United States
Environmental Protection
Agency
Office Of Water
(EN-338)
300 R-92-009
September 1991
vvEPA
Guidance For
Conducting A Pretreatment
Compliance Inspection
Printed on Recycled Paper
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GUIDANCE FOR CONDUCTING A
PRETREATMENT COMPLIANCE INSPECTION
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GUIDANCE FOR CONDUCTING A
PRETREATMENT COMPLIANCE INSPECTION
TABLE OF CONTENTS
1.) PCI GENERAL INSTRUCTIONS
,2.) POTW PCI CHECKLIST
3.) PCI REFERENCE MATERIAL
A. PCI CHECKLIST QUESTION REFERENCE
B. BIBLIOGRAPHY OF MATERIALS ON POTW PRETREATMENT PROGRAM
DEVELOPMENT, IMPLEMENTATION, AND OVERSIGHT !
C. LIST OF DEVELOPMENT DOCUMENTS AND ADDITIONAL U.S. EPA INDUSTRIAL
TECHNOLOGY DIVISION PUBLICATIONS i
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1.
PCI GENERAL INSTRUCTIONS
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1.
PCI GENERAL INSTRUCTIONS
TABLE OF CONTENTS
PAGE
OVERVIEW 1
THE PURPOSE OF A PCI 1
EXPERIENCE NECESSARY TO CONDUCT A PCI r 2
PROCEDURES FOR CONDUCTING A PCI 3
Preparation for the Inspection ' 4
Entry Interview 6
File Review ', 6
Industrial User Site Visits • 9
Supplemental Data Review/Interview with the CA 11
Closing Conference ;! 11
Documentation 12
Follow-up and Reporting 13
HOW TO USE THE CHECKLIST 14
Cover Page 15
Section I: IU File Evaluation 15
Section II: Supplemental Data Review/Interview 16
Section III: Evaluation and Summary 17
Attachment A: Pretreatment Program Status Update 17
Attachment B: Pretreatment Program Profile 18
Attachment C: Worksheets 18
WENDB Data Entry Worksheet ; 18
RNC Worksheet 18
IU Site Visit Report Form 19
File Review Worksheets .j 19
SUMMARY OF PCI PROCEDURES 19
LIST OF TABLES
1. SPECIFIC OBJECTIVES OF A PCI 2
2. PRETREATMENT PROGRAM INFORMATION TO REVIEW BEFORE A PCI 5
3. INFORMATION POTW SHOULD COMPILE BEFORE A PCI 6
4. CRITERIA TO USE IN SELECTING IU FILES TO REVIEW 9
5. CRITERIA TO USE IN SELECTING lUs TO VISIT '< 10
6. EXAMPLE PCI CHECKLIST INFORMATION DOCUMENTATION SYSTEM 15
7. SUMMARY OF PCI PROCEDURES 20
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PRETREATMENT COMPLIANCE INSPECTION
GENERAL INSTRUCTIONS
OVERVIEW
The National Pretreatment Program regulates the discharges of pollutants from non-
domestic sources into Publicly Owned Treatment Works (POTWs) that could pass through
inadequately treated, interfere with the treatment works processes, threaten worker health and
safety, or contaminate POTW sludges. The Pretreatment Compliance Inspection (PCI) is one of
the oversight mechanisms used by Approval Authorities1 to evaluate compliance by POTWs
[i.e.. Control Authorities (CAs)] with approved pretreatment programs. (Other oversight
mechanisms include the pretreatment program audit and the pretreatment program
performance report submitted at least annually by the CA.) This document provides guidance
to the inspector on each step of conducting a PCI inspection, including preparation for the
inspection, review of Industrial User (ID) files, visits to Ills, interview and closing conference
with the CA, and follow-up reporting. In addition, this guidance provides instructions for using
the POTW PCI Checklist, which was designed to facilitate the collection of data and ensure
that all necessary information is reviewed and documented. This Checklist is intended to be
used as a framework for organizing information that is reviewed or received during a PCI and
serves as a reminder to assess the compliance status of the CA's pretreatment program
implementation as required through its NPDES permit. A complete copy of the Checklist is
included with this manual. The manual also includes reference materials: an in-depth
explanation of all Checklist questions; a bibliography of materials applicable to development,
implementation and oversight of POTW pretreatment programs; and, a list of development
documents for categorical industries.
THE PURPOSE OF THE PCI
The primary purpose of a PCI is to determine or verify the CA's compliance with and
enforcement of its approved pretreatment program and NPDES permit pretreatment
requirements. This and other specific objectives for the PCI are listed in Table 1.
1Approval Authorities are U.S. Environmental Protection Agency (EPA) Regional Offices and States with
approved National Pollution Discharge Elimination System (NPDESJ/Pretreatment Programs.
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TABLE 1. SPECIFIC OBJECTIVES OF A PCI
Identification of deficiencies, problems, or noncompliance throughout the CA's service
area (including contributing jurisdictions) in implementing the approved program ;or
NPDES pretreatment requirements, focusing primarily on the issuance of control;
mechanisms and application of pretreatment standards and requirements, compliance
monitoring, and enforcement activities
Verification of information that the CA has supplied in its pretreatment program
performance reports (e.g. annual reports)
Determination of whether changes have been made to the CA's program since Approval,
or since the most recent PCI, audit, pretreatment program performance report, or
previous program modification
EXPERIENCE NECESSARY TO CONDUCT A PCI
Timely counseling on potential noncompliance or other issues that may be identified
during the inspection is central to the ultimate goal of ensuring an effective pretreatment
program. For this reason, the inspectors responsible for performing PCIs must be farjniliar
enough with the goals of the program, the General Pretreatment Regulations, and EP/VState
policy and guidance to conduct the inspection in a manner that will obtain informatioh to
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detect noncompliance with pretreatment requirements.
At a minimum, the inspector must be knowledgeable of: i
• Categorical Industries - Although the inspector does not need to be expert on each
process associated with each type of categorical industry, he/she must be familiar
with the categorical industries for which pretreatment standards exist and know
enough about the processes to verify whether an industry has been properly
categorized. The inspector can rely upon the applicability section of the categorical
standard regulations for individual categories, development documents, and'guidance
documents developed for some specific categories. :
• Application of Pretreatment Standards - The inspector must understand how to
implement specific standards such as Total Toxic Organic (TTO), how to calculate
production-based standards, when the Combined Wastestream Formula (CWF) and
Flow-Weighted Averaging formula (FWA) need to be used, and be able to verify that
the alternate standards have been calculated correctly. This understanding (includes
knowing which wastestreams are regulated, unregulated and dilute, and which
pollutants are regulated for each process. The inspector must also be knoWledgeable
on how to apply local limits and to compare local limits to categorical pretre'atment
standards to determine the most stringent. '
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« Control Mechanisms - The inspector's role is not merely to verify that a control
mechanism (e.g., permit) has been issued and is current but also to evaluate its
content and to ensure that it meets the minimum requirements of 403.8(f)(1)(iii).
• Compliance Monitoring - The inspector should be familiar with EPA-approved sampling
and analytical procedures, including specifications for sample location and type, and
how to collect samples for use as evidence in court proceedings. Additionally, the
inspector must be able to evaluate the basic inspection protocol and documentation
efforts for industrial inspections.
• Evaluation of Spill Prevention and Hazardous Waste - While it is not critical that the
inspector have extensive knowledge of regulatory requirements under the Resource
Conservation and Recovery Act (RCRA), he/she must have some knowledge of
hazardous wastes and prevention and control of spills of hazardous and nonhazardous
materials to sewers.
• Enforcement - The inspector should be familiar with EPA policies and guidance on
enforcement in order to evaluate the enforcement efforts of the POTW and the ability
of the POTW to obtain IU compliance.
PROCEDURES FOR CONDUCTING A PCI
A one-page summary of the steps involved in conducting a PCI is provided at the end of
this section (Table 7 entitled SUMMARY OF PCI PROCEDURES). Briefly, the major steps
involved in conducting a PCI include:
• Pre-site Visit Preparation j
- Notifying the CA, if appropriate,
- Reviewing information on the CA's pretreatment program
• Onsite Visit
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- Entry (presenting credentials)
- File review !
- Inspections of lUs
- Interview
- Closing conference ,
• Post-site Visit Follow-up
- Report
- Water Enforcement National Data Base (WENDB) data entry into Permit
Compliance System (PCS)
- Reportable Noncompliance/Significant Noncompliance (RNC/SNC) determination.
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Preparation For The inspection
During a PCI, considerable information must be collected in a relatively short period of
time. Therefore, planning is necessary in advance of the actual site visit to ensure that the
inspection is properly focused and that the information necessary to determine compliance with
program requirements is collected. \
The inspector should include the following steps in planning for a specific PCI:
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• Notify the CA of the scheduled inspection approximately a week in advance2
• Review CA data
- Approved program requirements ;
- Pretreatment requirements in POTW's NPDES permit :
- Previous PCI and audit reports, pretreatment program performance reports, and
most recent Significant Industrial User (SIU) compliance data. ;
The CA should be notified of a pending inspection when it is necessary that appropriate
CA personnel (and contributing jurisdiction personnel) and/or specific compiled data be
available at the time of the inspection. This notification can prevent the inspector from
traveling to the POTW only to find that the CA contact or specific information is not ^available.
Prior to the site visit, the inspector will need to obtain specific information on the current
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status of the CA's pretreatment program. This information should be used to update the
Pretreatment Program Status Update (Attachment A of the PCI Checklist). A summary of the
type of information to review is listed in Table 2.
The inspector should also obtain appropriate information in advance of the site visit to
assist him/her in clearly understanding the specific requirements of the CA's approved
program. An extensive list of background information for the program is contained in the
2The inspector should follow Regional or State policy which may dictate whether the CA is notified in advance
of the scheduled inspection. '
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Pretreatment Program Profile (Attachment B of the PCI Checklist.)3 This allows the inspector
to spend onsite time focusing on problems and current issues instead of collecting information
that should already be a part of the Approval Authority's file. After completing the PCI, the
inspector should make appropriate changes to the Status Update and the Profile.
TABLE 2. PRETREATMENT PROGRAM INFORMATION TO REVIEW BEFORE A PCI
• General information (Name of CA, contact)
• Number of treatment plants, NPDES permit discharge limits, sludge conditions, pretreatment conditions
• Influent, effluent, sludge, biomonitoring/toxicity test data
• Approved program and any approved modifications
- Procedures/frequency for updating IU inventory
- Procedures for notifying Ills of classification and applicable standards and requirements
- Procedures for issuing control mechanisms
- Procedures/frequency for sampling/inspecting lUs
- Procedures for handling hauled wastes
- Enforcement Response Plan (ERP)
• Findings of last PCI, audit, pretreatment program performance report i
If the PCI is announced, the inspector should request that the CA compile certain
information in advance that will be discussed during the onsite interview portion of the
inspection, such as data required to support determinations of SNC, RNC, and WENDB data
elements. Table 3 lists the types of information that the CA should have but may not be able
to re;adily supply or summarize during the inspection unless compiled in advance. (This
information may be contained in the CA's pretreatment program performance reports, but if it
is not the inspector should request that the information be compiled for the PCI.) If possible,
this information should be sent to the inspector before the site visit. If the CA does not
provide this information prior to the site visit, the information should be made available when
the inspector arrives onsite.
Pretreatment Program Profile should be comprehensively completed (or updated) during a Pretreatment
Audit. If it is not available in a completed form, the inspector may want to work with the EPA or State
Pretreatment Coordinator to compile the information in preparation for the PCI.
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TABLE 3. INFORMATION POTW SHOULD COMPILE BEFORE A PCI'
• Number/List of Categorical lUs (ClUs)
• Number/List of significant noncategorical lUs
• Number/List of regulated noncategorical lUs
• Number/List of SlUs with existing, unexpired control mechanisms
• Number of control mechanisms not issued within 180 days of the expiration date
• Number/List of SlUs evaluated for the need to develop slug discharge control plans
• Number/List of SlUs not sampled or inspected at least once
• Number/List of SlUs with effluent violations
• Number/List of industries affected by enforcement actions
• Number/List of SlUs in SNC
• Number/List of SlUs on compliance schedules
• Number/List of SlUs in SNC with self-monitoring and not inspected or sampled
•Based on the last four full quarters4
Entry Interview '
Upon arriving onsite to conduct the PCI, the inspector should follow normal entry
procedures according to EPA's 1988 NPDES Compliance Inspection Manual. A brief interview
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should follow, involving appropriate CA pretreatment staff, wherein the inspector introduces
him/herself and explains the purpose and objectives of the inspection. He/she should also
discuss procedures for conducting the inspection, and ask that any outstanding information
that had been requested of the CA earlier be compiled and made available during the file
review.
File Review '
The file review conducted during the PCI provides a means of assessing the CA's
performance based on the records the CA maintains on its lUs. These records document that
the CA has conducted the permitting, compliance monitoring, compliance assessment and
4EPA's September 9, 1991, memorandum, Application and Use of the Regulatory Definition of Significant
Noncompliance for Industrial Users addresses the concept of quarters in terms of calculating SNC.
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enforcement activities required by its approved program. If the CA does not maintain such
documentation it has no proof of meeting the requirements of its program. Verbal accounts
and assurances by CA personnel, although helpful in identifying potential problems, do not
constitute sufficient documentation of CA program activities. The inspector should
independently verify all such verbal information with file data. The inspector may need to
request that CA personnel locate or organize file information. If relevant information is not
found in the files, the inspector should note this as a problem or deficiency on the Checklist.
Thus, the file review serves two main purposes:
• To determine compliance with the approved pretreatment program requirements
• To verify information submitted by the CA in its pretreatment program performance
reports (i.e., annual or more frequent reports) to the Approval Authority.
