.]
9/15/89(T4
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APPENDIX G _ SAMPLE STANDARD CONDITIONS FOR PERMITS
c) Grab Sample - An individual sample collected in less than 15 minutes,
without regard for flow or time.
d) Instantaneous Maximum Concentration - The maximum concentration
allowed in any single grab sample.
e) Cooling Water -
(1) Uncontaminated: Water used for cooling purposes only which has
no direct contact with any raw material, intermediate, or final
product and which does not contain a level of contaminants
detectably higher than that of the intake water.
(2) Contaminated: Water used for cooling purposes only which may
become contaminated either through the use of water treatment
chemicals used for corrosion inhibitors or biocides, or by direct
contact with process materials and/or wastewater.
f) Monthly Average - The arithmetic mean of the values for effluent
samples collected during a calendar month or specified 30 day period
(as opposed to a rolling 30 day window) .
g) Weekly Average - The arithmetic mean of the values for effluent
samples collected over a period of seven consecutive days.
h) fi£ -Weekly - Once every other week.
i) Bi -Monthly - Once every other month.
j) Upset - Means an exceptional incident in which there is unintentional
and temporary noncompliance with technology-based permit effluent
limitations because of factors beyond the reasonable control of the
permittee, excluding such factors as operational error, improperly
designed or inadequate treatment facilities, or improper operation and
maintenance or lack thereof.
k) Bypass - Means the intentional diversion of wastes from any portion of
a treatment facility.
13. General Prohibitive Standards
The permittee shall comply with all the general prohibitive discharge
standards in [reference specific section of ordinance]. Namely, the
industrial user shall not discharge wastewater to the sewer system:
a) Having a temperature higher than 10^» degrees F (40 degrees C) ;
b) Containing more than 100 ppm by weight of fats, oils, and grease;
9/15/89
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APPENDIX Jj SAMPLE STANDARD CONDITIONS FOR PERMITS
c) Containing any gasoline, benzene, naptha, fuel oil or other flammable
or explosive liquids, solids or gases; and in no case pollutants with
a closed cup flashpoint of less than one hundred forty (140) degrees
Fahrenheit (60° C), or pollutants which cause an exceedance of 10
percent of the Lower Explosive Limit (LEL) at any point within the
POTW.
d) Containing any garbage that has not been ground by household type or
other suitable garbage grinders;
e) Containing any ashes, cinders, sand, mud, straw, shavings, metal,
glass, rags, feathers, tar, plastics, wood, paunch, manure, or any
other solids or viscous substances capable of causing obstructions or
other interferences with proper operation of the sewer system;
f) Having a pH lower than 5.0 or higher than 11.0, or having any other
corrosive property capable of causing damage or hazards to structures,
equipment or personnel of the sewer system;
g) Containing toxic or poisonous substances in sufficient quantity to
injure or interfere with any wastewater treatment process, to
constitute hazards to humans or animals, or to create any hazard in
waters which receive treated effluent from the sewer system treatment
plant. Toxic wastes shall include, but are not limited to wastes
containing cyanide, chromium, cadmium, mercury, copper, and nickel
ions ;
h) Containing noxious or malodorous gases or substances capable of
creating a public nuisance; including pollutants which result in the
presence of toxic gases, vapors, or fumes;
i) Containing solids of such character and quantity that special and
unusual attention is required for their handling;
j) Containing any substance which may affect the treatment plant's
effluent and cause violation of the NPDES permit requirements;
k) Containing any substance which would cause the treatment plant to be
in noncompliance with sludge use, recycle or disposal criteria
pursuant to guidelines or regulations developed under section 405 of
the Federal Act, the Solid Waste Disposal Act, the Clean Air Act, the
Toxic Substances Control Act or other regulations or criteria for
sludge management and disposal as required by the State;
1) Containing color which is not removed in the treatment processes;
m) Containing any medical or infectious wastes;
9/15/89 G-6
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APPENDIX G SAMPLE STANDARD CONDITIONS FOR PERMITS
n) Containing any radioactive wastes or isotopes; or
o) Containing any pollutant, including BOD pollutants, released at a flow
rate and/or pollutant concentration which would cause interferenre
with the treatment plant.
14. Compliance with Applicable Pretreatment Standards and Requirements
Compliance with this permit does not relieve the permittee from its
obligations regarding compliance with any and all applicable local, State and
Federal pretreatment standards and requirements including any such standards
or requirements that may become effective during the term of this permit .
SECTION B. OPERATION AND MAINTENANCE OF POLLUTION CONTROLS
1. Proper Operation and Maintenance
The permittee shall at all times properly operate and maintain all facilities
and systems of treatment and control (and related appurtenances) which are
installed or used by the permittee to achieve compliance with the conditions
of this permit. Proper operation and maintenance includes but is not limited
to: effective performance, adequate funding, adequate operator staffing and
training, and adequate laboratory and process controls, including appropriate
quality assurance procedures. This provision requires the operation of
back-up or auxiliary facilities or similar systems only when necessary to
achieve compliance with the conditions of the permit.
2. Duty to Halt or Reduce Activity
Upon reduction of efficiency of operation, or loss or failure of all or part
of the treatment facility, the permittee shall, to the extent necessary to
maintain compliance with its permit, control its production or discharges (or
both) until operation of the treatment facility Is restored or an alternative
method of treatment is provided. This requirement applies, for example, when
the primary source of power of the treatment facility fails or is reduced. It
shall not be a defense for a permittee in an enforcement action that it would
have been necessary to halt or reduce the permitted activity in order to
maintain compliance with the conditions of this permit.
3. Bypass of Treatment Facilities
a) Bypass is prohibited unless it is unavoidable to prevent loss of life,
personal injury, or severe property damage or no feasible alternatives
exist.
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APPENDIX G SAMPLE STANDARD CONDITIONS FOR PERMITS
b) The permittee may allow bypass to occur which does not cause effluent
limitations to be exceeded, but only if it is also for essential main-
tenance to assure efficient operation.
c) Notification of bypass:
(1) Anticipated bypass. If the permittee knows in advance of the
need for a bypass, it shall submit prior written notice, at least
ten days before the date of the bypass, to the [name of Control
Authority].
(2) Unanticipated bypass. The permittee shall immediately notify the
[name of Control Authority] and submit a written notice to the
POTW within 5 days. This report shall specify:
(i) A description of the bypass, and its cause, including its
duration;
(ii) Whether the bypass has been corrected; and
(iii) The steps being taken or to be taken to reduce, eliminate
and prevent a reoccurrence of the bypass.
4. Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of
treatment or control of wastewaters shall be disposed of in accordance with
section 405 of the Clean Water Act and Subtitles C and D of the Resource
Conservation and Recovery Act. [The Control Authority should add citations to
local or State regulations that may apply]
SECTION C. MONITORING AND RECORDS
1. Representative Sampling
Samples and measurements taken as required herein shall be representative of
the volume and nature of the monitored discharge. All samples shall be taken
at the monitoring points specified in this permit and, unless otherwise
specified, before the effluent joins or is diluted by any other wastestream,
body of water or substance. All equipment used for sampling and analysis must
be routinely calibrated, inspected and maintained to ensure their accuracy.
