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 ง403.8(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.
9/15/89

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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



9/15/89xi

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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
9/15/89
                                                           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
9/15/89                                                                    1-1

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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.
9/15/89                                                                    1-2

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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.
9/15/89                                                                    1-5

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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 timซ;  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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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 Pierป 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 Dซtซ
    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 thซ; 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.
9/15/89                                                                   3-12

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         PART II




PERMIT WRITING PROCEDURES

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                                   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.
9/15/89                                                                    4-5

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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
       yซBte 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*. ปampling 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
9/15/89                                                                    4-9

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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.
9/15/89                                                                   4-11

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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.
9/15/89                                                                   4-12

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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 bซ; 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
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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)].
9/15/89                                                                   7-14

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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.
9/15/89                                                                   7-16

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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.
9/15/89                                                                   7-18

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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.
 9/15/89
                                                           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.
9/15/89                                                                    8-4

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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
9/15/89                                                                    8-7

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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
9/15/89                                                                    8-8

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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)]

9/15/898-10

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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.
9/15/89                                                                   8-11

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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
9/15/89                                                                   8-12

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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
9/15/89                                                                   8-13

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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) .
9/15/89                                                                   8-14

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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.
9/15/89                                                                   8-15

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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.
9/15/89                                                                   8-16

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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.
9/15/89                                                                   8-17

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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
9/15/89                                                                   8-19

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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(ซ)
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

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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 thซi 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
9/15/89                                                                     10-8

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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
                                           10-10

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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.


9/15/8911-2

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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

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                                   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
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                    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
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   ซd MOW dtoctaffe pennk
                                       I
                                           fonn
                                      i
                               POTW tf time of diJcl)ir|B
                             WMe bwkr dactwfetป 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$gjenฃ ฐ^ 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 fฐr 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 fฐr 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,vuiฅ,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 DoฃUj|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 ฃ911C
(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'ป8-4086

                                       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

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                                  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

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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)].
9/15/89                                                                    C-7

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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,
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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
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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, ซstc., 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
9/15/89                                                                    D-8

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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.
9/15/89                                                                    D-9

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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.]
9/15/89                                                                   D-10

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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
9/15/89                                                                    E-3

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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
9/15/89                                                                    E-4

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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)
9/15/89                                                                    E-5

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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-nitrosodlphซnylaaine
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
Bซta-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 WMป











57VWM
39
900.000 OPO ttme* 9uป
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 rซ >itiซ ซป•••!
""*** Qปf '''**" * ฐ*""""
6000 QPO 1
Mi.QOO GPO Sowi BraT 1
* ปJOO OTO 29.000 OPO 5 000 OPO *
ID POTW
10.000 Nturaaaon ' • M 000 OPO
SPD * '•ซ *"
Non-Cofna
CflOlnfl 100.000 GPO
KH .000 OPO
• i
EaudBttan ^ / Pnmarir \ Amon ^ Scaondvy \ 2 '00 000 GPO _

ฎ 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
                                ILJฎ1
sL

^
                                                   3* Wtti
                    *
                    i
                                                      310 3nrซr Nซ.
                                                 QfftCg
                                     %' WATZft
            ro iron*
                       w*
                       *
             ••eeos
                                  tioe uปc.ซ
                                      v..ซ€
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]
9/15/89
                          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 bซ 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.]


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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)  fiฃ -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^ป 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 (60ฐ 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.
9/15/89                                                                    G-7

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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].
9/15/89                                                                    G-8

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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.
9/15/89                                                                    G-9

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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.
9/15/89                                                                   G-10

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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.
9/15/89                                                                   G-13

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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
9/15/89                                                                    H-2

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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

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                                  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.
9/15/89                                                                    1-1

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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
9/15/89                                                                    1-2

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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
9/15/89                                                                    1-3

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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,

9/15/891^4

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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
9/15/89                                                                    1-5

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APPENDIX I
                                                                ปiCT 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
9/15/89
                                                                     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.
9/15/89                                                                    1-7

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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.
9/15/89                                                                    1-8

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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

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                                  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 (32ฐF)  degrees and one  hundred forty (140ฐF)
         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 104ฐF (40ฐC);
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:  [Thซ permit writer mitt apply local linitt or
      any applicable, more stringent categorical standards.]

        Arsenic          	 nig/1

        Barium
        Cadmium          	 ng/1
        Chromium         	 nปg/l
        Copper            	 mg/1
        Cyanide          	 nig/1
        Lead              	 og/1
        Mercury          	 fflg/1
        Nickel            	 mg/1
        Silver            	 ng/1
        Zinc              	 mg/1
        Selenium         	 ปg/l
        Oil and Grease    	 ปg/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

-------
                                    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
ฃ

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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