The file review gives the inspector the opportunity to determine and document
deficiencies in the following major program components: issuance of control mechanisms,
application of standards, compliance monitoring and enforcement. The PCI Checklist's
Section I: IU File Evaluation follows this general outline of program components to be
evaluated and lists frequently observed deficiencies in implementing these major program
components. i
The file review should be completed before conducting the interview portion (Section II:
Supplemental Data Review/Interview) of the inspection. This procedure allows the inspector to
identify issues or problems found in ID files which can then be discussed and resolved during
the interview. In some cases it may be appropriate to conduct the interview first (i.e., where
doing such would enable the inspector to better focus the file review), followed by the file
review, and a closing interview to resolve issues or contradictions that arise as a result of the
file review. For example, if the inspector was unable to obtain or review information as part of
the preparation for the PCI, has no knowledge of the number or types of SI Us, or has never
reviewed the files at the CA, the inspector may be able to obtain information in an initial
interview that would assist him/her in selecting which files to review or in understanding how
the files are organized (e.g., spill plans being kept in a separate file drawer or the chain-of-
custody forms being kept in the laboratory's files).
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The inspector should ensure that all deficiencies identified during the file review are
adequately documented and should obtain copies of any relevant information. For example, if
the CA has issued a control mechanism to an SIU which contains incorrect limits, the inspector
should make a copy of the control mechanism to support documentation of the deficiency in
the Checklist. Appropriate narrative comments should be recorded in the "Commenljs" section
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of the PCI Checklist under the industry name and address. Occasionally, it will be impractical
to make copies of material which demonstrate problems or deficiencies at the time of the PCI
(i.e., the material does not exist or a copy machine is not available). Where the material exists
but cannot be copied onsite, the inspector should request that the CA duplicate and send these
materials after completion of the onsite portion of the inspection. The inspector should keep a
copy of the list of materials requested in order to verify receipt of all needed documents. If the
materials cannot be obtained, this should be noted on the Checklist, along with specific
information that will enable the inspector to obtain the material at a later time (e.g., the control
mechanism number, to whom it was issued, and when).
The inspector should review as many files as necessary to ensure a complete
review. Although the PCI Checklist provides space for information on five files, the inspector
should not limit his/her review to five files. Obviously, if the CA has 5 or fewer SlUs, the
inspector should review all the SIU files. If the CA has greater than 5 SlUs, then the inspector
should increase the number of files reviewed. Additional copies of Section I: IU File'Evaluation
should be made to accommodate all files reviewed.
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Some CAs will have more SlUs (and therefore more files) than the inspector can review
during the PCI. The files reviewed should be representative of the industries regulated by the
CA, and therefore should include the various types of categorical and noncategorical 'SlUs. The
inspector should select files that demonstrate the CA's implementation of all pretreatment
requirements. Table 4 lists some of the criteria the inspector can use to select files to review.
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For example, the inspector could randomly select one SIU from each of the following: SlUs in
SNC, SlUs in compliance, SlUs in noncompliance but not in SNC, SlUs on compliance
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schedules, ClUs subject to production-based standards, and ClUs using the CWF. SUch a
selection would enable the inspector to investigate the CA's implementation of categorical
standards and local limits, identification of violations, determination of SNC, and adherence to
its ERP. The inspector may want to select SIU files that were not reviewed in previous PCIs.
The inspector should avoid reviewing only a specific group of SlUs (e.g., those in SNC) or the
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same set of files PCI after PCI (unless this group or set represents all SlUs). By targeting only
those SlUs where deficiencies or problems are known to exist, the inspector will not be able to
identify other deficiencies or problems.
The inspector should also not be limited by the items listed in the file review portion of
the PCI Checklist. The Checklist is intended to assist the inspector's organization of thought
and documentation of deficiencies. If additional deficiencies are identified, they should be
documented at the end of Section I: ID File Evaluation under G. Other.
TABLE 4. CRITERIA TO USE IN SELECTING IU FILES TO REVIEW
« CIU without pretreatment but reported as in compliance with categorical standards
• CIU subject to production-based categorical pretreatment standards
• One CIU from each of the different categories represented (e.g., 1 metal finisher, 1 aluminum former, 1
electrical and electronic components manufacturer)
« CIU where CWF was applied
« SIU reported in SNC in POTW's recent pretreatment program performance reports
• SIU that has caused pass through or interference
• SIU in occasional noncompliance (but not SNC)
« SIU that has received escalated enforcement action
» SIU that had slug load or accidental discharge
• CIU subject to TTO limitations
* SIU subject to local limits only
« Largest (in flow and/or loading) SIU
» SIU that (potentially) generates/stores hazardous waste
Industrial User Site Visits
Another important component of the PCI are visits to selected SlUs. Site visits to SlUs
can be used to:
Verify file information or clarify/verify errors the CA has made in implementation
(such as: miscategorization, misapplication of categorical standards, no evaluation of
spill potential or hazardous waste handling)
Observe and record any deficiencies in the CA personnel's inspection or sampling
procedures.
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The Inspector should generate a brief site visit report focusing on any information that is new
or inconsistent with the information in the CA's file. '•
In selecting which IDs to visit, the inspector should choose those IDs where the file data
suggest possible errors, deficiencies, or ID noncompliance that needs further investigation
(particularly in categorization, sampling location, or the need for and use of CWF or FWA). For
example, the inspector should visit IDs where the file data:
• Are insufficient to determine categorization or indicates that the ID may be subject to
a different categorical standard than the one the CA applied
• Suggest inappropriate sampling locations (locations that do not contain all regulated
process wastestreams) or sampling locations with possible dilution wastestreams
present !
• Reveal very different monitoring results between the CA compliance monitoring data
and the ID self-monitoring data. I
Criteria for selecting which industries to visit are listed in Table 5. The number of SlUs to visit
is dependent upon the results of the file review and is left to the discretion of the inspector (or
Regional/State policy). The more files reviewed and site visits conducted, the more thorough
the PCI will be in identifying deficiencies. :
TABLE 5. CRITERIA TO USE IN SELECTING lUs TO VISIT
• Any SIU with incomplete or missing information in the file with regards to:
- Categorization/classification
- Dilute wastestreams introduced prior to sampling point
- Self-monitoring/compliance information
- POTW sampling/inspection procedures
• CIU without pretreatment but reported as in compliance with categorical standards
• SIU in SNC
• SIU that has caused pass through or interference
• SIU that had slug load or accidental discharge
• Other criteria used in selecting files to review
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If an SIU is selected for a visit, its file should have been reviewed during the file review to
determine whether the information contained in the file is consistent with observations made
during the IU visit. The IU Site Visit Report Form, provided as part of Attachment C of the PCI
Checklist, can prompt the inspector as to the information that should be reviewed or obtained
during an IU site visit.
Supplemental Data Review/Interview With The CA
The interview with CA personnel should occur after the inspector has had the
opportunity to review the files. This will allow the inspector to focus cm specific issues or
problem areas that have been identified during the file review, to clarify items from the file
review, and to evaluate compliance with program requirements that could not be determined
from the file review. It is generally useful to interview various CA personnel responsible for the
different pretreatment tasks (e.g., permitting, inspecting, sampling, compliance tracking and
enforcement). Where the staff is large, the inspector may want to arrange for several
interviews at different times with different personnel. Where appropriate, the inspector may
want to interview contributing jurisdiction personnel to evaluate program implementation in the
jurisdiction(s).
During the interview with the CA, verbal responses to the inspector's questions should
be substantiated with documentation; information that had been specifically requested by the
inspector should be provided at this time to serve as documentation. It is also very important
that the inspector take accurate notes during the interview, and that he/she fully understands
all responses before proceeding to the next question or issue. Oral or written statements
obtained during an interview are generally admissible in court under exceptions to the "hearsay
evidence" rules. For this reason, a written record should be made of statements made during
the interview, either in the form of a verbatim record of questions and answers, unsworn
statements, or informal notes.
Closing Conference
The closing meeting is also an ideal time for final questions and details to be resolved.
The inspector should be prepared to discuss general follow-up procedures, such as transmittal
of findings, that will occur. The closing conference discussion should be guided by rules
established by the Regional Administrator or State Director regarding permittee contacts in the
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Region/State but may at least include presentation and discussion of preliminary findings. In
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general, certain precautions are essential:
• The inspector should not discuss any legal or enforcement consequences with the
pretreatment program contact. '
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• The inspector must refrain from recommending a particular consultant or consulting
firm, even if asked to do so. Inspectors should tell the CA representative to contact a
professional society or other CAs for a listing or advice concerning this matter.
Documentation
Any and all irregularities in the CA's pretreatment program or IU files should be
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documented. "Documentation" refers to all notes, Checklists or copies taken to provide
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evidence to support the program deficiencies identified during the inspection. Types iof
documentation include the completed PCI Checklist, field notes, analytical results from
samples, recorded statements, photographs, videotapes, drawings and maps, printed; matter
and copies of permits and records. The inspector should obtain copies of any material in the
CA's files that indicate an error, problem or deficiency. Types of material indicating problems
include: ;
• Control mechanisms that contain incorrect limits !
• Monitoring data that indicate noncompliance where the CA has not responded
• Enforcement actions believed to be inappropriate. '
The basis of all documentation relating to the CA pretreatment program is the Checklist which,
if used properly, provides accurate and inclusive documentation of all pretreatment activities.
It will form the documentary basis for all determinations made by the inspector. The! inspector
should supplement the Checklist with clarifying notes. For example, if information on the
number and types of enforcement actions were obtained from the CA's pretreatment| program
performance report, the inspector should note on the Checklist that this issue was not
evaluated or not determined as part of the inspection and should include a reference to the
CA's report. This type of clarification is needed so there is no erroneous assumption1 made
that the information was obtained through the PCI. All PCI documentation should be
maintained in the same manner as other NPDES inspections. For additional information on
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proper documentation, inspectors should refer to EPA's 1988 NPDES Compliance Inspection
Manual.
Follow-up And Reporting
The Checklist and any report generated from the PCI provide the basis for all follow-up
activities. It is important that the PCI Checklist and any accompanying reports be written in a
clear and comprehensive manner. Section III: Evaluation and Summary of the Checklist
provides space for identifying required actions (and recommendations,, as per EPA/State
policies) that the POTW should undertake to resolve any deficiencies in its program. All
deficiencies identified during the PCI must be documented along with required corrective
actions. The deficiencies must be factual and verifiable. All supporting documentation (e.g.,
photographs, descriptive statements, copies of records) must be clearly referenced so anyone
reading the report will get a complete, clear overview of the situation, The required corrective
actions must be clearly differentiated from any recommendations aimed at improving the
implementation of the CA 's program.
The inspector should follow Regional/State policy on who completes the WENDB and
RNC worksheets that are part of the PCI Checklist. They need not necessarily be
completed during the site visit and should not be provided to the CA in the report unless
Regional/State policy so dictates. The NPDES Compliance Inspection Report Form 3560-3
must also be completed after the inspection and incorporated into the final inspection
report. This form contains a pretreatment code (P) to indicate that, a PCI was performed.
This form must be prepared to provide for data entry into PCS.
The inspector should also update the Profile and Status Update, where needed,
based on information obtained during the PCI. If other personnel are responsible for
updating the Profile and Status Update, the inspector should provide information from the
PCI to assist in this process.
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HOW TO USE THE CHECKLIST
The PCI Checklist is a tool to help the inspector in documenting problems or
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deficiencies and ensuring all necessary program components have been covered in the
inspection. The Checklist is organized into the following sections:
• Cover page
• Section I: ID File Evaluation ;
• Section II: Supplemental Data Review/Interview
• Section III: Evaluation and Summary
• Attachment A: Pretreatment Program Status Update i
• Attachment B: Pretreatment Program Profile \
• Attachment C: Worksheets
- WENDB Data Entry Worksheet
- RNC Worksheet ;
- IU Site Visit Report Form
- IU File Evaluation Worksheets.
The inspector should not limit him/herself only to the items listed in the Checklist but
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should expand on the Checklist where deficiencies/problems are uncovered. The .format of
the Checklist is designed to allow the inspector to add/customize via the preformatted
page at the end of each Section. As always, the inspector should provide clear comments
about specific deficiencies found. !
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Inspectors will realize that the PCI is not a comprehensive evaluation of all jaspects
of the CA's program or activities. In particular, the CA's resources, legal authority or the
technical basis of the CA's local limits are not reviewed or evaluated. Since an intensive
review of material in all files may not be possible during a PCI, it would not be appropriate
to conclude that the CA's program, procedures, or implementation activities are adequate
if no deficiencies were explicitly identified. When using the Checklist, the inspector should
note where items, questions or program components were not evaluated or were| not
answerable due to a lack of information. Where the inspector finds a deficiency jn a
program element, it should be identified with a check and noted in the comment field.
Only program elements the inspector knows to be deficient are checked. If no deficiencies
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are identified, then portions of Sections I, II, and III of the Checklist may remain blank. It is
essential that the inspector not provide what may be misleading information by indicating that
a program element is adequate. Such information can undermine subsequent enforcement
actions taken against the CA based on the inspection or upon other evaluations that can
conflict with the inspection. The inspector should develop and use some type of coding
system that will enable him/her to know what was reviewed, what was not reviewed, and
what was found to be deficient. Table 6 illustrates an example of a documentation system an
inspector could use.
TABLE 6. EXAMPLE PCI CHECKLIST INFORMATION DOCUMENTATION SYSTEM
Place a (S) in the appropriate places to indicate deficiencies; then describe the specific
deficiencies in the places provided or on separate sheets to be attached to the PCI
Checklist
Write ND (Not Determined) beside the questions or items that were not reviewed or
discussed during the PCI; at the end of the Checklist indicate the reason(s) why these
were not addressed (e.g., lack of time, appropriate CA personnel was not available to
answer, etc.)
Use NA (Not Applicable) where appropriate.
Cover Page
The cover page provides space for the name of the CA, its address, and the
representative present during the inspection. It also provides space for the date(s) of the
inspection and the inspectors' names, titles and phone numbers. At the top of the cover page
the inspector can indicate the sections and attachments of the PCI Checklist that were used in
the PCI.