Monitoring points shall not be changed without notification to and the
approval of the [name of Control Authority].
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APPENDIX G SAMPLE STANDARD CONDITIONS FOR PERMITS
2. Flow Measurements
If flow measurement is required by this permit, the appropriate flow
measurement devices and methods consistent with approved scientific practices
shall be selected and used to ensure the accuracy and reliability of
measurements of the volume of monitored discharges. The devices shall be
installed, calibrated, and maintained to ensure that the accuracy of the
measurements are consistent with the accepted capability of that type of
device. Devices selected shall be capable of measuring flows with a maximum
deviation of less than 10 percent from true discharge rates throughout the
range of expected discharge volumes.
3. Analytical Methods to Demonstrate Continued Compliance
All sampling and analysis required by this permit shall be performed in
accordance with the techniques prescribed in ^*0 CFR Part 136 and amendments
thereto, otherwise approved by EPA, or as specified in this permit.
4. Additional Monitoring by the Permittee
If the permittee monitors any pollutant more frequently than required by this
permit, using test procedures identified in Section C.3, the results of this
monitoring shall be included in the permittee's self-monitoring reports.
5. Inspection and Entry
The permittee shall allow the [name of Control Authority], or an authorized
representative, upon the presentation of credentials and other documents as
may be required by law, to:
a) Enter upon the permittee's premises where a regulated facility or
activity is located or conducted, or where records must be kept under
the conditions of this permit;
b) Have access to and copy, at reasonable times, any records that must be
kept under the conditions of this permit;
c) Inspect at reasonable times any facilities, equipment (including
monitoring and control equipment), practices, or operations regulated
or required under this permit;
d) Sample or monitor, for the purposes of assuring permit compliance, any
substances or parameters at any location; and
e) Inspect any production, manufacturing, fabricating, or storage area
where pollutants, regulated under the permit, could originate, be
stored, or be discharged to the sewer system.
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APPENDIX G SAMPLE STANDARD CONDITIONS FOR PERMITS
6. Retention of Records
a) The permittee shall retain records of all monitoring information,
including all calibration and maintenance records and all original
strip chart recordings for continuous monitoring instrumentation,
copies of all reports required by this permit, and records of all data
used to complete the application for this permit, for a period of at
least three years from the date of the sample, measurement, report or
application.
This period may be extended by request of the [name of Control
Authority] at any time.
b) All records that pertain to matters that are the subject of special
orders or any other enforcement or litigation activities brought by
the [name of Control Authority] shall be retained and preserved by the
permittee until all enforcement activities have concluded and all
periods of limitation with respect to any and all appeals have
expi red.
7. Record Contents
Records of sampling and analyses shall include:
a) The date, exact place, time, and methods of sampling or measurements,
and sample preservation techniques or procedures;
b) Who performed the sampling or measurements;
c) The date(s) analyses were performed;
d) Who performed the analyses;
e) The analytical techniques or methods used; and
f) The results of such analyses.
8. Falsifying Information
Knowingly making any false statement on any report or other document required
by this permit or knowingly rendering any monitoring device or method
inaccurate, is a crime and may result in the imposition of criminal sanctions
and/or civil penalties.
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APPENDIX G SAMPLE STANDARD CONDITIONS FOR PERMITS
SECTION D. ADDITIONAL REPORTING REQUIREMENTS
1. Planned Changes
The permittee shall give notice to the [name of Control Authority] 90 days
prior to any facility expansion, production increase, or process modifications
which results in new or substantially increased discharges or a change in the
nature of the discharge. [Alternatively, this requirement may appear in Part
3, Reporting Requirements, of the permit.]
2. Anticipated Noncompliance
The permittee shall give advance notice to the [name of Control Authority] of
any planned changes in the permitted facility or activity which may result in
noncompliance with permit requirements.
3. Automatic Resampling
If the results of the permittees's wastewater analysis indicates a violation
has occurred, the permittee must notify the [name of Control Authority] within
2k hours of becoming aware of the violation and repeat the sampling and
pollutant analysis and submit, in writing, the results of this repeat analysis
within 30 days after becoming aware of the violation.
4. Duty to Provide Information
The permittee shall furnish to the [name of Control Authority], within
[specify time] any information which the [name of Control Authority] may
request to determine whether cause exists for modifying, revoking and
reissuing, or terminating this permit, or to determine compliance with this
permit. The permittee shall also, upon request, furnish to the [name of
Control Authority] within [specify time] copies of any records required to be
kept by this permit.
5. Signatory Requirements [use whichever alternative best applies]
All applications, reports, or information submitted to the [name of Control
Authority] must contain the following certification statement and be signed as
required in Sections (a), (b), (c) or (d) below:
"I certify under penalty of law that this document and all attachments
were prepared under my direction or supervision in accordance with a
system designed to assure that qualified personnel properly gather and
evaluate the information submitted. Based on my inquiry of the person
or persons who manage the system, or those persons directly
responsible for gathering the information, the information submitted
is, to the best of my knowledge and belief, true, accurate, and
complete. I an aware that there are significant penalties for
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APPENDIX G SAMPLE STANDARD CONDITIONS FOR PERMITS
submitting false information, including the possibility of fine and
imprisonment for knowing violations."
a) By a responsible corporate officer, if the Industrial User submitting
the reports is a corporation. For the purpose of this paragraph, a
responsible corporate officer means:
(i) a president, secretary, treasurer, or vice-president of the
corporation in charge of a principal business function, or any
other person who performs similar policy- or decision-making
functions for the corporation, or;
(ii) the manager of one or more manufacturing, production, or
operation facilities employing more than 250 persons or having
gross annual sales or expenditures exceeding $25 million (in
second-quarter 1980 dollars), if authority to sign documents has
been assigned or delegated to the manager in accordance with
corporate procedures.
b) By a general partner or proprietor if the Industrial User submitting
the reports is a partnership or sole proprietorship respectively.
c) The principal executive officer or director having responsibility for
the overall operation of the discharging facility if the Industrial
User submitting the reports is a Federal, State, or local governmental
entity, or their agents.
d) By a duly authorized representative of the individual designated in
paragraph (a), (b), or (c) of this section if:
(i) the authorization is made in writing by the individual described
in paragraph (a), (b), or (c);
(ii) the authorization specifies either an individual or a position
having responsibility for the overall operation of the facility
from which the Industrial Discharge originates, such as the
position of plant manager, operator of a well, or a well field
superintendent, or a position of equivalent responsibility, or
having overall responsibility for environmental matters for the
company; and
(ill) the written authorization is submitted to the City.
e) If an authorization under paragraph (d) of this section is no longer
accurate because a different individual or position has responsibility
for the overall operation of the facility, or overall responsibility
for the environmental matters for the company, a new authorization
satisfying the requirements of paragraph (d) of this section must be
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APPENDIX G SAMPLE STANDARD CONDITIONS FOR PERMITS
submitted to the City prior to or together with any reports to be
signed by an authorized representative.