Section I: 1U File Evaluation
The file review section is designed to allow the inspector to document any problems or
deficiencies found during file review. The inspector should complete the IU information
requested in the designated "Narrative Comments" field (e.g., industry name, address, etc.) in
order to document the files reviewed. Many important components of the pretreatment
program are listed in this section (yet, the inspector should realize that the list is not all
inclusive). The inspector should indicate a deficiency by placing a (/) by any of the listed
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program components. Then, in the "Comments" field beneath each of the major program
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components in this section, he/she should write the specific deficiency found in the file. For
example, if the IU was subject to the metal finishing pretreatment standards and the inspector
found that the cadmium metal finishing limit had not been applied to the IU, then the'inspector
should place a (/) in C.2.C. and in the "Comments" field state that the cadmium limit for the
metal finishing category was not applied to the IU. If the identified deficiency is not listed in
any of the subsections of Section I of the Checklist, then the inspector should list the
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deficiency under G. Other and again explain or describe the specific deficiency in the
"Comments" field. I
Section II; Supplemental Data Review/Interview ;
Section II: Supplemental Data Review/Interview is designed to enable the inspector to
i
determine compliance with other program requirements that may not be easily determined
through review of individual files. While a determination of compliance for some of the items
i
in this section is possible based on the file reviews alone, most will require additional
information. For some of the program requirements listed in this section, the inspector may
need to request that the CA compile some data in advance so that a review will enable him/her
to determine compliance. Again, the inspector should not limit his/her review and evaluation to
the questions/items in the Checklist and is encouraged to ask questions beyond those in the
Checklist. |
I
The inspector should avoid asking leading or suggestive questions which imply the
desired answer. These types of questions tend to influence the answers given by the
interviewee. Examples of leading questions are:
• Did you sample all lUs in the past year? i
• Have you permitted all SlUs?
i
Additionally, the inspector should phrase questions to require a narrative response rather
than "yes" or "no" responses. For example, question II.F.2 is designed to enable the! inspector
to document any deficiencies in the CA's implementation of its approved ERP. Rather than
soliciting a "yes/no" response from CA personnel, the inspector should record his/her
evaluation based upon the CA's documentation of its enforcement actions. Before concluding
the interview, the inspector should verify that all necessary information has been gathered and
16
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that any outstanding problems are identified. If there is any conflicting information, the
inspector should resolve the issue to his/her satisfaction.
Section III: Evaluation And Summary
Section III: Evaluation and Summary may be completed at the end of the onsite visit or
thereafter in the office. This section provides a means for the inspector to summarize the
deficiencies identified during the inspection. The format allows the inspector to concisely
describe any noncompliance with the listed regulatory requirements and to specify and describe
the required and/or recommended corrective actions.5 Space is provided for the inspector to
add any additional recommendations or requirements. The inspector should follow
Regional/State policy in providing recommendations.
Attachment A: Pretreatment Program Status Update
Attachment A: Pretreatment Program Status Update provides a means of updating the
program's status. The attachment should be updated prior to each PCI based on information
obtained from the most recent inspection and/or audit and the last pretreatment program
performance report (e.g. annual report). If the CA's pretreatment program performance report
provides the number and list of SI Us in SNC (in the CA's pretreatment year), the inspector
should record this data in the Status Update, Section B: Pretreatment Program Status. Item
No. 4. If this information was not in the CA's pretreatment program performance report, then
prior to the PCI the inspector should request the CA to compile the following information and
send it to the inspector before the PCI or have it available during the PCI: the number (and
percent) of SlUs that were in SNC during the four most recent full quarters. The information
contained in the Status Update enables the inspector to become familiar with the known
strengths and weaknesses of the CA's program. At the completion of the PCI, the inspector
should revise the Status Update, as needed, based on information obtained during the PCI.
The CA's approved pretreatment program should be consistent with the regulatory requirements of the
General Pretreatment Regulations; however, the CA's program or NPDES permit pretreatment requirements may
not have been modified to include the latest revisions to the General Pretreatment Regulations. For those CA
programs that have not been modified, the inspector needs to determine compliance with the approved program
and iNPDES requirements that are legally effective at the time of the PCI.
17
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Attachment B: Pretreatment Program Profile '
The inspector should be familiar with the CA's approved pretreatment program, its
i
NPDES permit conditions, and all applicable pretreatment regulations. The Pretreatmeht
Program Profile (Attachment B to the PCI Checklist) was developed for this purpose. The
Profile provides a summary of the CA's approved pretreatment program requirements and
NPDES pretreatment conditions. The attachment should be initially completed based on
information obtained from the approved pretreatment program submission, all modifications
thereto, and the NPDES permit. If the Profile is available from a previous PCI or audit; the
inspector should use it to prepare for the inspection. If the Profile has not been previously
developed, it may be completed by the inspector and the State/EPA Pretreatment Coordinator.
Once completed, the Profile need only be updated when the approved pretreatment program is
modified and/or the NPDES permit requirements are revised. The inspector should review this
permanent record of the CA's approved program requirements and NPDES conditions prior to a
PCI, in order to determine the CA's compliance with all pretreatment requirements.
Attachment C: Worksheets I
WENDB Data Entry Worksheet :
The Pretreatment Permits and Enforcement Tracking System (PPETS) is a computerized
management information system for tracking the permit compliance and enforcement Jstatus of
approved pretreatment programs. The critical elements of the tracking system, referred to as
WENDB data elements, provide EPA with summary pretreatment statistics to highlight; problem
areas in local oversight and enforcement of approved pretreatment programs. The PCI
Checklist identifies the questions that correspond to the WENDB data elements. A WENDB
Data Entry Worksheet is included in Attachment C of the Checklist to facilitate data entry.
i
*
RNC Worksheet i
Approval Authorities are required to report certain permit violations on the Quarterly
Noncompliance Report (QNCR), including a CA's failure to adequately implement its approved
pretreatment program. RNC criteria are used in determining when a CA is to be reported on
i
the QNCR. In order to assess RNC, the inspector should become familiar with EPA's FY 1990
Guidance for Reporting and Evaluating POTW Noncompliance with Pretreatment Requirements.
The RNC Worksheet included in Attachment C of the PCI Checklist should be used by the
18
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inspector (in accordance with Regional/State policy) to determine and document whether the
CA should be reported on the QNCR based on the information obtained during the PCI.
IU Site Visit Report Form
The inspector must document any IU site visits which occur. The IU Site Visit Report
Form provided in Attachment C as a supplement to the Checklist may be used. This form is
provided for the convenience of the inspector. It should not be considered as all inclusive and
may be replaced with a more comprehensive form.
File Review Worksheets
The optional File Review Worksheets in Attachment C of the Checklist are designed to
assist the inspector in quantifying the CA's performance in applying standards, compliance
monitoring, and enforcement activities. If these worksheets are used they need not be
submitted as part of the report to the CA. However, they should be kept in the inspector's PCI
file. The inspector is especially encouraged to use these worksheets if he/she has reason to
believe that enforcement action will result or may be necessary. The worksheets are:
• File Review Worksheet
• IU Self-Monitoring Worksheet
'i
• POTW Monitoring Reports Worksheet
• Violations Based on IU Self-Monitoring and POTW Monitoring Data Worksheet
• Enforcement Actions Against IU Worksheet
• ClUs Worksheet.
SUMMARY OF PCI PROCEDURES
Table 7 provides a one-page summary of the steps involved in conducting a PCI. The
inspector may find this summary useful to refer to during the preparation, onsite visit, and
follow-up.
19
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TABLE 7. SUMMARY OF PCI PROCEDURES
PREPARATION TASKS
Determine specific objectives of PCI
Provide advance notification to CA
Review CA information
CA approved pretreatment program, its NPDES conditions and all applicable environmental regulations
(NPDES limits, receiving stream water quality standards, sludge standards, air emissions) (Pretreatment
Program Profile)
Most recent compliance data and reports
Any available environmental data to identify any problems
Obtain information from CA before site visit .
Complete Pretreatment Program Status Update
Follow entry procedures
Conduct file review
Select files to review
ClUs that the CA has reported are in compliance but do not have any pretreatment, SlUs that are in SNC
or that have had a range of enforcement actions, ClUs using the CWF or FWA or are subject to •
production-based standards, etc.
Review file information j
Classification
Control mechanism •
Application of pretreatment standards
Compliance monitoring (sampling and inspections) ,
Enforcement
Compliance status '
Conduct IU inspections
Select IDs to inspect
Conduct inspections
Observe CA inspection/sampling procedures '
Verify file information or clarify/verify errors CA has made in implementation -
Obtain IU compliance/noncompliance information for possible enforcement action against IU '
Manufacturing/process areas, all wastestreams (regulated, unregulated, dilute), hazardous waste
generation/handling, pretreatment facilities, IU sampling and analysis protocols (sampling point, '
procedures and methods), spill/slug potential and controls, records
Interview
Obtain information
Information that was not obtained by file review
Clarify deficiencies found in file review \
Check notes and Checklist to ensure everything has been reviewed
Clarify any discrepancies
Obtain copies of CA records
Copies of any materials in the CA 's files that indicate an error or deficiency (e.g., control mechanisms that
do not contain correct limits, monitoring data that indicate noncompliance where CA has not responded,
or enforcement actions believed to be inappropriate)
FOLLOW4JP TASKS
Write the report '
Content of report i
Deficiencies •
Required actions '-
Recommendations
Request for CA to respond
Complete WENDB and RNC portions of the Checklist and Program Profile and Status Update
20
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2.
POTW PCI CHECKLIST
-------
-------
POTW PCI CHECKLIST
When using this Checklist the inspector should develop a system of documentation that will
indicate what was reviewed, what was not reviewed and what was found to be deficient. It is
essential that the inspector not provide what may be misleading information by indicating that a
program element is adequate. Such information can undermine subsequent enforcement actions.
The following table provides an example documentation system that can be used.
EXAMPLE PCI CHECKLIST INFORMATION DOCUMENTATION SYSTEM
• Place a (/) in the appropriate places to indicate deficiencies; then describe the specific
deficiencies in the places provided or on separate sheets to be attached to the
Pretreatment Compliance Inspection (PCI) Checklist
• Write ND (Not Determined) beside the questions or items that were not discussed or
reviewed during the PCI; at the end of the Checklist indicate the reason(s) why these
were not addressed (e.g., lack of time, appropriate Control Authority (CA) personnel was
not available to answer)
• Use NA (Not Applicable) where appropriate.
This Checklist assumes that the CA's program has been modified to include the latest
revisions to the General Pretreatment Regulations [referred to as the Domestic Sewage Study
(DSSJ revisions}. For those CA programs that have not been modified, the inspector needs
to determine compliance with the approved program and National! Pollutant Discharge
Elimination System requirements that are legally effective at the time of the PCI.
The CA is responsible for regulating all SlUs in its service area, regardless of the jurisdiction in
which they are located. The PCI should encompass the CA's program implementation
throughout its service area including contributing jurisdictions. When reviewing each program
component (i.e., ID inventory, issuance of control mechanism, compliance monitoring, and
enforcement) the inspector should document any deficiency in implementation and enforcement
in the contributing jurisdictions.
In principal, the PCI should cover the CA's pretreatment program through the last four fall
quarters1. If the PCI occurs within three months after the end of the Ca's pretreatment year, then
the inspector may choose to review data through the CA's pretreatment year in order to validate
the information the CA submitted in its pretreatment program performance report.
'EPA's September 9, 1991, memorandum, Application and Use of the Regulatory Definition of Significant
Noncompliance for Industrial Users addresses the concept of quarters in terms of calculating SNC. Briefly, at the
end of each quarter, all data from the previous 6-month time period is to be used in the calculation of SNC. Under
this system, each IU is evaluated for SNC four times during the year and the total evaluation period covers 15
months (i.e., beginning with the last quarter of the previous pretreatment year through the end of the current
year).
-------
THIS PAGE INTENTIONALLY LEFT BLANK
-------
2.
POTW PCI CHECKLIST
TABLE OF CONTENTS
COVER PAGE
SECTION I: IU FILE EVALUATION 1
CA Notification of IU 5
Issuance of IU Control Mechanism 6
CA Application of IU Pretreatment Standards 7
CA Compliance Monitoring g
CA Enforcement Activities 9
IU Compliance Status 10
SECTION II: SUPPLEMENTAL DATA REVIEW/INTERVIEW 13
CA Pretreatment Program Modification 13
IU Characterization 14
Control Mechanism Evaluation 15
Application of Pretreatment Standards and Requirements ....'. 16
Compliance Monitoring 17
Enforcement ig
SECTION III: EVALUATION AND SUMMARY 21
CA Pretreatment Program Modification 21
IU Characterization 21
Control Mechanism Evaluation 21
Application of Pretreatment Standards and Requirements 22
Compliance Monitoring „ 22
Enforcement 24
-------
2.
POTW PCI CHECKLIST
TABLE OF CONTENTS (Continued)
PAGE
ATTACHMENT A: PRETREATMENT PROGRAM STATUS UPDATE . A-1
CA Information . A-1
Pretreatment Program Status A-1
!
ATTACHMENT B: PRETREATMENT PROGRAM PROFILE ;. . B-1
CA Information . B-1
Pretreatment Program Modifications . B-1
Treatment Plant Information ;. . B-2
Legal Authority . B-3
IU Characterization . B-4
Control Mechanism B-4
Application of Standards ,. . B-5
Compliance Monitoring :. . B-5
Enforcement . B-6
Data Management/Public Participation '. . B-6
Resources B-6
Additional Information B-7
ATTACHMENT C: WORKSHEETS . C-1
WENDB Data Entry Worksheet . C-1
RNC Worksheet :. . C-3
IU Site Visit Report Form . C-5
File Review Worksheet . C-9
IU Self-Monitoring Worksheet !. . C-10
POTW Monitoring Reports Worksheet C-11
Violations Based on IU Self-Monitoring and POTW Monitoring Data Worksheet . C-12
Enforcement Actions Against IU Worksheet . C-13
ClUs Worksheet . C-14
-------
POTW PRETREATMENT COMPLIANCE INSPECTION CHECKLIST
PCI CHECKLIST CONTENTS
Cover Page
D Section 1 JU Rle Evaluation
Q Section t! Supplemental Data Review/Interview
d Section }II Evaluation and Summary
EU Attachment A Pretreatment Program Status Update
O Attachment 8 Pretreatment Program Profile
LJ Attachment C Worksheets
D WENDB Data Entry Worksheet
D RNC Worksheet
D 1U Site Visit Report Form (Optional)
D File Review Worksheets (Optional)
Attachment D Supporting Documentation
-
CA name and address:
PIRT/DSS incorporated in NPDES permit?
Date(s) of PCI
Period covered by PCI
Yes No
INSPECTOR(S)
Name
Name
Title/Affiliation
Telephone Number
CA REPRESENTATIVE(S)
Title/Affiliation
*
Telephone Number
'Identified program contact
-------
ACRONYM LIST
BMR
CA
CFR
CIU
CSO
CWA
CWF
DSS
EP
EPA
ERP
FTE
FWA
gpd
IU
IWS
MGD
MSW
N/A
N/D
NPDES
O&G
PIRT
POTW
RCRA
RNC
SIU
SNC
TCLP
TRC
TTO
WENDB
Term
Baseline Monitoring Report
Control Authority
Code of Federal Regulations
Categorical Industrial User
Combined Sewer Overflow
Clean Water Act
Combined Wastestream Formula
Domestic Sewage Study
Extraction Procedure
U.S. Environmental Protection Agency
Enforcement Response Plan
Full-Time Equivalent
Flow-Weighted Averaging
gallons per day
Industrial User
Industrial Waste Survey
Million Gallons Per Day
Municipal Solid Waste
Not applicable
Not determined
National Pollutant Discharge Elimination System
Oil and Grease
Pretreatment Implementation Review Task Force
Publicly Owned Treatment Works
Resource Conservation and Recovery Act
Reportable Noncompliance
Significant Industrial User
Significant Noncompliance
Toxicity Characteristic Leachate Procedure
Technical Review Criteria
Total Toxic Organics
Water Enforcement National Data Base
-------
SECTION I: IU FILE EVALUATION
INSTRUCTIONS: Select a representative number of files to review. Provide relevant details on each file
reviewed. Comment on problems identified. Where possible, all ClUs (and S/UsJ added since the fast PCI or
audit should be evaluated. Make copies of this section to review additional files as necessary.
NARRATIVE COMMENTS
FILE
Industry name and address
Total flow (gpd)
Process flow (gpd)
Type of industry (products manufactured)
Industry visited during PCI
Yes
No
Applicable Federal
category
Compliance status ED SNC (period:
LJ Noncompliance/corrected
LJ Noncompliance/continuing
Comments
-------
SECTION I: IU FILE EVALUATION (Continued)
NARRATIVE COMMENTS
FILE.
Industry name and address
Total flow (gpd)
Procbss flow (gpd)
Type of industry (products manufactured)
Industry visited during PCI
Yes CD No CH
Applicable Federal
category
Compliance status
SNC (period: )
Noncompliance/corrected
Noncompliance/continuing
Comments
FILE
Industry name and address
Total flow (gpd)
Process flow (gpd)
Type of industry (products manufactured)
Industry visited during PCI
Yes
No
Applicable Federal
category
Compliance status
SNC (period: )
Noncompliance/corrected
Noncompliance/continuing
Comments
-------
SECTION I: IU FILE EVALUATION (Continued)
NARRATIVE COMMENTS
FILE
Industry name and address
Total flow (gpd)
Process flow (gpd)
Type of industry (products manufactured)
Industry visited during PCI
Yes
No
Applicable Federal
category
Compliance status
SNC (period:
I—I Noncompliance/corrected
I—I Noncompliance/continuing
Comments
FILE
Industry name and address
Total flow (gpd)
Process flow (gpd)
Type of industry (products manufactured)
Industry visited during PCI
Yes LJ No L]
Applicable Federal
category
Compliance status EH SMC (period:
Noncompliance/corrected
Noncompliance/continuing
Comments
-------
THIS PAGE LEFT INTENTIONALLY BLANK
-------
SECTION I: IU FILE EVALUATION (Continued)
Industry Name
INSTRUCTIONS: Evaluate the contents of SlU files. Indicate problem areas with an
///. Use N/A (not applicable) where necessary. Use ND (not determined) where
there is insufficient information to evaluate/determine implementation status. Leave
the space blank when a problem is not noted. Comment on each problem identified.
Clearly identify the file that each comment pertains to; also indicate where a
comment applies to all the files.
File
File
File
File
File
IU FILE REVIEW
Reg.
Cite
A. CA NOTIFICATION OF IU
1. Notification of classification or change in classification
2, Notification of applicable standards/requirements/RCftA
403.8(f)(2)(iii)
403.S(fK2K»«)
Comments
-------
SECTION I: IU FILE EVALUATION (Continued)
File
File
File
File
File
EU FILE REVIEW
Reg.
Cite
B. ISSUANCE OF IU CONTROL MECHANISM
1. Issuance or reissuance of control mechanism
2. Control mechanism contents
a. Statement of duration (<_ 5 years)
b, Statement of nontransferabllity
c. Applicable effluent limits (local limits, categorical standards)
. d. Self-monitoring requirements ;
• Identification of pollutants to be monitored
i
• Sampling frequency
• Sampling locations/discharge points
» Sample types {grab or composite)
• Reporting requirements
* Record-keeping requirements 1
e. Statement of applicable civil and criminal penalties
f. Compliance schedules '
g. Notice of slug loading
h. Notification of spills, bypasses, upsets, etc.
i. Notification of significant change in discharge
}. 24-hour notification of violation/resample requirement
k. Slug discharge control plan requirement
403,8
-------
SECTION I: 1U FILE EVALUATION (Continued)
File
File
File
File
File
IU FILE REVIEW
Reg.
Cite
CA APPLICATION OF IU PRETREATMENT STANDARDS
1. IU categorization
2. Calculation and application of categorical standards
a. Classification by category/subcategory
b> Classification as new/existing source
c. Application of limits for all regulated pollutants
3. Application of local limits
4. Calculation and application of production-based standards
5, Calculation and application of CWF or FWA
6. Application of most stringent limit
403.8(flW(ii)
403.5
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SECTION I: IU FILE EVALUATION (Continued)
File
File
File
File
File
IU FILE REVIEW
Reg.
Cite
IX CA COMPLIANCE MONITORING
Sampling
11 Sampling {once a year}
2. Sampling at frequency specified in approved program
3» Documentation of sampling activities
4. Analysis of results for all parameters
$. Appropriate analytical methods (40 CFft Part 136) ,
Inspection
6. Inspection (once a year)
7. Inspection at frequency specified in approved program
8. Documentation Of inspection activities
9. Evaluation of need for slug discharge control plan
403.8 (W2JM
4Q3.8#)(2Kvi)
403.8(f)(2)(vi)
403.8(f)(2)(v)
Comments
8
-------
SECTION I: IU FILE EVALUATION (Continued)
File
File
File
File
File
IU FILE REVIEW
Reg.
Cite
E. CA ENFORCEMENT ACTIVITIES
1. Identification of violations
a. Discharge violations
b. Monitoring/reporting violations
c. Compliance schedule violations
2. Calculation of SNC
3. Adherence to approved ERP
4. Escalation of enforcement
5, Publications for SNC
403.8(f)(2)(vi)
403.8(f)(2)(vii)
403.8
Comments
-------
SECTION I: IU FILE EVALUATION (Continued)
File
File
File
File
File
IU FILE REVIEW
Reg.
Cite
COMPLIANCE STATUS
Self-Monitoring and Reporting
Sampling at frequency specified in contra! mechanism/regulation
2. Analysis of all required pollutants
3, Submission of BMR/90-day report :
4. Periodic self-monitoring reports
5. Reporting ail required pollutants \
6. Signatory/certification of reports '
7. Submission of compliance schedule reports by required dates i
8. Notification within 24 hours of becoming aware of violations
•".< i
• Discharge violation
• Slug load
« Accidental spill *
9. Resampling/reporting within 30 days of knowledge of violation
y-1 [
10. Notification of hazardous waste discharge 1
11. Submission/implementation of slug discharge control plan
12. Notification of significant changes
403.12(g)(1)&(h)
403
403.12(e)&(h)
4Q3.12(g«1}&{K)
403.12(1)
403.12(g)<2)
403.12(g)(2)
403.12fj)&(p}
403.8(f)(2)(v)
INSTRUCTIONS: Indicate the lU's noncompliance status by placing an "X" in the appropriate box.
1
Discharge
13. Noncompliance with discharge limits (but not SNC)
14, SNC
a. Chronic violations
b. TRC
c. Pass through or interference
* Spill or slug load
d. Other discharge violations (specify)
Reporting
15. Noncompliance with reporting requirements (but not SNC)
16. SNC with reporting requirements
403.8{f}(2)(vji)
[403.5(a)(1)]
|403.U(fH
403.8(f)(2)(vii)
403,S(M3)
-------
SECTION I: IU FILE EVALUATION (Continued)
File
File
File
File
File
IU FILE REVIEW
Reg.
Cite
G< OTHER
Comments
SECTION I COMPLETED BY:
TITLE:
DATE:
TELEPHONE:
11
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THIS PAGE LEFT INTENTIONALLY BLANK
12
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SECTION II: SUPPLEMENTAL DATA REVIEW/INTERVIEW
INSTRUCTIONS: Complete this section during the onsite visit based on CA activities since the last PCI or
audit. Attach documentation where appropriate. Specific data may be required in some cases.
A. CA PRETREATMENT PROGRAM MODIFICATION {40&1«3
1. Did the CA make substantial changes to the pretreatment program that were not
approved by the Approval Authority (e.g., definitions, limits)?
If yes, describe.
YSS
No
2. Is the CA in the process of modifying any approved pretreatment program component
(including legal authority, local limits, DSS requirements, etc.)?
If yes, describe.
Yes
No
13
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SECTION II: SUPPLEMENTAL DATA REVIEW/INTERVIEW (Continued)
B. tU CHARACTERIZATION w**wmmm \ ;
1. How and when does the CA update its IWS to identify new lUs or changes in wastewater discharges at
existing (Us? [403.8(f)(2)(i)i
2. How many IDs are currently identified by the CA in each of the following groups?
a. | SlUs (as defined by the CA) [WENDB-SIUSI
ClUs [WENDB-CIUS]
Noncategorical SI Us
b.
c.
Other regulated noncategorical IDs (specify)
TOTAL
14
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SECTION II: SUPPLEMENTAL DATA REVIEW/INTERVIEW [Continued)
CONTROL MECHANISM EVALUATION
1 . a. How many SlUs (as defined by the CA) are required to be covered by an individual
control mechanism?
b. How many SlUs are not covered by an existing, unexpired permit or other
individual control mechanism? [WENDB-NOCMJ [RNC-IIJ
If any, explain.
2. How many control mechanisms were not issued within 180 days of the expiration date of the
previous control mechanism? [RNC-ii]
If any, explain.
15
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SECTION II: SUPPLEMENTAL DATA REVIEW/INTERVIEW (Continued)
D. APPLICATION OF PRETREATMENT STANDARDS AND REQUIREMENTS
1. a. How many SlUs were not evaluated for the need to develop slug discharge control plans in
the last 2 years? [403.8{f)(2)(v)j I
b. List the SlUs below or attach additional sheets as needed.
2. Did the CA apply all applicable categorical standards and local limits to I Us
whose wastes are hauled to the POTW?
If yes, identify the industries.
N/A
Yes
If no, explain.
3. Did any lUs notify the CA of a hazardous waste discharge? [403.i2(j)&(p>]
If yes, identify and explain.
Yes
No
16
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SECTION II: SUPPLEMENTAL DATA REVIEW/INTERVIEW (Continued)
E, COMPLIANCE MONITORING
1. Identify the following.
Program
Aspect
Required
Frequency
Actual
Frequency
Explain Difference
a, Inspection
• ClUs
• Other SlUs
p. Sampling Iby CA)
• ClUs
• Other SlUs
c. Self-Monitoring
• ClUs
• Other SlUs
d- Reporting
ClUs
Other SlUs
2. In the past 12 months, how many, and what percentage of, SlUs were the following? [403.8(f)(2)(v>] [WENDB-
NOIN] [RNC-II]
a. Not sampled or not inspected at least once IWENDB-NOINI
b. Not sampled at least once
c. Not inspected at least once
If any, explain.
17
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SECTION II: SUPPLEMENTAL DATA REVIEW/INTERVIEW (Continued)
P. ENFORCEMENT : / ; j
1 . Which of the following enforcement actions did the CA use?
a. Notice or letter of violation
b. Administrative Orders
c. Administrative fines
d. Show cause hearings
e. Compliance schedules
f. Permit revocation
g. Civil suits
h. Criminal suits
i. Termination of service
j. Other (specify)
N/A
Yes
No
Explain if appropriate. II
2. Did the CA comply with its approved ERP? [403.8
-------
SECTION II: SUPPLEMENTAL DATA REVIEW/INTERVIEW (Continued)
F, ENFORCEMENT {Continued)
4. Did the CA publish all SlUs in SNC in the largest daily newspaper in accordance with
NPDES permit requirements? [403.8(f)(2)(vii)i
If yes, attach a copy.
If no, explain.
Yes
No
5. How many SlUs are in SNC with self-monitoring requirements and were not inspected and/or
sampled (in the four most recent full quarters)? IWENDB-SNINI
6. a. Did the CA experience any of the following caused by industrial discharges?
« Interference
• Pass through
« Fire or explosions (flashpoint, etc.)
« Corrosive structural damage
« Flow obstructions
• Excessive flow rates
• Excessive pollutant concentrations
• Heat problems
• Interference due to O&G
» Toxic fumes
• Illicit dumping of hauled wastes
• Worker health and safety
• Other (specify)
Yes
No
Unk
Explain
b. If yes, did the CA take enforcement action against the IDs causing or contributing
to pass through or interference? IRNC-U
Yes
No
19
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SECTION II: SUPPLEMENTAL DATA REVIEW/INTERVIEW (Continued)
F. ENFORCEMENT (Continued!
7. a. How many SlUs are on compliance schedules?
b. List these SlUs by name and compliance schedule end dates (attach additional sheets as needed).
SIU
End Date
8. Were any ClUs allowed more than 3 years from the effective date of a categorical
standard to achieve compliance? [403.6(t>>]
If yes, identify and explain.
Yes
No
9. Did the SlUs return to compliance by any of the following? [RNC-IJ
a. Within 90 days
b. Within the time specified in the ERP
c. Through a compliance schedule
Yes
No
G. ADDITIONAL EVALUATIONS
INSTRUCTIONS: Attach additional sheets as needed.
SECTION II COMPLETED BY:
TITLE:
POTW REPRESENTA TIVE
PROVIDING RESPONSES:
DATE: ;
TELEPHONE:
DATE:
TELEPHONE:
20
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SECTION III: EVALUATION AND SUMMARY
INSTRUCTIONS: Identify program components that the CA is recommended I'Rec.J or required (Req.) to
implement in order to effectively implement the pretreatment program and/or to meet its regulatory
requirements. Specify the corrective action the CA needs to take.