6. Operating Upsets
Any permittee that experiences an upset in operations that places the
permittee in a temporary state of noncompliance with the provisions of either
this permit or with [reference specified section of ordinance] shall inform
the [name of Control Authority] within 24 hours of becoming aware of the upset
at [daytime telephone number] or [night tine and weekend telephone number]
after 5 p.m. Monday - Friday or weekends and holidays.
A written follow-up report of the upset shall be filed by the permittee with
the [name of Control Authority] within five days. The report shall specify:
a) Description of the upset, the cause(s) thereof and the upset's impact
on the permittee's compliance status;
b) Duration of noncompliance, including exact dates and times of
noncompliance, and if not corrected, the anticipated time the
noncompliance is expected to continue; and
c) All steps taken or to be taken to reduce, eliminate and prevent
recurrence of such an upset.
The report must also demonstrate that the treatment facility was being
operated in a prudent and workmanlike manner.
A documented and verified operating upset shall be an affirmative defense to
any enforcement action brought against the permittee for violations
attributable to the upset event.
7. Annual Publication
A list of all industrial users which were subject to enforcement proceedings
during the twelve (12) previous months shall be annually published by the
[name of Control Authority] in the largest daily newspaper within its service
area. Accordingly, the permittee is apprised that noncompliance with this
permit may lead to an enforcement action and may result in publication of its
name in an appropriate newspaper in accordance with this section.
8. Civil and Criminal Liability
Nothing in this permit shall be construed to relieve the permittee from civil
and/or criminal penalties for noncompliance under [reference specific section
of ordinance] or State or Federal laws or regulations.
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AP_PENDIX_G SAMPLE STANDARD CONDITIONS FOR PERMITS
9. Penalties for Violations of Permit Conditions
The [cite specific section of ordinance] provides that, any person who violates
a permit condition is subject to a civil penalty of at least [cite dollar
amount] per day of such violation. Any person who willfully or negligently
violates permit conditions is subject to criminal penalties of a fine of up to
[cite dollar amount] per day of violation, or by imprisonment for [number] of
yoar(s), or both. The permittee may also be subject to sanctions under State
and/or Federal law.
10. Recovery of Costs Incurred
In addition to civil and criminal liability, the permittee violating any of
the provisions of this permit or [reference specific section of ordinance] or
causing damage to or otherwise inhibiting the [name of Control Authority]
wascewater disposal system shall be liable to the [name of Control Authority]
for any expense, loss, or damage caused by such violation or discharge. The
[name of Control Authority] shall bill the permittee for the costs incurred by
the [name of Control Authority] for any cleaning, repair, or replacement work
caused by the violation or discharge. Refusal to pay the assessed costs shall
constitute a separate violation of [reference specific section of ordinance].
9/15/89 G-14
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APPENDIX H
INDUSTRIAL USER MANAGEMENT PRACTICES
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APPENDIX H
INDUSTRIAL USER MANAGEMENT PRACTICES
Industrial user management practices are measures undertaken by
industrial users to prevent or minimize the potential for release of
pollutants in significant amounts to the sewer system. Industrial user
management practices used by industries for preventing spills or slug loads
are essentially the same as those typically used for safety, industrial
hygiene, fire protection, protection against loss of product, insurance
company requirements, and public relations. Industrial user management
practices typically address the following sources of pollution:
• Toxic and hazardous chemical spills and leaks
• Plant site runoff
• Sludge and waste disposal
• Drainage from material storage areas
• Other "good housekeeping" practices.
Industrial user management practices are grouped into two general
categories: baseline and advanced. Both baseline and advanced industrial
user management practices can include the following types of management
practices:
• Establishment of a Slug. Control Committee responsible for implementa-
tion and maintenance of an industry's slug loading control plan
• Maintenance of a material inventory system to identify all sources
and quantities of toxic and hazardous materials handled and produced
within the industrial user's facilities
• Establishment of employee training programs to provide personnel of
all levels with a complete understanding of the facility's slug
loading control plan or toxic organic management plan
• Establishment of preventive maintenance procedures to inspect plant
equipment and other systems to discover conditions that could cause
production breakdowns or harmful deterioration of systems, and the
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APPENDIX__H INDUSTRIAL USER MANAGEMENT PRAt'.T I CHS
correction of such conditions through adjustment, repair, or
replacement of worn parts before equipment or system failure
resulting in spills
• Conducting routine visual inspections that consist of tours or
patrols throughout the plant facilities to detect spills or evi timer
of conditions that could lead to slug loading
• Improvement of good housekeeping practices essential to the
maintenance of a clean and orderly working environment
• Evaluation of the compatibility of chemicals and other materials with
the containers in which they are stored, with other materials with
which they are mixed, the compatibility of the container with the
environment, and adjustment of material storage or handling practices
accordingly
• Establishment of a security system to prevent accidental or inten-
tional entry into the plant that could lead to a chemical release
• Use of a slug loading reporting system to maintain records for tin-
purpose of reporting slug loading, studying slug loading recurrence,
expediting mitigation or cleanup activities, and complying with legal
requirements.
Baseline management practices are:
• Generally applicable to all industries
• Relatively low in cost and simple to implement
• Not directed to particular pollutant compounds
Advanced industrial user management practices, on the other hand, are
used in addition to baseline management practices to provide a further level
of protection for preventing arid controlling chemical releases. Advanced
industrial user management practices are specific to groups of toxics and
hazardous substances and can be divided into the following four categories of
management practices:
Prevention practices including monitoring systems, nondestructive
testing, labeling, covering or enclosing materials, equipment or
process operations, and other techniques used to prevent material
spills
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APPENDI_X_H INDUSTRIAL USER MANAGEMENT PRACTICES
• Containment practices used to contain or capture releases of
materials within the industrial premises
• Mitigation practices for the cleanup and treatment of spill materials
• Ultimate disposition practices for the proper disposal of spilled
materials,
Control Authorities may choose to require implementation of one or more
of the management practices discussed above. Management practices or programs
should be designed and tailored for each industrial user's individual
situation. The requirements for implementation should be incorporated into
the special conditions section of an industrial user's permit, as discussed in
Chapter 10 of this manual. For more information on industrial user management
practices, the permit writer should read the draft NPDES Best Management
Practices Guidance Document, Development of Slug Loading Control Programs for
Publicly-Owned Treatment Works, and Guidance Manual for Implementing. Total
Toxic Organic (TTO) Pretreatment Standards.