A,
1.
B.
1.
2.
C.
1.
Regulatory <
Description Citation Q
CA PRETREATMENT PROGRAM MODIFICATION
Notify of program modification 403.18
'
IU CHARACTERIZATION
Identify and locate all SlUs 403.8(f)<2Xi)
Identify the character and volume of pollutants 4O3.8(f)(2)(H) n
contributed to POTW by lUs
CONTROL MECHANISM EVALUATION
Issue individual control mechanisms to all SlUs 403.8(f)(D(iio I.B
Action
Checklist
uesf fonts) Rec* Re<'<
II. A
II. B
.B.1; II.E.1
.1; 1I.C.1&2
21
-------
SECTION III: EVALUATION AND SUMMARY (Continued)
c.
2.
D.
1.
2.
E.
1.
s
1 Action
Regulatory Checklist ~
Description Citation Question^} Rec* Re<>-
CONTROL MECHANISM EVALUATION (Continued)
Ensure control mechanisms contents 403.s(f)d)(iii) i.B.2.a-j ,
include:
a. A statement of
b. A statement of
c. Effluent limits
d. Self-monitoring
e. A statement of
duration f. Compliance schedules
nontransferability g. Notice of slug loading
h. Notification of spills, bypasses, upsets, etc.
requirements i. Notification of significant change in discharge
penalties j. 24-hour notification of violation/resample irequirement
APPLICATION OF PRETREATMENT STANDARDS AND REQUIREMENTS
Apply all applicable pretreatment standards 403.8(f)(i)(ii); 403.5 i.e. 1-6; n.D.2
Evaluate the need 1
control plans
or SlUs to develop slug discharge 403.8(f)(2)(v) I.D.S; 11.0.1
i
COMPLIANCE MONitpRiNG . ,}
Inspect and sample
approved program
each SIU in accordance with Approved program I.D.2&7; II.E.1
22
-------
SECTION ill: EVALUATION AND SUMMARY (Continued)
Description
Regulatory
Citation
Checklist
(luestion(s)
Action
Rec. Req.
i, COMPLIANCE MONITORING {Continued}
2. Inspect and sample each SIU once a year
403.8(f)(2)(v)
I.D.1&6; II.E.1&2
3. Use proper sampling analysis (40 CFR Part 136) and
inspection procedures
403.8(f)(2)(vi)
I.D.3.5&8
4. Require, receive, and analyze reports from SlUs
403.8(f)(2)(iv)
II.E.1
5. Monitor to demonstrate continued compliance and
resampling after violation(s)
403.12{g)(1)&(2)
I.F.3.4&9
6. Ensure ClUs report on all regulated pollutants at least
once every 6 months
403.12{g)(1)
I.F.2&5
23
-------
SECTION III: EVALUATION AND SUMMARY (Continued)
Description
Regulatory
Citation
Checklist
Question^}
Action
Req.
E, COMPLIANCE MONITORING {Continued)
7. Ensure noncategorical SlUs self-monitor and report all
regulated pollutants at least once every 6 months
403.12(h)
I.F.2&5
8. Require self-monitoring reports from ClUs to be signed
and certified and reports from SlUs to be signed
403.12(1);
403.6(a)(2)(ii)
I.F.6
9. Receive notification of hazardous waste discharges
403.12(j)&(p)
I.F.10; II.D.3
F. ENFORCEMENT
1. Implement approved ERP
403.8(f)(5)
I.E.3; II.F.2
2. Annually publish a list of ILJs in SNC
403.8(f)(2)(vii)
I.E.5; II.F.4
24
-------
SECTION III: EVALUATION AND SUMMARY (Continued)
Description
Regulatory
Citation
Action
Checklist
Question(s)
Rec*
Req.
. ENFORCEMENT (Continued)
3. Develop IU compliance schedules
403.8{f)(1)(iv)(A)
I.B.2.f; II.F.1.7&9
4. Ensure IU compliance within 3 years of standards
effective date (or less than 3 years where required by
standard)
403.6(b)
II.F.8
5. Ensure new sources report on compliance with
appropriate standards within the first 90 days of
discharge
403.12(d)
I.F.3
G. ADDITIONAL EVALUATIONS
SECTION III COMPLETED BY:
TITLE:
DATE:
TELEPHONE:
25
-------
THIS PAGE LEFT INTENTIONALLY BLANK
-------
PRETREATMENT PROGRAM STATUS UPDATE
INSTRUCTIONS: This attachment is intended to serve as an update of program status. It should be updated
prior to each PCI based on information obtained from the most recent PCI and/or audit and the last pretreatment
program performance report.
A, CA INFORMATION
1 . CA name
2. a. Pretreatment contact b. Mailing address
c. Title d. Telephone number
3. Date of last CA report to Approval Authority
4. Is the CA currently operating under any pretreatment-related consent decree,
Administrative Order, compliance schedule, or other enforcement action?
Yes No
5. Effluent and sludge quality
a. List the NPDES effluent and sludge limits violated and the suspected cause(s).
Parameters Violated
Cause(s)
b. Has the treatment plant sludge violated these tests?
• EP toxicity
• TCLP
Yes No
B. PRETREATMENT PROGRAM STATUS
1 . Indicate components that were identified as deficien
a. Program modification
b. Legal authority
c. Local limits
d. ID characterization
e. Control mechanism
f . Application of pretreatment standards
g. Compliance monitoring
h. Enforcement program
i. Data management
j. Program resources
k. Other (specify)
t.
Last PCI
Date:
Last Audit
Dat«:
Program Report
Date:
A-1
ATTACHMENT A: UPDATE
-------
PRETREATMENT PROGRAM STATUS UPDATE (Continued)
B. PRETREATMENT PROGRAM STATUS {Continued*
2. Is the CA presently in RNC for any of these violations?
a. Failure to enforce against pass through and/or
interference [RNC-IHSNC]
b. Failure to submit required reports within 30 days [RNC-IHSNC]
c. Failure to meet compliance schedule milestones within
90 days [RNC-IHSNC]
d. Failure to issue/reissue control mechanisms to 90 percent
of SlUs within 6 months [RNc-ni
e. Failure to inspect or sample 80 percent of SI Us within
the last 1 2 months [RNC-IIJ
f. Failure to enforce standards and reporting requirements IRNC-II]
g. Other (specify) [RNC-III
Data Source
Yes
No
3. List SlUs in SNC identified in the last pretreatment program performance report, PCI, or audit (whichever is
most recent).
Name of SIU in SNC Compliance Status
Source
4. Indicate the number and percent of SlUs that were identified as being in SNC* with the following
requirements from the CA's last pretreatment program performance report. If the CA's report does not
provide this information, obtain the information for the most recent four full quarters during the PCI.
SNC
Evaluation Period
% Applicable pretreatment standards and reporting requirements *SNC defined by:
% Self-monitoring requirements
% Pretreatment compliance schedules
POTW
EPA
5. Describe any problems the CA has experienced in implementing or enforcing its pretreatment program.
E
ATTACHMENT A COMPLETED BY:
TITLE:
DATE:
TELEPHONE:
ATTACHMENT A: UPDATE
A-2
-------
PRETREATMENT PROGRAM PROFILE
INSTRUCTIONS: This attachment is intended to serve as a summary of program information. This background information
should be obtained from the original, approved pretreatment program submission and modifications and the NPDES permit.
The profile should be updated, as appropriate, in response to approved modifications and revised NPDES permit requirements.
A. CA INFORMATION
1. CA name
2. Original pretreatment program submission approval date
3. Required frequency of reporting to Approval Authority
4. Specify the following CA information.
Treatment Plant Name
NPDES Permit Number
5. Does the CA hold a sludge permit or has the NPDES permit been modified to includi
disposal requirements?
If yes, provide the following information.
3POTW Name
Issuing
Authority
Issuance Expiration
Bate Bate
B. PRETREATMENT PROGRAM MODIFICATIONS __
Effective Expiration
Bate Bate
Yes No
Regulated Pollutants
•'
1. When was the CA's NPDES permit first modified to require pretreatment implementation? [WENDB-
PTIM]
2. Identify any substantial modifications the CA made in its pretreatment program since the. approved pretreatment program
submission. [403.18]
Bate Approved
Nature Of Modification
Bate Incorporated 'in
NPDES Permit
B-l
ATTACHMENT B: PROFILE
(revised April 1992)
-------
PRETREATMENT PROGRAM PROFILE (Continued)
C. TREATMENT PLANT INFORMATION
INSTRUCTIONS; Complete this section for each treatment plant operated under an NPDES permit issued to the CA.
1. Treatment plant name
2. Location address
3. a. NPDES permit number
b. Expiration date
4. Treatment plant wastewater flows
Design | I MOD Actual
MOD
5. Sewer system I a. Separate
b. Combined
c. Number of CSOs
6. a. Industrial contribution (MOD)
b. Number of SIUs discharging to plant
c. Percent industrial flow to plant
7. Level of treatment
a. Primary
b. Secondary
c. Tertiary
Type of Process(es)
8. Indicate required monitoring frequencies for pollutants identified in NPDES permit.
a. Metals
b. Organics
c. Toxicity testing
d. EPtoxicity
e. TCLP
Influent
Crimes/Year)
Effluent
(Times/Year)
Sludge
(Times/Year)
Receiving Stream
(Times/Year)
9. Effluent Discharge
a. Receiving water name
b. Receiving water classification
c. Receiving water use
d. If effluent is discharged to any location other than the receiving water, indicate where.
10. 301(h) waiver (ocean discharge)
a. Applied for
b. Granted
Yes
No
c. Date of application
d. Date approved or denied
11. Did the CA submit results of whole effluent biological toxicity testing as part of its
NPDES permit applications)? [122.21®(1) and (2)]
a. If yes, did the CA use EPA-approved methods? [I22.21Q)(3)]
b. Has there been a pattern of toxicity demonstrated?
N/A.
• Yes
No
12. Indicate methods of sludge disposal.
Quantity of Sludge
a. Land application dry tons/year
b. Incineration dry tons/year
c. Monoflll dry tons/year
d. MSW landfill dry tons/year
Quantity of Sludge
e. Public distribution
f. Lagoon storage
g. Other (specify)
dry tons/year
dry tons/year
dry tons/year
ATTACHMENT B: PROFILE
(revised April 1992)
B-2
-------
PRETREATMENT PROGRAM PROFILE (Continued)
1>. LEGAL AUTHORITY ,
1. a. Indicate where the authority to implement and enforce pretreatment standards and requirements is contained (cite
legal authority).
b. Date enacted/adopted
c. Date of most recent revision
2. Does the CA's legal authority enable it to do the following: [403.8(0(l)Ci-vH)]
a. Deny or condition pollutant discharges [403.8(0(1)0)]
b. Require compliance with standards [403.8(f)(l)C»)]
c. Control discharges through permit or similar means [403.8(0(1)0")]
d. Require compliance schedules and IU reports [403.8(f)(l)(iv)]
e. Cany out inspection and monitoring activities [403.8(f)(l)(v)]
f. Obtain remedies for noncompliance [403.8(Q(l)(vi)]
g. Comply with confidentiality requirements? [403.8(0(l)(vn)]
3. a. How many contributing jurisdictions are there?
List the names of all contributing jurisdictions and the number of SIUs in th
Jurisdiction Name
Yes
ose jurisdictions.
No
Number of CIUs Number at Other SIUs
b. Has the CA negotiated all legal agreements necessary to ensure that pretreal
be enforced in contributing jurisdictions?
If yes, describe the legal agreements (e.g., intergovernmental contract, agre
ment standards will Yes
No
.ement, IU contracts, etc.).
4. If relying on contributing jurisdictions, indicate which activities those jurisdictions perform.
a. IWS update
b. Permit issuance
i
c. Inspection and sampling
d. Enforcement
e. Notification of lUs
f. Receipt and review of IU reports
g. Analysis of samples
h. Other (specify)
'
B-3
ATTACHMENT B: PROFILE
(revised April 1992)
-------
PRETREATMENT PROGRAM PROFILE (Continued)
E. W
1. a. Does the CA have procedures to update its IWS to identify new HJs or changes in wastewater
discharges at existing ILTs? [403.8(0(2)®]
Yes
b. Indicate which methods are to be used to update the IWS.
• Review of newspaper/phone book
• Review of water billing records
• Review of plumbing/building permits
c. How often is the IWS to be updated?
No
• Onsite inspections
• Permit application requirements
• Citizen involvement
• Other (specify)
2. Is the CA's definition of "significant industrial user" consistent within the language in the Federal
regulations? [403.3(t)(l>]
If no, provide the CA's definition of "significant industrial user."
Yes
No
F. CONTROL MECHANISM
1. a. Identify the CA's approved control mechanism (e.g., permit, etc.).
b. What is the maximum term of the control mechanism?
2. Does the approved control mechanism include the following? [403.8(0(1)0"')]
a. Statement of duration
b. Statement of nontransferability
c. Effluent limits
d. Self-monitoring requirements
• Identification of pollutants to be monitored
• Sampling location
• Sample type
• Sampling frequency
• Reporting requirements
• Notification requirements
• Record keeping requirements
e. Statement of applicable civil and criminal penalties
f. Applicable compliance schedule
3. Does the CA have a control mechanism for regulating Ills whose wastes
are trucked to the treatment plant?
N/A •
Yes
No
•. Does the program identify designated discharge point(s) for trucked or
hauled wastes? [403.5(b)(8)]
If yes, describe the discharge point(s) (including security procedures).
ATTACHMENT B: PROFILE
(reviled April 1992)
B-4
-------
PRETREATMENT PROGRAM PROFILE (Continued)
G» APPLICATION OF STANDARDS
1. Does the CA have procedures to notify all Ills of applicable pretreatment standards and any
applicable requirements under the CWA and RCRA? [403.8(f)(2)Cui)]
2. If there is more than one treatment plant, were local limits established specifically for
each plant?
N/A
3. Has the CA technically evaluated the need for local limits for all pollutants listed below? [WENDB-
EVLL] [403.5(c)(l); 403.8®(4)]
a. Arsenic (As)
b. Cadmium (Cd)
c. Chromium (Cr)
d. Copper (Cu)
e. Cyanide (CM)
f . Lead (Pb)
g. Mercury (Hg)
h. Nickel (Ni)
i. Silver (Ag)
j. Zinc (Zn)
k. Other (specify)
Partial Technical Evaluation (not all 10 pollutants evaluated)?
Headwords
Analysis
Completed?
Yes :
No
Technically
Evaluated?
Yes
No
Local Limits
Adopted?
Yes
No
Yes No
Yes No
Local Limit
(Numeric)
H. COMPLIANCE MONITORING
1. Indicate compliance monitoring and inspection frequency requirements.
Program Aspect
a. Inspections
• CIUs
• Other SIUs
b. Sampling by POTW
• CIUs
• Other SIUs
c. Self-monitoring
• CIUs
• Other SIUs
d. Reporting by H7
• CIUs
• Other SIUs
Approved
Program
Requirement
NPDES Permit
Requirement
State
Requirement
Minimum Federal
Requirement
- « T ' '
I/year
I/year
""
I/year
I/year
J J J J-
2/year
2/year
:
2/year
2/year
B-5
ATTACHMENT B: PROFILE
(revised April 1992)
-------
PRETREATMENT PROGRAM PROFILE (Continued)
1. Does the CA's program define " significant noncompliance?"
If yes, is the CA's definition of "significant noncompliance" consistent with EPA's? [403.8(f)(2)(vU)]
If no, provide the CA's definition of "significant noncompliance. "
No
2. Does the CA have an approved, written ERF? [403.8(0(5)]
Yes
No
3. Indicate the compliance/enforcement options that are available to the POTW in the event of IU noncompliance.
[403.8(f)(l)(vi)]
a. Notice or letter of violation
b. Compliance schedule
c. Injunctive relief
d. Imprisonment
e. Termination of service
f. Administrative Order
g. Revocation of permit
h. Fines (maximum amount)
• Civil $_
• Criminal $_
• Administrative $
./day/violation
../day/violation
./day/violation
J. DATA MANAGEMENT/PUBLIC PARTICIPATION
1. Does the approved program describe how the POTW will manage its files and data?
Are files/records
computerized?
hard copy?
both?
Yes
No
2. Are program records available to the public?
Yes
No
3. Does the POTW haverovisions to address claims of confidentialit? [403.8(f)(2)(vii)]
K. RESOURCES
1. What are the resource allocations for the following pretreatment program components:
a. Legal assistance
b. Permitting
c. Inspections
d. Sample collection
e. Sample analysis
f. Data analysis, review, and response
g. Enforcement
h. Administration?
TOTAL
FTEs
ATTACHMENTS: PROFILE
(revised April 1992)
B-6
-------
PRETREATMENT PROGRAM PROFILE (ContiniUMl)
K. RESOURCES (Continued)
2. Identify the sources of funding for the pretreatment program. [403.8(f)(3)]
a. POTW general operating fund
b. IU permit fees
c. Industry surcharges
d. Monitoring charges
e. Other (specify)
L. ADDITIONAL INFORMATION
ATTACHMENT B COMPLETED BY:
TITLE:
DATE:
TELEPHONE:
B-7
ATTACHMENT B: PROFILE
(revised April 1992)
-------
B-8
-------
WENDB DATA ENTRY WORKSHEET
1, WENDB DATA ENTRY WORKSHEET
INSTRUCTIONS: Enter the data provided by the specific checklist questions that are referenced.
CA name
NPDES number
Date of inspection
• Number of SlUs*
• Number of ClUs
- Number of SlUs without control mechanism
- Number of SlUs not inspected or sampled
- Number of SlUs in SNC** with standards or reporting
- Number of SlUs in SNC with self-monitoring
- Number of SlUs in SNC with self-monitoring and not inspected or
sampled
Date emteired into PCS
PCS
Code
SIUS
CIUS
NOCM
NOIN
PSNC
MSNC
SNIM
Checklist
Reference
II.B.2.a
II.B.2.a
ll.C.l.b
II.E.2
Att. A.B.4
Att. A.B.4
II.F.5
Data
*The number of SlUs entered into PCS is based on the CA's definition of "Significant Industrial User."
**As defined in EPA's 1986 Pretreatment Compliance Monitorina and Enforcement Guidance.
WENDB DATA ENTRY WORKSHEET
COMPLETED BY:
TITLE:
DATE:
TELEPHONE:
C-1
ATTACHMENT C: WORKSHEETS
-------
THIS PAGE LEFT INTENTIONALLY BLANK
C-2
ATTACHMENT C: WORKSHEETS
-------
RNC WORKSHEET
I. RNG WORKSHEET
NSTRUCTIONS: Place a check in the appropriate box on the left if the CA is found to be in RNC or SNC.
name
MPDES number
Date of inspection
Date entered into QNCR
Failure to enforce against pass through and/or interference
Failure to submit required reports within 30 days
Failure to meet compliance schedule milestone date within 90 days
Failure to issue/reissue control mechanisms to 90% of SlUs within 6 months
Failure to inspect or sample 80% of SlUs within the last 12 months
Failure to enforce pretreatment standards and reporting requirements
Other (specify)
Level
Checklist
Reference
II.F.6.b&9
Att. A.A.3
Att. A.A.4
II.C.1.D&2
II.E.2
II.F.2
SNC
CA in SNC for violation of any Level I criterion
CA in SNC for violation of two or more Level II criterion
For more information on RNC, please refer to EPA's 1990 Guidance for Reporting and Evaluating POTW Noncompliance with
Pretreatment Imnlementation Requirements.
RNC WORKSHEET COMPLETED BY:
TITLE:
DATE:
TELEPHONE:
C-3
ATTACHMENT C: WORKSHEETS
-------
THIS PAGE LEFT INTENTIONALLY BLANK
C-4
ATTACHMENT C: WORKSHEETS
-------
IU SITE VISIT REPORT FORM
HI, JU SITE VISIT REPORT FORM
INSTRUCTIONS: Use this form to record observations made during the site visit and findings based on the site
visit. Provide as much detail as possible.
Name of industry and city
Date of visit
Time of visit
Name(s) of inspector(s)
Provide name(s) and title(s) of industry representative(s).
Name
Title
1. What does this industry produce?
2. How is the industry classified by the POTW? Is this classification correct?
3. Have there been any significant changes in processes or flow?
4. What raw materials are used?
C-5
ATTACHMENT C: WORKSHEETS
-------
IU SITE VISIT REPORT FORM (Continued)
5. What processes are used to make the product(s)? (Attach a step-by-step diagram if possible.)
6. Where is water used and what is the source of the water (city, well, river, etc.)?
7. Describe the processes which discharge wastewater.
ATTACHMENT C: WORKSHEETS
C-6
-------
IU SITE VISIT REPORT FORM (Continued)
8. Describe the sample, location. Are the CA and industry using the same location?
9. Describe the treatment system which is in place.
C-7
ATTACHMENT C: WORKSHEETS
-------
IU SITE VISIT REPORT FORM (Continued)
10. Whafchemicals are maintained onsite? How are they stored? Is adequate spill prevention in place?
11. Are any hazardous wastes stored or discharged?
Additional comments
IU SITE VISIT REPORT FORM
COMPLETED BY:
TITLE:
DATE:
TELEPHONE:
ATTACHMENT C: WORKSHEETS
C-8
-------
FILE REVIEW WORKSHEET
IV, FILE REVIEW WORKSHEET
IU name
INSTRUCTIONS: For each pollutant required to be regulated record the local limit and categorical standard (if
applicable) that the CA should be applying and enforcing. Then record that actual discharge limits applied
through the control mechanism (permit). Also record the sample type and frequency required by the control
mechanism.
Permit issuance date
t
Parameter
Local
limit
Categorical
Standards
Daily
Average
Long-
Term
Average
Permit expiration date
Permit Discharge
Limits
Daily
Average
long-
Term
Average
Required
Sample Type
Required
Sample
Frequency
Comments
I
PERMIT LIMITS WORKSHEET
COMPLETED BY:
TITLE:
DATE:
TELEPHONE:
C-9
ATTACHMENTC: WORKSHEETS
-------
FILE REVIEW WORKSHEET (Continued)
V. IU SELF-MdNITORING WORKSHEET
IU name
INSTRUCTIONS: Review IU self-monitoring reports and data and record the information in the appropriate
columns below.
V,
Date Sample
Collected
; ^ 1U Self-Monitoring ,
Date Report
Received
Date Report
Due
Days
Late
Pollutants
Monitored
Do reports indicate 40 CFR Part 136 analytical methods were used?
Were self-monitoring reports signed/certified?
List any reports not signed/certified.
If subject to TTO certification, were they submitted as required?
Sample
Type
Pollutants
Missing
•
, Yes No
IU SELF-MONITORING WORKSHEET
COMPLETED BY:
TITLE:
DATE:
TELEPHONE:
ATTACHMENT C: WORKSHEETS
C-10
-------
FILE REVIEW WORKSHEET (Continued;)
VL POTW MONITORING REPORTS WORKSHEET |
IU name
•••••^•i^Mi^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
INSTRUCTIONS: Review POTW monitoring records am
columns either 1) note the actual data in the appropriate
the information was found in the POTW's monitoring
chain-of-custody was incomplete, or if analytical metho
Daw
Sample
Collected
1
Pollutants
Monitored
Sample
Time
Flow
Rate
Sample
Type
/ enter the information in column 1 and 2. For the other
i columns, or 2) indicate with a yes (Y) or no (N) whether
records. Indicate if sample type was inappropriate, if
ds other than Part 136 methods were used.
Preser*
vatlon
Method
Personnel
Chairt-
of-
Custody
40 CFR Part 136
Analytical
Techniques
I
POTW MONITORING REPORTS
WORKSHEET COMPLETED BY:
TITLE:
DATE:
TELEPHONE:
C-11
ATTACHMENT C: WORKSHEETS
-------
FILE REVIEW WORKSHEET (Continued)
VII. VlOLAtlON$ BASED ON IU SELF-MONITORING AND POTW MONITORING DATA WORKSHEET
IU name
INSTRUCTIONS: Review IU self-monitoring and POTW monitoring data; compare this information to the permit
limits; and list all violations.
Type
{Daily or
Long-Term
Average)
Date Re-
sampling
Results
Submitted
PQTW Monitoring or
IU Self-Monitoring
Monitoring Result
IU SELF-MONITORING AND POTW
MONITORING DATA WORKSHEET
COMPLETED BY:
TITLE:
DATE:
TELEPHONE:
ATTACHMENT C: WORKSHEETS
C-12
-------
FILE REVIEW WORKSHEET (Continued)
Vlll/ ENFORCEMENT ACTIONS AGAINST IU WORKSHEET
IU name
INSTRUCTIONS: Record violations, (e.g. 3/15/91. zinc), the enforcement actions taken by the CA (e.g.
telephone. 4/1/91) and the response of the IU (e.g. re-sampled, 4/15/91 - returned to compliance).
Date of
Violation
Nature of Violation
Action Taken
Spills, slugs, and accidental discharges
Action
Date
IU Response
Date of spill/slug
Response
Date
Time CA notified
Description of spill/slug
CA response
ENFORCEMENT ACTIONS AGAINST
IU WORKSHEET COMPLETED BY:
TITLE:
DATE:
TELEPHONE:
C-13
ATTACHMENT C: WORKSHEETS
-------
FILE REVIEW WORKSHEET (Continued)
IX. ClUs WORKSHEET
IU name
INSTRUCTIONS: Record information from IU file, note any apparent misapplication of the applicable categorical
pretreatment standards.
1. IU category (s)
2. List all applicable subcategories.
3. a. Does the sampling location contain nonregulated or dilution wastestreams?
• CA
• IU
b. If yes, is the CWF applied?
c. If yes, is FWA applied?
Yes
4. Is the facility subject to production-based standards?
a. If yes, provide the following information.
• Average production
• Average process flow
5. Provide the following information on TTO monitoring and reporting (if applicable).
a. Date initial scan performed
b. Date organic management plan submitted
c. Date(s) certifications submitted (in the past 12 months)
d. Date(s) monitoring performed (in the past 12 months)
ClUs WORKSHEET COMPLETED BY:
TITLE:
DATE:
TELEPHONE:
ATTACHMENT C: WORKSHEETS
C-14
-------
3.
PCI REFERENCE MATERIAL
-------
-------
PCI CHECKLIST QUESTION REFERENCE
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PCI CHECKLIST QUESTION REFERENCE
TABLE OF CONTENTS
PAGE
SECTION I: IU FILE EVALUATION 2
CA Notification of IU 2
Issuance of IU Control Mechanism .... 3
CA Application of IU Pretreatment Standards ......."....... . . . . 5
CA Compliance Monitoring 1 Q
CA Enforcement Activities ....... 15
IU Compliance Status 13
SECTION II: SUPPLEMENTAL DATA REVIEW/INTERVIEW 25
CA Pretreatment Program Modification 25
IU Characterization 2g
Control Mechanism Evaluation 28
Application of Pretreatment Standards and Requirements 29
Compliance Monitoring 30
Enforcement o.
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REFERENCE TO THE POTW PRETREATMENT COMPLIANCE INSPECTION
CHECKLIST QUESTIONS
The purpose of these instructions is to provide the inspector with guidance in conducting
a Pretreatment Compliance Inspection (PCI) of a local pretreatment program implemented by a
Publicly Owned Treatment Works (POTW) using the U.S. Environmental Protection Agency's
(EPA's) "POTW Pretreatment Compliance Inspection Checklist." The Checklist is intended to
serve as a guide to ensure the comprehensiveness of the PCI and as a tool for the
documentation of PCI findings. As such, the intent of the PCI questions may not always be
self-evident. Instead, the questions are meant to act as triggers to remind the inspector to
delve into specific program areas and to evaluate compliance with implementation requirements
in those areas. The same question may need to be asked in different ways to derive an
answer. The inspector should use this reference to obtain a better understanding of the intent
and scope of each Checklist question and as a guide to finding the answers required. He/she
should not be limited by the Checklist, but should obtain as much information as is necessary
to identify program implementation deficiencies.