9/15/89 H-3
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APPENDIX I
SAMPLE FACT SHEET
-------
APPENDIX I
SAMPLE FACT SHEET
1. SYNOPSIS OF APPLICANT INFORMATION
a. Name and Address of Applicant
[Name of Industry]
1224 Anything Road
[City], NJ 12345
(222) 333-4444
b. Description of Applicant's Operation
[Name of Industry] is a manufacturer of sealed lead-acid batteries
(SIC 3691). Descriptions of the specific industrial operations
involved in the battery manufacturing process at [Name of Industry]
have been described in four industry submittals dated February 24,
1988, January 26, 1988, and March 29, 1988. These submittals may be
found in Attachment A of this document. Based on this information, a
table was developed to compare the subprocesses identified by [Name
of Industry] to those referenced in EPA's Battery Manufacturing
Development Documents. This table may be found in Attachment B.
c. Production Data
Thus far, [Name of Industry] has submitted monthly production data
for 1985, 1986, and 1987, and an estimate of production for 1988.
This information may be found in Attachment C.
d. Name of Control Authority's Wastewater Treatment Plant Receiving the
Vastewater
Northeast Plant
e. Description of Existing Pollution Abatement Facilities
(See Figure 1 - Attachment D)
Pipe 01: Wastestreams from the pasting area are subjected to
chemical precipitation and settling and combined with wastestreams
from acid mixing, acid fill, battery cooling, and qualification prior
to pH adjustment and discharge to the City's sewer.
Pipe 02: Wastestreams from handwash, showers, toilets, and tech labs
are discharged to the City's sewer with no treatment.
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APPENDIX I SAMPLE FACT SHEET
f. Description of Discharges (as reported by applicant)
The infomation provided by [Nane of Industry], with respect to
effluent characteristics, includes third and fourth quarter 1987
monitoring data (at Pipe 03), a 1987 flow diagram, and a 1985
baseline monitoring report. The 1987 monitoring reports are included
in Attachment E. A review of water utility meter readings for this
facility revealed a significant variance in both short and long term
water use. A comparison of these records with production information
did not reveal a significant correlation.
Pipe 01: 4,560 gallons per day for chemical precipitation combined
with 7,100 gallons per day of other process flows prior to pH
treatment and discharge to Pipe 01 (11,660 gpd).
Pipe 02: 4,000 gallons per day from sanitary wastewater sources,
including handwashing, combined with 1,000 gallons per day from tech
labs (5,000 gpd).
2. PROPOSED FINAL EFFLUENT LIMITATIONS
Effective no later than the effective date of this permit, and lasting
until the expiration date of this permit, (Name of Industry] is authorized to
discharge wastewater from Pipes 01 and 02. Pipes 01 and 02 are as identified
in Figure 1, Attachment D. These discharges shall be limited as specified
below:
Part 1 - Effluent Limits based on Categorical Standards [40 CFR 461.34(a)(9)
Miscellaneous Wastewater Streams (PSES)]
(Must be met at the combined discharges of Pipes 01 and 02.)
EFFLUENT LIMITATIONS
Parameter
Flow
Total Copper
Total Lead
Mass LoadinE
Daily
Report (MGD)
0.021
0.005
(Ibs/dav)
Monthly
Average
Report (MGD)
0.011
0.002
Concentration (me/1)
Daily
Report
Report
Monthly
Average
Report
Report
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APPENDIX I SAMPLE Tf
Part 2 - Effluent Limits based on Local Linits [Sewer Use Ordinance
Section 99]
(Limits will be applied at the connection to the City's sewer)
Instantaneous Maximum
Instantaneous Maximum Concentration in
Parameter Mass Loading (mg/1) Any Sample (mg/1)
Flow Report Report (in mgd)
Total Arsenic Report 1.0
Total Cadmium Report 1.5
Total Copper Report 4.0
Total Cyanide Report 1.0
Total Lead Report 1.0
Total Mercury Report 0.1
Total Nickel Report 4.0
Total Silver Report 1.0
Total Chromium Report 6.0
Total Zinc Report 4.0
pH Report 5.0 - 9.0 s.u
Rationale for Effluent Limitations
Two sets of limits will apply to the discharges from this facility to
the sanitary sewers of the [Name of City]. Equivalent mass-based categorical
pretreatment standards will apply to the combined wastewater streams (Pipes 01
and 02). These categorical standards are based on categorical pretreatment
standards set forth in the Code of Federal Regulations [40 CFR 461.34(a)(9)].
Local sewer use ordinance limits will apply to the combined process,
unregulated, and dilution waste streams at the point of discharge to the
City1s sewers.
The battery manufacturing categorical pretreatment standards allow a
certain pollutant mass in each regulated battery manufacturing process
wastestream. The allowance for the total combined process wastestream is
determined by the summation of all of the allowances for each process
wastestream. Because of the fluctuations in water use at this facility, the
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APPENDIX I SAMPLE FACT SHEET
effluent limits based on categorical standards will be mass limits (Ib/day) as
opposed to concentration limits (mg/1).
Total copper and total lead are the only pollutants regulated by battery
manufacturing categorical pretreatment standards for the processes used by the
permittee. For [Name of Industry], the only regulated process flows that
receive a discharge allowance are floor wash, laboratory flows, and hand wash
flows. These operations fall under the "miscellaneous wastewater streams"
category and receive a one-time discharge allowance based on the production
rate of the facility. None of the other processes at this facility receive
any discharge allowance under categorical standards. Because regulated flows
are contained in both of this facility's discharges (Pipes 01 and 02), this
allowance will be applied to the combined discharge from these wastestreams.
The pretreatment standards (PSES) obtained from 40 CFR 461.34(a)(9) and EPA
guidance documents are given below:
Production-based Limitation
(Ibs per million Ibs of lead used)
Pollutant/Process Daily Maximum Monthly Average
Copper, total
Lead, total
0.58
0.13
0.31
0.06
To calculate the equivalent mass-based limits it was necessary to
determine the amount of pure lead used at this facility and the amount of lead
contained in the lead pastes. Because of the rapid expansion of this facility
over the past several years, the production rate was based on the estimated
1988 data only. The amount of pure lead used during the three highest
production months was averaged and a daily lead usage value was determined
from this average amount (based on a 22 day-per-month work schedule). This
average daily lead usage value was then multiplied by the allowance values,
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APPENDIX I SAMPLE FACT SHEET
presented above, to obtain the daily aaxinum and monthly average nass-per-day
permissible in [Name of Industry] total discharge.