This Checklist reference guide assumes that the Control Authority's (CA rs) program
has been modified to include the latest revisions to the General Pretreatment Regulations
[referred to as the Domestic Sewage Study (DSS) revisions]. For those CA programs that
have not been modified, the inspector needs to determine compliance with approved
program and National Pollutant Discharge Elimination System (NPDES) requirements that
are legally effective at the time of the PCI.
The CA is responsible for regulating all SlUs in its service area, regardless of the
jurisdiction in which they are located. The PCI should encompass the CA's program
implementation throughout its service area including contributing jurisdictions. When
reviewing each program component (i.e., IU inventory, issuance of control mechanism,
compliance monitoring, and enforcement) the inspector should document any deficiency in
implementation and enforcement in the contributing jurisdictions.
In principal the PCI should cover the CA's pretreatment program through the last four full
quarters1. If the PCI occurs within three months after the end of the CA's pretreatment year,
then the inspector may choose to review data through the CA's pretreatment year in order to
validate the information the CA submitted in its pretreatment program performance report.
EPA's September 9, 1991, memorandum, Application and Use of the Regulatory Definition nf Significant
Noncomphance for Industrial Users addresses the concept of quarters in terms of calculating SNC. Briefly at the
end of each quarter, all data from the previous 6-month time period is to be used in the calculation of SNC
violations. Under this system, each IU is evaluated for SNC four times during the year and the total evaluation
period covers 15 months (i.e., beginning with the last quarter of the previous pretreatment year through the end
of the current year).
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SECTION I
SECTION I: IU FILE EVALUATION
Each of the major program components in Section I of the Checklist is listed below along
with an explanation of the issue (generally an explanation of the regulatory requirement).
Guidance is provided on how the inspector can evaluate the CA's (or Ill's) compliance with the
program requirement and on what constitutes a deficiency. The "Where to Look" guides the
inspector to the most likely source or document that will contain the necessary data to
evaluate.
Narrative Comments
What: These comments provide a brief profile of the IU. This information should
summarize industrial categorization, discharge characterization, and compliance history.
Source: File information, interview comments, and site visit to the ID.
Comment Section: Some information is filled out at the start of the file review (e.g.,
name, address, etc.). Some information (e.g., category, flow, compliance status, etc.)
will be obtained as the review proceeds. The inspector should enter additional
information about the industry obtained from the interview with CA staff or site visit to
the IU.
IU File Review
A. CA Notification of IU
A.1. Notification of classification or change in classification
ISSUE: The CA is required to notify all lUs subject to the pretreatment program
of their classification as a Significant Industrial User (SIU).
WHERE TO LOOK: Control mechanism (e.g., permit), a written notice or letter, or
documentation of a conversation between the IU and the CA.
HOW TO EVALUATE: Look for documentation pertaining to the CA's notification
to the IU. If the inspector cannot locate documentation of such notification, a
deficiency should be noted.
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A.2. Notification of applicable standards/requirements/RCRA
ISSUE: The CA is required to notify all I Us subject to the pretreatment program
of applicable standards and requirements (including limits for discharge of
pollutants, sampling and reporting requirements, as well as the lU's
responsibilities under the Resource Conservation and Recovery Act [RCRA]).
WHERE TO LOOK: Control mechanism, a written notice or letter, or
documentation of a conversation between the IU and the CA.
HOW TO EVALUATE: Look for documentation pertaining to the CA's notification
to the IU. If the inspector cannot locate documentation of such notification, a
deficiency should be noted.
B.
Issuance of IU Control Mechanism
B.1. Issuance or reissuance of control mechanism
ISSUE: The CA is required to control IU discharges to the POTW. All SIU
discharges must be controlled under individual control mechanisms (i.e., permit,
order, or similar means). A CA is in Reportable Noncompliance (RNC) if it has not
reissued 90% of the control mechanisms within 180 days; from the expiration of
the existing control mechanisms.
WHERE TO LOOK: The control mechanism may be called "control mechanism,"
"order," "permit," etc. (e.g., "IU contract") and a complete copy of a current
control mechanism should be in the file.
HOW TO EVALUATE: If the inspector cannot locate a control mechanism or if
the control mechanism is not current or valid, a deficiency should be noted. If the
control mechanism has to be signed by the CA and the control mechanism is not
signed, it may not be valid.
The inspector should check an expired control mechanism to see if it has been or
will be reissued within 180 days from the expiration of the last control
mechanism. If the control mechanism is expired and not reissued, the CA may
have the authority to administratively extend the control mechanism (similar to
the Agency's authority under the NPDES). Check to see if there is a letter to the
permittee that indicates the control mechanism has been extended. However, the
inspector should be aware that an administrative extension may only be used in
unusual situations; it may not be used in lieu of sufficient staff to write control
mechanisms.
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SECTION I
B.2. Control mechanism contents
ISSUE; Individual control mechanisms issued to SlUs must contain minimum
conditions listed in 40 Code of Federal Regulations (CFR) 403.8(f)(1)(iii) (a-j on
the Checklist).
WHERE TO LOOK: Control mechanism.
HOW TO EVALUATE: Examine the control mechanism for the inclusion of the
following conditions. Carefully read the entire control mechanism. Many of the
conditions will probably be found in the section "Standard Conditions," or a
section similarly titled.
a. Statement of duration - the control mechanism cannot have a duration of
more than 5 years. If the permit does not contain such a statement or an
expiration date or has an effective period of more than 5 years, a deficiency
should be noted.
b. Statement of nontransferability - the control mechanism cannot be transferred
without, at a minimum, prior notification to the CA and provision of a copy of
the existing control mechanism to the new owner or operator.
c. Applicable effluent limits - the control mechanism must contain effluent limits
based on applicable general pretreatment standards in 40 CFR 403.5,
categorical pretreatment standards, local limits, and State and local law.
Deficiencies should be noted if the pretreatment standards contained in the
control mechanism are incorrect or if the CA has not applied all standards
(including monthly average limits) for all regulated pollutants. If the inspector
cannot determine whether the correct limits were applied (because the CA
has not documented any calculations or information is missing), then a ND
(not determined) should be recorded on the Checklist.
d. Self-monitoring requirements - the control mechanism must contain sampling,
reporting and record-keeping requirements including an identification of the
pollutants to be monitored, sampling location, sampling frequency, and
sample type. The CA may choose to conduct all compliance monitoring in
lieu of IU self-monitoring. In this case, the control mechanism need not
contain those self-monitoring requirements which the CA is performing on
behalf of the IU.
e. Statement of applicable civil and criminal penalties - the control mechanism
must contain a statement of applicable civil and criminal penalties for
violation of pretreatment standards and requirements.
f. Compliance schedules - if the control mechanism contains a compliance
schedule which extends the compliance date beyond applicable Federal
deadlines a deficiency should be noted.
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SECTION I
Notice of slug loading [40 CFR 403.12(f)] - if the control mechanism does not
contain this notification requirement a deficiency should be noted.
Notification of spills, bypasses, upsets, etc. [40 CFF 403.12(f)] - if the
control mechanism does not contain this notification requirement a deficiency
should be noted.
i. Notification of significant change in discharge [40 CFR 403.12(j)] - if the
control mechanism does not contain this notification requirement a deficiency
should be noted.
j. 24-hour notification of violation/resample requirement (40 CFR 403.12{g)] - if
the control mechanism does not contain this notification requirement a
deficiency should be noted.
k.
Slug discharge control plan requirement - if the CA has identified the lU as
needing a slug discharge control plan, the control mechanism should contain
a requirement to develop and implement such a plan. If the CA has
determined that the IU does not need to develop and implement a plan, the
inspector should record NA (not applicable) on the Checklist.
c- CA Application of IU Pretreatment Standards
C.1. IU categorization
JSSUE: The CA is required to correctly determine whether the IU is subject to
categorical pretreatment standards and, if so, which categorical standard(s)
applies. The inspector should be aware that an IU may be subject to more than
one categorical pretreatment standard since these standards apply to individual
industrial processes.
WHERE TO LOOK: Control mechanism, fact sheet, control mechanism application
form. Baseline Monitoring Report (BMR), process and flow diagrams, inspection
reports, correspondence, and IU site visit.
HOW TO EVALUATE: The inspector should attempt to verify proper
categorization by reviewing any applicable documentation. The inspector will
need to be familiar with the industrial categories regulated by categorical
pretreatment standards. The categorical pretreatment standards are found in
EPA's regulations Title 40, Chapter I, Subchapter N, Effluent Guidelines and
Standards, 40 CFR Parts 405-471. Numerous documents in the IU file may need
to be reviewed to obtain process information helpful in categorizing the IU If
information to make these determinations is missing from the file, or if the
standards in the control mechanism conflict with the inspector's own
conclusions, a visit to the IU may be necessary to determine or verify the correct
categorization. If a site visit is not made to verify proper categorization a
potential problem (e.g. possible miscategorization) should be recorded and
explained in the inspector's notes.
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C.2. Calculation and application of categorical standards
ISSUE: The CA is required to calculate and apply the applicable categorical
pretreatment standards to those industries regulated by categorical standards.
This includes: (a) correct classification by category and subcategory; (b) correct
classification as existing or new source [see 40 CFR 403.3(k) for definition]; and
(c) correct application of limits for all regulated pollutants.
WHERE TO LOOK; Control mechanism, fact sheet, control mechanism application
form, BMR, process and flow diagrams, inspection reports, and sampling data.
HOW TO EVALUATE: The inspector should review the lU's control mechanism
application, BMR, and process or flow diagrams to obtain information on its
industrial processes for possible categorization. These documents should also
provide information on any combined wastestreams. Inspection reports and
sampling data may indicate that the IU has more going on than is described in
other documents. The categorical pretreatment regulations [Pretreatment
Standards for Existing Sources (PSES) and Pretreatment Standards for New
Sources (PSNS)] will provide information on regulated processes and pollutants.
The information found in the file should be compared to the category specified by
the CA in the lU's control mechanism as well as to the Federal categorical
standard. The inspector should bear in mind that more than one categorical
standard may apply to a given IU. If sampling data are not consistent with
process descriptions or if process descriptions are inconsistent with those
described in the most likely categorical standards, the inspector will probably
need to schedule a site visit to the IU facility. The inspector should note any
deficiencies in the CA's application of the correct categorical standards (this
applies only to industries regulated by categorical standards, not all SlUs).
C.3. Application of local limits
ISSUE: The CA is required to calculate and apply appropriate limits, including
local limits and prohibited discharge standards, for all industries regulated by the
local pretreatment program.
WHERE TO LOOK: CA's ordinance and control mechanism.
Note: Local limits may apply at end-of-pipe or end-of-process, depending upon
the CA's permitting practices. If they are applied at end-of-process, the
ordinance should not refer to the local limits simply as discharge limits, but should
make it clear that they limit pollutants discharged from individual processes. The
inspector should review EPA rs Guidance Manual on the Development and
Implementation of Local Discharge Limitations Under the Pretreatment Program
for an explanation of different allocation methods for local limits.
HOW TO EVALUATE: The inspector needs to review the control mechanism
which should require compliance with the CA's ordinance, including its local limits
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SECTION I
and prohibited discharge standards. The control mechanism may cite these
standards or reiterate them in the standard conditions section. The inspector
should be aware that the CA does not have the authority to waive (or give a
variance to) these standards. If the CA has applied an lU-specific standard that is
less stringent than the standard listed in the ordinance, the inspector should
investigate this incident further to determine whether the CA has inappropriately
granted a variance from the local limits. If the ordinance contains language that
implies that the standards in the ordinance are end-of-pipe or end-of-process
limits that all Ills must meet, the CA cannot waive or grant variances from these
limits.
The CA may apply categorical standards at end-of-process and local limits at end-
of-pipe. In this case, the control mechanism must clearly state where each apply.
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If the ordinance contains numerical limits to be applied on an ID-specific basis,
the inspector should look for language which indicates that they represent
influent loadings which are not to be exceeded in the collection system. The
ordinance should also require compliance with the limits specified in the control
mechanism.
Further, the CA usually does not expect each IU to self-monitor for all the
pollutants regulated by local limits, but only for those reasonably expected to be
present. In this case, the control mechanism must specify which parameters are
to be monitored by that IU. If the control mechanism required the IU to self-
monitor for local limits and all parameters are not monitored, a deficiency should
be noted.
C.4. Calculation and application of production-based standards
ISSUE: The CA is required to calculate and apply appropriate limits for industries
regulated by production-based categorical standards.
WHERE TO LOOK: Control mechanism, fact sheet, control mechanism application
form, BMR, process and flow diagrams, and correspondence.
Note: The application of production-based standards requires production data
(i.e., pounds/number/square footage of "widgets"), flow data, and concentration
of pollutants. Separate calculations may be required for each production process,
depending upon industry configuration (e.g., one process versus multiple
processes). Some POTWs may be using alternate limits based on historical data
(applying an alternate concentration or mass limit as opposed to calculating a
production-based limit each day) [see 40 CFR 403.6(c)(2)], Alternate limits
should be based on a long-term measure of production. See Guidance Manual for
the Use of Production-Based Pretreatment Standards and the Combined
Wastestream Formula [September, 1985].
HOW TO EVALUATE: The control mechanism should state what categorical
standard the CA applied to the IU. The inspector should review the appropriate
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SECTION
categorical regulations and know how these standards should be applied. The
inspector also needs to be familiar with the guidance on how to derive alternate
limits contained in EPA's Guidance Manual for the Use of Production-Based
Pretreatment Standards and the Combined Wastestream Formula. Then the
inspector should review the information in the Ill's control mechanism application
or BMR to determine whether the correct standard is being applied. These
documents should also contain production data, although these data may also be
found in correspondence submitted by the IU. If production data are hot included
in the file, a deficiency should be noted.
C.5. Calculation and application of CWF or FWA
ISSUE; The CA is allowed to calculate and apply an alternate limit based on the
Combined Wastestream Formula (CWF) or the Flow Weighted Average (FWA)
formula.
WHERE TO LOOK: Control mechanism, fact sheet, control mechanism application
form, process and flow diagrams, and ID site visit.
Note: The CWF is used where a regulated process wastestream is mixed prior to
treatment with wastestreams other than those generated by the regulated
process [some combination of regulated, unregulated and/or dilute (e.g.,
sanitary)]. See Guidance Manual for the Use of Production-Based Pretreatment
anc/ t^e Combined Wastestream Formula [September, 1985].