The actual calculation of [Name of Industry] effluent limits was
performed as follows:
1) Production Rate Calculations (Ibs per million Ibs of lead used)
[Name of Industry] supplied the following projected lead usage
figures for the three highest production months of 1988:
Lead Oxides Usage (Ibs) Pure Lead Usage (Ibs)
October 438,000 400,000
November 428,000 448,000
December 386.000 400.000
1,252,000 1,248,000
The amount of pure lead in the lead oxides was calculated based on
information provided by [Name of Industry] representatives during the meeting
of 3/29/88. Pure lead in "red lead" is 91 percent and in "litharge" is
93 percent. Fifty percent of the lead oxides used are red lead and 50 percent
are litharge. Therefore the weight of pure lead in the lead oxides is:
(0.91)(0.5)(1,252.000) + (.93)(0.5)(1.252.000) - 1.152.000 Ibs
The monthly arithmetic mean for these three months is, therefore:
(1,152,000 -I- l,248,000)/3 - 800,000 Ibs/month. Based on a 22 day-per-month
work schedule, the daily lead use is, 800,000/22 - 36,400 Ibs/day.
2) Effluent Limit Calculation (Example: Daily Maximum for copper)
Production Rate x Categorical Standard - Mass-Loading
(0.0364 million Ibs lead used/day)(0.58 Ibs copper/million Ibs lead used) -
0.021 Ibs copper/dav
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APPENDIX I
»iCT SHEET
Effluent Units for the remaining regulated parameters were calculated
in the sane manner and the results are presented in Section 2, Part 1 of this
fact sheet.
3.
MONITORING REQUIREMENTS
Effective no later than the effective date of this permit, and lasting
until the expiration date of this permit, [Nane of Industry] is authorized to
discharge wastewater from Pipes 01 and 02. Pipes 01 and 02 are as identified
in Figure 1, Attachment D.
These discharges shall be monitored as specified below:
Part 1 - Categorical Standards
Measurement
parameter
Flow
Total Copper
Total Lead
Sample
Frequency
Continuous
I/Month
I/Month
Type
Record
24-hr Composite
24-hr Composite
Part 2 - Local Limits
Measurement
Pflrajeter
Flow
Total Arsenic
Total Cadmium
Total Copper
Total Cyanide
Total Lead
Total Mercury
Total Nickel
Total Silver
Total Chromium
Total Zinc
pH Continuous
Sample
Frequency
Continuous
1/6 months
1/6 months
I/Month
1/6 months
I/Month
1/6 months
1/6 months
1/6 months
1/6 months
I/month
Record
Type
Record
24-hr Composite
24-hr Composite
24-hr Composite
Grab
24-hr Composite
24-hr Composite
24-hr Composite
24-hr Composite
24-hr Composite
24-hr Composite
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1-6
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APPENDIX I SAMPLE FACT SHEET
Because of the wide variation in water usage at this facility, the
applicant will be required to monitor wastewater flows continuously at each
pipe. The minimum frequency of sampling for all other parameters will be once
per six calendar months. All samples will be 24-hour flow proportioned com-
posites. Past practices have caused several exceedances of current effluent
limits for lead, copper, and zinc and variations in production rates and
wastewater flows have been noted. Therefore, monthly sampling of lead,
copper, and zinc is required to provide an adequate characterization of
effluent quality at this facility. For the other contaminants limited by this
permit, sampling will be required once every six months in accordance with the
City's minimum monitoring frequency requirements in the sewer use ordinance
and in the City's permitting policies and procedures document. The baseline
monitoring report (BMR) has revealed that they are not currently a problem so
an increase from the minimum monitoring frequency will not be required.
Monitoring will be required at three locations at the [Name of Industry]
facility as follows:
1) Pipe 01 - The connection of the discharge from the pH treatment unit
to the City's sewer. The processes which contribute to this
wastestream may be seen in Figure 1, Attachment D. This location
will be sampled and limited as defined in Sections 2 and 3, above.
2) Pipe 02 - The connection of the combined hand wash, shower, toilet,
and tech lab discharges to the City's sewer. This discharge is
described schematically in Figure 1, Attachment D. This location
will be sampled and limited as defined in Sections 2 and 3, above.
3) Pipe 03 - The discharge from the lead treatment unit (chemical
precipitation) as shown in Figure 1, Attachment D. This location
will be monitored daily for lead and monthly for copper. No effluent
limits will be applied directly at this location; however, no addi-
tion of lead or copper is permissible at this discharge according to
categorical standards.
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APPENDIX I SAMPLE FACT SHEET
4. REPORTING REQUIREMENTS
Industrial user reporting requirements will be in accordance with those
outlined in the City's permitting policies and procedures. In addition, [Name
of Industry] will be required to submit monthly production data (in Ibs/month)
and all water meter readings (in gpd). Production data will be used to
determine if the production rate varies more than 20 percent from that used in
calculation of effluent standards in order to determine whether permit limits
must be modified. For each sampling location, wastewater flow data, effluent
analytical results, calculation of mass loadings, and continuous pH chart
records must also be submitted. All required reports must be submitted
quarterly.
5. STANDARD CONDITIONS
The industrial user permit for [Name of Industry] will include all of
the standard conditions listed in City's Permitting Policies and Procedures
Document.
6. SPECIAL CONDITIONS
a. Flow measuring devices will be required at Pipes 01, 02, and 03.
b. The permittee will be required to maintain and calibrate these flow
measuring devices according to manufacturer's recommendations and
submit verification of these procedures with quarterly monitoring
reports.
c. Because an industry site visit revealed the storage of hazardous
chemicals in the facility, the permittee must develop and implement a
spill prevention and control plan for the facility. The plan must be
approved by the City and implemented according to the compliance
schedule contained in the permit. However, approval of this plan by
the City does not relieve the permittee from its requirements to meet
all applicable local, State, and Federal laws and regulations.
[NOTE: Actual Appendices are not included.]
THE PERMIT WRITER NEEDS TO INCLUDE ANT SUPPORTING DOCUMENTATION SUCH AS
MATERIAL SUBMITTED BY THE INDUSTRIAL USER, CALCULATIONS, ETC. AS APPENDICES.
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APPENDIX I SAMPLE FACT SHEET
ATTACHMENT A - Industry Submittals
ATTACHMENT B - Table of Regulated Subprocesses
ATTACHMENT C - Monthly Production Data
ATTACHMENT D - Description of Existing Pollution Abatement Facilities
ATTACHMENT E - Monitoring Data
9/15/89 1-9
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APPENDIX J
SAMPLE WASTE HAULER PERMIT
-------
APPENDIX J
SAMPLE WASTE HAULER PERMIT
COVER PAGE
Permit No. [cite permit number]
In accordance with the provisions of [cite specific section of ordinance]
Waste Hauler's Name
Location Address
Mailing Address (optional)
is hereby authorized to discharge hauled wastewater to the [name of Control
Authority] sewer system located at [POTW Address] in accordance with the
conditions set forth in this permit. Compliance with this permit does not
relieve their permittee of its obligation to comply with any or an applicable
pretreatment regulations, standards, or requirements under Federal, State, or
local laws, including any such regulations, standards, requirements, or laws
that may become effective during the term of this permit.
Noncompliance with any term or condition of this permit shall constitute a
violation of the (name of Control Authority] sewer use ordinance.
This permit shall become effective on [Date] and shall expire at midnight on
[Date].
If the permittee wishes to continue to discharge after the expiration date of
this permit, an application must be filed for a renewal permit in accordance
with the requirements of [cite specific section of ordinance], a minimum of 90
days prior to the expiration date.
If you wish to appeal or challenge any conditions imposed in this permit, a
petition shall be filed for modification or reissuance of this permit in
accordance with the requirements of [cite specific section of ordinance],
within 30 days of your receipt of this correspondence. Pursuant to [cite
specific section of ordinance], failure to petition for reconsideration of the
permit within the allotted time is deemed a waiver by the permittee of his
right to challenge the terms of this permit.
[Official Seal of Control Authority]
By: fSignature!
Superintendent
Issued this [Date] day of [Month], 19
9/15/89
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APPENDIX J SAMPLE UASTE HAULER PERMIT
SECTION 1 - DISCHARGE REQUIREMENTS
A. The discharge of all hauled wastes oust be performed at the following
designated area: [provide description of designated area]. Discharge
to [name of Control Authority] sewer system at any other location is
prohibited. The permittee must provide prior notice to the [name of
Control Authority] of the intent to discharge and the actual discharge
must be performed during supervision by plant personnel. In all cases,
discharge may only be performed Monday through Friday 8:00 a.m. to
4:00 p.m.
B. Hauled wastes are subject to sampling by [name of Control Authority].
The hauler may also be required to suspend the discharging of wastes
until the analysis is complete. The [naue of Control Authority]
reserves the right to refuse permission to dump any load.
SECTION 2 - SPECIFIC LIMITATIONS
A. Any commercial or industrial waste that may cause pass through of
pollutants or interference with the wastewater treatment plant
operations or that violates Federal, State, or local restrictions shall
not be discharged to the wastewater treatment plant.
B. Any waste transported from an industry subject to categorical pretreat-
ment standards must meet the applicable Federal categorical standards.
Authorization by the [nane of Control Authority] prior to pumping must
be obtained for the hauling of categorical wastes.
C. The permittee is prohibited from discharging wastes with the following
characteristics:
Having a pH lower than 6.0 or higher than 9.0;
Containing fats, wax, grease, or oils of petroleum origin, whether
emulsified or not, in excess of one hundred (100) mg/1 or containing
substances which may solidify or become viscous at temperatures
between thirty-two (32°F) degrees and one hundred forty (140°F)
degrees Fahrenheit (0 degrees and 60 degrees Centigrade);
Containing any gasoline, benzene, naphtha, fuel oil or other
flammable or explosive liquids, solids or gases;
- Having a temperature higher than 104°F (40°C);
9/15/89 J-2
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APPENDIX J SAMPLE WASTE HAULER PERMIT
Containing any ashes, cinders, sand, mud, straw, shavings, metal,
glass, rags, feathers, tar, plastics, wood, paunch, manure, or any
other solids or viscous substances capable of causing obstructions or
other interferences with proper operation of the sewer system;
Containing any pollutant, including oxygen demanding pollutants (BOD
etc.) at flow rate and/or concentration which will cause a pass
through of pollutants to occur or an interference with the [name of
Control Authority] wastewater treatment facility's operations or
sludge use and/or disposal practices;
Material considered a hazardous waste under the Resource Conservation
and Recovery Act (RCRA).
D. The permittee is prohibited from discharging wastes which exceed the
following limitations: [Th« permit writer mitt apply local linitt or
any applicable, more stringent categorical standards.]
Arsenic nig/1
Barium
Cadmium ng/1
Chromium n»g/l
Copper mg/1
Cyanide nig/1
Lead og/1
Mercury fflg/1
Nickel mg/1
Silver ng/1
Zinc mg/1
Selenium »g/l
Oil and Grease »g/l
pH s. u.
SECTION 3 - MONITORING AND RECORDS
A. All wastes must be accompanied by a completed waste manifest form. The
form shall contain information regarding the wastes from and the
signature of, each waste generator. The hauler shall also sign the
form, indicating that he has accepted no wastes other than those listed.
The manifest must be reviewed by a Control Authority representative
9/15/89 JO
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APPENDIX J SAMPLE WASTE HAULER PERMIT
prior to discharge. Failure Co accurately record every load,
falsification of data, or failure to transmit the form to the plant
operator prior to discharge may result in revocation of this permit or a
fine of up to [cite dollar amount] per offense. [The permit writer
should insert criminal penalties provided for in ordinance.]
B. Any waste identified as a commercial or industrial waste, as defined in
[cite specific section of ordinance] must be presampled prior to pick-up
by the waste hauler and the results of that sampling submitted to [name
of Control Authority]. The permittee must receive approval from [name
of Control Authority] prior to pick-up and hauling of said commercial or
industrial wastes.
C. The permittee shall retain records of all monitoring information, waste
manifest forms, copies of all reports required by this permit, and
records of all data pertaining to hauled loads for a period of at least
three years. This period may be extended by request of the [name of
Control Authority] at any time.
SECTION 4 - STANDARD CONDITIONS
[The standard conditions may be the same as those for other industrial
users. The POTV may need to develop additional standard conditions for
vaste haulers.] [See Appendix G]
SECTION 5 - SPECIAL CONDITIONS
A. The permittee must carry liability insurance, and provide satisfactory
evidence of it to [name of Control Authority], in such amounts and form
as determined by the [name of Control Authority]. Such insurance shall
afford compensation for taking corrective action and for bodily injury,
and for property damage to third persons caused by accidental releases.
Coverage shall be in the amount of [cite dollar amount] per occurrence,
and [cite dollar amount] annual aggregate amounts. The permittee may
still obtain additional insurance coverage as may be deemed necessary
for his or her own protection.
9/15/89 J-4
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FART V
KEY WORD INDEX
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PART V
KEY VORD INDEX
A
analytical methods 5-3, 8-1. 8-9, 8-10, 8-13, 8-28, G-9
application 2-2. 2-7. 3-1. 3-4, 3-7, 3-11, 4-1, 4-2, 4-3, 4-4, 4-6, 4-7,
4-8. 4-9, 4-12, 4-13, 4-14, 7-1, 7-10, 9-2, 11-2, 11-3, 12-2, 12-3, C-2.
D-2, D-3, D-4. D-8, D-9, D-10, F-l, F-2, G-l, G-2, G-4, G-10, J-l
Approval Authority 1-2, 3-1, 4-10, 7-14, 11-1, D-2
definition of, C-l
attorney ix, 9-1
baseline monitoring report 4-6, 4-12, 8-7, 8-10, 1-2, 1-7
definition of, C-l
best professional judgment 4-3,
definition of, C-l
categorical industrial user 4-3, 5-3, 8-5, 8-12, C-4, C-5
definition of, C-l
categorical pretreatment standard 1-1, 2-3, 3-5, 4-5. 4-7, 4-13, 5-2, 5-3,
5-5, 7-1. 7-2. 7-3, 7-4, 7-8. 7-9. 8-2, 8-3, 8-4, 8-7. 8-9, 8-11, 8-12.
8-15. 8-16, 8-17, 8-27, 10-1, 10-2, 12-1, 12-3, 12-4. C-2, C-3, C-4, C-5,
C-6. C-7, D-l, F-9, 1-3, 1-4, J-2
definition of, C-l
Clean Water Act 1-1, 7-2, 7-5, 8-9, 9-5, C-2, C-3, C-4, C-5, C-6, G-8
definition of, C-l
combined wastestream formula ix, 4-3, 4-8, 7-3, 7-5, 7-9, 7-19, 8-3, 8-4,
11-3, C-2, C-7
definition of, C-l
compliance schedule 2-5, 2-6, 8-10, 8-12, 8-26, 9-5. 10-1. 10-2, 10-5,
D-6. D-9, F-9, F-10, 1-8
9/15/89
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PART V KEY WORD INDEX
composite sample 8-5, 8-6, 8-7, 8-21, 10-9, C-3, C-6, F-5, G-4
concentration limit 7-3. 7-4. 7-5, 7-8, 8-6, 8-24, 8-27
definition of, C-l
confidential Information 9-4
conventional pollutants 7-13, 8-19, 12-1
definition of, C-2
cover page 5-1, 6-1, 6-2. G-4, J-l
dally maximum limit 7-3, 7-4, 7-7. 7-11, 7-19, 8-5, 8-27, 11-3. D-3, F-3.
F-6. G-4, 1-4, 1-5
definition of, C-2
Development Document
definition of, C-2
dilution wastestream 4-5, 7-3. 7-9, 8-3, 8-16, 8-17
dilute wastestream
definition of, C-2
duration 2-1, 2-3, 2-6, 7-7, 8-5, 8-21, 9-2, 10-10, 11-1, C-3, C-4, D-3.
D-7, F-5, F-7, G-8. G-13
£
effective date 6-1, 8-20, 8-24, 8-25, 10-7, C-l, D-2, F-5, 1-2, 1-6
effluent limits 4-5. 4-6, 5-1, 7-1, 7-2, 7-3, 7-4, 7-7, 7-8, 7-9, 7-11,
7-12, 7-18, 7-19, 8-1, 8-2, 8-5, 8-6. 10-3, 10-4, 11-2, F-3, F-4, 1-2,
1-3, 1-4, 1-5, 1-6, 1-7
expiration date 2-3. 3-11, 6-1, 7-18, D-10, F-2, G-4, 1-2, 1-6, J-l
I
fact sheet 5-4, 7-19, 11-2, 11-3, 1-1, 1-6
flow-proportional composite sample 10-9
definition of, C-3
9/15/89
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PART V KEY WORD INDEX
flow weighted averaging formula 7-3, 8-3, 8-4
definition of. C-3
grab sample 8-5, 8-6, 8-7, 9-2, G-5
definition of, C-3
fi
hauled wastes 12-2, 12-3, 12-4, 13-2, 13-3, 13-4, J-2
hauler 2-2, 12-1, 12-2, 12-3, 12-4, 12-5, 12-6, 12-7, 13-2, 13-3, D-l, D-2,
D-10, J-l, J-2, J-3, J-4
hazardous waste 4-8, 12-1, 12-5, 13-1, 13-2, 13-3, 13-4, C-5, J-3
Indirect discharge
definition of, C-2
Industrial user
definition of, C-3
categorical industrial user C-l, C-4
noncategorlcal Industrial user C-5, D-l, D-2
significant industrial user 1-3, 2-1, C-5, D-l, D-2, D-3
industrial user management practices 4-7, 4-8, 10-1, 10-2, 10-3, F-8, H-l,
H-2, H-3
definition of, C-3
slug loading control plan 10-6, 10-7, F-8, H-l
spill prevention 8-8, 8-25, 10-3, C-6, 1-8
toxic organic management plan 8-12, 8-19, 8-21, 8-28, C-6, H-l
inspection 2-3, 3-5, 4-2, 4-5, 4-6, 4-7, 4-9, 4-14, 9-4. 10-6, D-6, G-9, H-2
interference 1-1, 3-6, 7-6, 7-14, 7-15, 7-16, 10-2, 10-3, 10-9, 12-1, D-l,
D-6, D-10, F-4, G-7, J-2, J-3
definition of, C-3
9/15/89:
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PART V KEY WORD INDEX
issuance
relssuance 2-2, 2-3, 3-1. 3-11, 3-12, 5-4. 11-1, D-8, D-9, F-l. G-2, G-3,
J-l
L
legal authority vii. viii, 2-1. 2-6, 3-1, 3-3, 4-1, 5-4, 6-1, 12-1, 12-2
limit
categorical pretreatment standard 2-3, 5-2, 7-8, 10-1, 10-2, 12-4, C-2,
C-3. C-5, C-7, F-9
concentration limit 7-3, 7-4. 7-5, 7-8, 8-6, 8-24, 8-27, C-l, 1-4
daily maximum 7-3, 7-4, 7-7, 7-11. 7-19, 8-5, 8-27, 11-3, C-2, D-3, F-3,
F-6, G-4. 1-4, 1-5
effluent limit 4-5. 4-6, 5-1, 7-1. 7-2, 7-3, 7-4, 7-7, 7-8, 7-9, 7-11,
7-12, 7-18, 7-19, 8-1, 8-2, 8-5, 8-6. 10-3, 10-4, 11-2, F-3, F-4,
1-2, 1-3, 1-4, 1-5, 1-6. 1-7
local limit ix. 1-1, 1-3, 2-4, 3-3, 3-5, 3-9, 5-2, 7-2, 7-6, 7-7, 7-8,
7-9. 7-13, 7-19, 8-3, 8-10, 11-3, 12-4, C-4, F-9, 1-3, 1-6, J-3
monthly average 7-3, 7-4, 7-7, 8-24, 8-27, 9-2, 11-3, C-4. D-3, F-3, F-6,
G-5. 1-4. 1-5
National categorical pretreatment standards 12-3, 12-4
National prohibited discharges 7-2, 7-14, C-4
other local requirements 3-6
pretreataent standards for existing sources C-5
production-based standards ix, 7-5, 7-18, 8-24
prohibited discharges 7-2, 7-14, 7-15, 7-16, 12-3, C-4, F-4
prohibitions 3-5, 5-3, 7-2, 7-6, 7-8. 7-14, 9-2, 10-2, 12-1, C-3, C-4,
C-6, F-4
total toxic organics 8-4, 8-28, 10-3, C-6
local limit 1-1. 1-3. 2-4, 3-3, 3-5, 3-9. 5-2, 7-2, 7-6, 7-7, 7-8, 7-9,
7-13, 7-19, 8-3. 8-10, 11-3, 12-4, ix. C-4. F-9, 1-3. 1-6, J-3
9/15/894
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PART V KEY WORD INDEX
a
modify 1-5, 2-4. 2-7, 5-3, 5-4, 7-5, 9-2, D-8, G-l
monitoring requirements 4-6, 4-8, 5-1, 7-7, 8-2, 8-7, 8-9, 8-10, 8-18, 8-20,
8-21, 9-3, 10-1, 10-4, 10-8, 10-9, 10-10, 10-11, F-5, F-8, 1-6
monthly average limit 7-3, 7-4, 7-7, 8-24, 8-27, 9-2, D-3, F-3. F-6. G-5,
1-4, 1-5
definition of, C-4
H
National categorical pretreatment standards 12-3, 12-4
definition of, C-4
National prohibited discharges 7-2, 7-14
definition of, C-4
nonconventional pollutants 4-5
definition of, C-4
nondomestic user 3-4, D-l
definition of, C-4
nontransferability 9-2, 12-6
notification 2-7, 3-9, 5-2, 5-3, 7-12, 7-18, 8-25. 10-11, 12-5, D-7. D-9,
F-7, G-2, G-8
ordinance 1-3, 2-2, 2-4. 3-1. 3-3. 3-4, 3-5, 3-6, 3-7, 3-10, 3-11. 4-1,
4-10. 5-3, 6-2, 7-2. 7-6, 7-7, 7-13, 7-15, 8-24, 8-25, 9-1, 9-2, 9-5,
10-1. 12-2. D-l, D-2, D-7, D-10, F-2. F-4, G-5. G-13, 1-3, 1-7. J-l, J-4
sewer use ordinance 3-3, 3-4, 3-5, 6-2, 7-2, 7-6, 7-7, 9-1, 9-2, 9-5.
12-2, D-l, F-2, 1-3, 1-7. J-l
other local requirements 3-6
pass through 1-1, 3-6, 7-6, 7-13, 7-14, 10-2, 10-3, 12-1, C-6, D-l, D-6,
D-10, F-4, J-2, J-3
definition of, C-4
9/15/89
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PART V KEY WORD INDEX
periodic coupliance reports 7-5, 7-18, 8-27, 8-28
definition of, C-4
pretreatment
definition of, C-4
pretreataent standards for existing sources
definition of, C-5
pretreatnent standards for new sources
definition of, C-5
pollutants
conventional pollutants 7-13, 8-19, 12-1, C-2
nonconventional pollutants 4-5, C-4
pollutants of concern 5-4, 10-4, C-2
toxic pollutants 12-1, C-4
pollutants of concern 5-4, 10-4. C-2
process wastewater
definition of, C-5
production-based standards 7-5, 7-18, 8-24
definition of, C-5
prohibited discharges 7-2, 7-14, 7-15, 7-16, 12-3, C-4, F-4
prohibitions 3-5, 5-3, 7-2, 7-6, 7-8, 7-14, 9-2, 10-2, 12-1, C-3, C-4, C-6,
F-4
public notice 2-5, 3-7, 3-8
publicly owned treatment works
definition of, C-5
E
regulated wastestrean 7-3, C-l
definition of, C-5
reissuance 2-2, 2-3, 3-1, 3-11, 3-12, 5-4, 11-1. D-8, D-9, F-l, G-2, C-3,
J-l
9/15/89
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PART V KEY WORD INDEX
report
baseline monitoring report 4-6, 4-12, 8-7, 8-10, C-l, 1-2, 1-7
periodic compliance report 7-5, 7-18, 8-27, 8-28, C-4
reporting requirements 1-3, 1-4, 5-1, 8-1, 8-4, 8-7, 8-10, 8-11, 8-12, 8-14,
8-15, 8-16. 8-17, 8-20. 8-24. 8-25, 8-26, 9-3, F-6, F-7, G-ll, 1-8
Resource Conservation and Recovery Act 4-7, 7-16, 9-5, 12-1, 12-4, C-3, G-8,
J-3
definition of, C-5
revoke 1-5, 2-6, 2-7
S
sample collection method 8-1, 8-5
sample type
composite sample 8-5, 8-6, 8-7, 8-21, 10-9. C-3, C-6, F-5, G-4
flow-proportional composite sample 10-9
grab sample 8-5, 8-6, 8-7, 9-2, C-3, G-5
sample collection method 8-1, 8-5
time-proportional composite sample 8-7
sampling location 1-3, 7-3, 8-1. 8-2, 8-3, 8-4, 8-18, D-6, 1-8
self-monitoring 3-3, 3-6, 4-6. 5-3, 8-1. 8-4. 8-7, 8-10, 8-13, 8-18, 8-19,
8-26. 10-4, 10-9, 10-10, D-9, G-2, G-9
definition of, C-5
sewer use ordinance 1-3, 3-3, 3-4, 3-5, 3-10, 3-11, 6-2, 7-2, 7-6, 7-7, 9-1,
9-2. 9-5, 12-2, D-l, F-2, 1-3, 1-7, J-l
signatory 5-3, 9-4, G-ll
signature 3-9, 6-2, 8-13, 8-27. J-l, J-3
significant industrial user 1-3, 2-1, D-l, D-2, D-3
definition of, C-5
9/15/89
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PART V KEY WORD INDEX
sludge 1-L, 2-2, 4-6, 4-8, 7-13, 7-16, 8-8, C-3, C-4, C-6, D-6, F-8, F-9,
G-6, H-l, J-3
slug load
definition of, C-6
slug loading control plan 10-6, 10-7, F-8, H-l
special condition 2-4, 4-7, 5-1, 5-4, 7-10, 8-5, 8-9, 9-5, 10-1, 10-3, 10-4,
10-5, 10-7, D-6, 11-3, F-8, H-3, 1-8, J-4
spill prevention 8-8, 8-25, 10-3, C-6, 1-8
spill prevention and control plan
definition of, C-6
split sample
definition of, C-6
standard condition 5-1, 5-2, 5-4, 7-2, 7-15, 8-10. 8-12, 9-1, 9-2, 9-4, 9-5,
12-6, F-4, F-5, F-6, F-8, F-10, G-l, 1-8, J-4
Standard Industrial Classification code
definition of, C-6
I
terminate 2-4, 2-6, 5-4
tiered permit 7-6, 7-9, 7-10, 7-12
time-proportional composite sample 8-7
definition of, C-6
total toxic organics 8-4, 8-28, 10-3
definition of, C-6
toxic organic management plan 8-12, 8-19, 8-21, 8-28, H-l
definition of, C-6
toxic pollutants 12-1, C-4
definition of, C-6
transferability 2-6
Treatability Manual 11-3
definition of, C-7
9/15/89
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PART V KEY WORD INDEX
B
unregulated wastestreams 7-9, C-7
upset 8-25, 9-2, F-7, F-8, G-5. G-13
definition of, C-7
9/15/89
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