The FWA applies where one or more categorical wastestreams mix with a
nonregulated or dilute wastestream after treatment but prior to sampling. Where
the CA has used the CWF instead of the FWA and this provides a more stringent
limit than the FWA would have, then the CA can continue to use the CWF. [See
5 1 Federal Register 2 1454.]
HOW TO EVALUATE: Again, the inspector should be familiar with the guidance
on how to use the CWF and FWA formula contained in EPA's Guidance Manual
for the Use of Production-Based Standards and the Combined Wastestream
Formula. If the user is subject to categorical standards, the inspector must
consider whether the standards need to be adjusted using the CWF or FWA
formula. This may be determined by reviewing the sample location described in
the control mechanisms, sampling records, and any wastewater flow schematics
or other information that identifies the types of wastestreams present at the
sample location. A site visit to the IU may be required to determine whether use
of the CWF or FWA is necessary.
Where use of the CWF or FWA results in an alternate limit that is below detection
level, that limit may not be applied and adjustment of the standard is not
appropriate. Instead the CA needs to require the IU to reduce, eliminate, or
separate the dilute wastestreams introduced prior to the sampling point or identify
another sampling point prior to the combined wastestreams.
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SECTION I
The inspector should find the standards in the control mechanism. If there is a
fact sheet, it should contain the calculations used to adjust the standard. A
deficiency should be noted if the inspector identifies that the CWF or FWA should
have been used and was not or if the CWF/FWA was incorrectly applied.
C.6. Application of most stringent limit
ISSUE: The CA is required to compare all calculated limits ([categorical, CWF,
FWA, and local limits) and apply the most stringent for each regulated
constituent.
WHERE TO LOOK: CA's ordinance, approved program's local limits, categorical
regulations, and control mechanism.
HOW TO EVALUATE: The control mechanism should include all applicable
effluent limitations. The CA's ordinance will usually contain the local limits. If
the ordinance does not contain the limits, the approved program should contain
the local limits or procedures for allocating the local limits. The appropriate
categorical standards are found in EPA's regulations. Title 40, Chapter I,
Subchapter N, Effluent Guidelines and Standards, 40 CFR Parts 405-471. The
CA may have a copy of these volumes of the Code of Federal Regulations or may
have a copy of the particular Federal Register containing the appropriate
standards.
For Categorical Industrial Users (ClUs), the CA can apply all limits (any applicable
categorical standards and local limits) or the most stringent limits. The procedure
for determining which limit (the categorical or the local limit] is more stringent
may not be a straightforward comparison of the two numerical values.
Categorical standards are applied at the end of the regulated process(es), while
local limits may have been developed to be applied to the total wastewater
discharge from the IU. The presence of dilution wastestrearns will also affect the
numerical value of the categorical standard (an alternate standard has to be
calculated). The CA may have forgotten to evaluate the monthly average
categorical standards.
The inspector may be able to identify obvious errors in application of the most
stringent limit. However, some errors may not be readily apparent. If the CA has
not clearly documented how it arrived at its determination of the most stringent
limit, the inspector may have to conduct independent calculations for one or two
pollutants to ascertain that the correct limits have been applied.
Once the appropriate standards for the user have been identified, the inspector
must review the control mechanism to verify that the correct standards have
been applied. If the correct limits are not included in the control mechanism, a
deficiency should be noted.
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SECTION I
D. CA Compliance Monitoring
Sampling
D.1. Sampling (once a year)
ISSUE: The CA is required to sample each SIU discharge point at least once per
year to verify compliance independent of self-monitoring data supplied by the IU.
WHERE TO LOOK: CA sampling records, laboratory (in-house or outside contract
lab) analytical reports, and chain-of-custody forms.
HOW TO EVALUATE: The inspector should find documentation of CA sampling
events on CA or contract lab analysis data forms, field sampling forms or log
books, and chain-of-custody forms. In some cases, this information may be filed
separately from other pretreatment data. Sampling records and chain-of-custody
forms are frequently kept in the lab. All data should be available to the inspector.
The CA may keep current data on a computer. The inspector should examine all
CA compliance sampling data in the lU's file. If sampling data do not exist, a
deficiency should be noted
D.2. Sampling at frequency specified in approved program
ISSUE: The CA is required to sample each IU discharge point to verify
compliance independent of self-monitoring data supplied by the IU. The CA is
required to conduct this sampling at the frequency specified in the approved
program (or in any modification to the approved program).
WHERE TO LOOK: CA sampling records, laboratory (in-house or outside contract
lab) analytical reports, chain-of-custody forms, interview, and approved program.
HOW TO EVALUATE: The inspector must be aware of the requirements in the
approved program. Where the program establishes a sampling scheme with
varying frequencies based on specific criteria, the inspector will need to determine
where the IU fits in this scheme. To do so, he/she may need to discuss the IU
with pretreatment staff to determine the required sampling frequency^ He/she
should then determine the actual number of times the CA sampled the IU. If the
CA sampled less frequently than required in the approved program, this is a
deficiency. Where the approved program does not specify sampling frequencies,
the CA still must sample at least once a year pursuant to the regulatory
requirement.
D.3. Documentation of sampling activities
ISSUE: The CA is required to conduct sampling activities with sufficient care to
produce evidence admissible in enforcement proceedings. Appropriate sampling
(grab vs. composite) should have been used and the sampling conducted at
proper locations and times (during representative process/discharge). Since the
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SIU is required by 40 CFR 403.12(g) to conduct all monitoring in accordance with
40 CFR Part 136, the CA should perform analyses according to 40 CFR Part 136
procedures.
WHERE TO LOOK: CA analytical reports, field sampling forms or log books,
chain-of-custody forms, and Quality Assurance/Quality Control (QA/QC)
protocols.
HOW TO EVALUATE: The inspector should review analytical results and chain-
of-custody forms for requisite documentation of the sampling event. The
inspector should also look for documentation of QA/QC protocols. This may be
kept in the CA's lab. If a contract lab is used, this information should be
furnished to the CA. Documentation should at least include: sample date and
time, location, sampling method/type, sampler's name, sample preservation
techniques, sample characteristics, dates of analyses, name of analyst, analytical
technique/method (40 CFR Part 136), and analytical results. Where production-
based or mass limits have been applied, sampling will need to include wastewater
flow data at time of sampling or the sampling equipment calibrated to collect a
flow-proportional sample. All QC sample data should be reported along with the
standard sampling results. Where documentation is incomplete or missing, a
deficiency should be noted.
D.4. Analysis of results for all parameters
ISSUE: The CA is required to obtain analytical results for all regulated
parameters.
WHERE TO LOOK: Categorical regulations, control mechanism, CA analytical
reports, and Toxic Organic Management Plan (TOMP).
HOW TO EVALUATE: Categorical standards (PSES, PSNS) specify regulated
pollutants and discharge limits for each specific process. The control mechanism
should require self-monitoring for all these parameters as well as those local limits
potentially present in the lU's discharge and any other pollutants of concern for
that IU. Categorical industries are subject to categorical standards even where
the CA has failed to incorporate these into a control mechanism.
The CA's analytical data will show the pollutants analyzed. The analytical results
must include data on aH regulated parameters, even if such pollutants are not
expected to be present in the wastestream. Example: A metal finisher doing
phosphatizing of steel is still required to be sampled for silver, nickel, etc., even
though silver, nickel, etc. are not used in the process. In this case, the analytical
data record would indicate "not detected or below detectable" for each of the
constituents not present in the discharge. The inspector should note any
regulated pollutants that the CA has .not sampled and analyzed and a deficiency
should be noted.
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The inspector should determine whether the IU has an approved TOMP. (These
are sometimes kept in another location for emergency purposes.) The inspector
should look at the TOMP to verify its existence and approval. If the ID has an
approved TOMP, the inspector should ask the CA how frequently verification
sampling is done.
D.5. Appropriate analytical methods (40 CFR Part 136)
ISSUE: The SIU is required to use the methods defined under 40 CFR Part 136
when collecting and analyzing all samples obtained to determine compliance with
pretreatment standards. Since the CA's compliance monitoring serves to verify
compliance with the same standards and to check the validity of self-monitoring
data, the CA's monitoring should also be conducted in accordance with 40 CFR
Part 136.
WHERE TO LOOK: CA and IU analytical reports, chain-of-custody forms, and
QA/QC protocols.
Note: The 40 CFR Part 136 methods are those test procedures approved by EPA
for the analysis of pollutants under the Clean Water Act. There are other EPA
test methods approved for other regulatory programs. For example, both the
Office of Solid Waste and Office of Air have EPA approved test methods for
analysis of pollutants under the RCRA and the Clean Air Act. In some cases, the
CA may obtain permission to use an alternative analytical method if such method
is approved by the EPA Administrator. Such approval would be found in a formal
letter or report.
HOW TO EVALUATE: The laboratory's sampling analysis reports should include
the analytical methods used. QA/QC protocols and chain-of-custody forms may
also identify analytical methods used. The CA's documentation of the methods
used should list the specific methods and not just indicate "EPA approved
methods." While specific test procedures included in "Standard Methods for the
Examination of Water and Wastewater" are approved under 40 CFR Part 136 for
many parameters, not all the test procedures in "Standard Methods" are
approved. If a particular method(s) is identified, the inspector may have to review
40 CFR Part 136 to determine whether that method is approved. The inspector
should look for documentation that the lab (whether POTW or contract lab)
performs all pretreatment analyses according to methods listed in 40 CFR Part
136 or an alternate method approved by the EPA Administrator. If the
appropriate methods were not used, a deficiency should be noted.
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Inspection
D.6. Inspection (once a year)
ISSUE: The CA is required to inspect each IU at least once per year to verify
compliance independent of data supplied by the ID.
WHERE TO LOOK: Inspection report or form, activity log, or letter of inspection
findings.
HOW TO EVALUATE: The inspector should look for inspection reports, logs,
and/or daily activity reports for documentation of inspection events. If the
occurrence of the inspection is only noted in a log book (e.g., date, name of IU,
and IU representative), the inspector should note the folio wing deficiency
"inspection occurred but data was not collected and documented with sufficient
care to provide admissible evidence in an enforcement action". In some cases,
inspection reports may be maintained in a file separate from other pretreatment
activities. If the inspector is unable to locate any written documentation of an
inspection, a deficiency should be noted.
D.7. Inspection at frequency specified in approved program
ISSUE: The CA is required to inspect each SIU at the frequency required by the
approved program (or any modifications of the approved program) to verify
compliance with pretreatment standards and requirements independent of data
supplied by the IU.
WHERE TO LOOK: Inspection report or form, activity log, letter of inspection
findings, and interview.
HOW TO EVALUATE: The inspector must be aware of the inspection
requirements in the approved program. As with sampling events, the approved
program may specify an inspection scheme with variable frequencies. If this is
the case, the inspector will probably need to discuss the criteria applied to that IU
to determine the required inspection frequency. If inspections during the past
year occurred less frequently than required in the approved program, a deficiency
should be noted.
D.8. Documentation of inspection activities
ISSUE: The CA is required to conduct each SIU inspection with sufficient care to
produce evidence admissible in enforcement proceedings.
WHERE TO LOOK: Inspection report or form, activity log, or letter of inspection
findings.
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HOW TO EVALUATE: Documentation should at least include: inspection date
and time, inspector's name, ID representative(s) present at inspection', and all
observations or information obtained during the inspection. Observations could
include: description of manufacturing processes or services performed;
identification of sources, flow and types of wastewater discharges (regulated,
dilution flow, etc.); evaluation of pretreatment facilities (adequacy, capacity,
etc.); evaluation of IU sampling protocols, sampling equipment, sampling point
and analytical methods; evaluation of spill/slug potential and compliance with spill
prevention plan; evaluation of hazardous waste generation, storage areas and
handling procedures; evaluation of IU records, areas/processes inspected; and,
representative production activity during the inspection. All findings, deficiencies,
and any required actions relayed verbally or in writing to the IU should be
documented in the CA's report. Depending on the frequency of inspections
performed by the CA at each IU, not all inspection reports will be the same.
Some may be more detailed than others so all of the components listed above
may not be found in each report.
D.9. Evaluation of need for slug discharge control plan
ISSUE: The CA is required to evaluate each lU's need for a slug discharge control
plan at least once every two years.
WHERE TO LOOK: Inspection report or form, letter of inspection findings, activity
log, enforcement order, compliance schedule, and control mechanism.
Note: This may also be called an accidental discharge plan. However, to fulfill
the regulatory requirement, the plan must also address any potential
nonaccidental slug discharges.
HOW TO EVALUATE: The inspector should find documentation of this evaluation
in the CA's inspection reports or a letter to the IU of evaluation findings. The CA
may have required the IU to develop a slug discharge control plan via the control
mechanism, an enforcement order, a compliance schedule, a meeting or
correspondence. Where a slug control plan was required, it should also be in the
IU file. If the IU has an existing slug discharge control plan that was approved
more than two years prior to the PCI, the inspector should find documentation of
a reevaluation of the facility and the effectiveness of the existing plan.
A slug discharge control evaluation should at least include investigation of:
production and/or service areas, chemical storage, material handling and transfer
areas, loading and unloading operations, shut down/cleaning operations, plant site
runoff areas, containment structures, TOMPs, and emergency response
procedures. The inspector should look for evidence that the CA inspected all
areas of the IU facility where there are floor drains, noting potential for spills
from: open chemical drums, process tanks, chemical storage, pretreatment
system hydraulic overload, sludge spillage, leakage from segregated lines (e.g.,
for the removal of toxic organics), nonrountine batch discharges, pretreatment
system failure, and bypasses.
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SECTION I
If no evidence exists that the IU was evaluated (or re-evaluated at least once
every two years) a deficiency should be noted. If a plan was required and never
developed, a deficiency should be noted.
E. CA Enforcement Activities
In the event of IU noncompliance, the CA must take action to bring an IU back
into compliance within the shortest time frame possible. This portion of the file
review evaluates whether the CA has reviewed all monitoring data to determine
IU compliance, is aware of the compliance status of the industry, and is following
its approved Enforcement Response Plan (ERP) procedures for responding to IU
violations.
E.I. Identification of violations
a. Discharge violations
b. Monitoring/reporting violations
c. Compliance schedule violations
ISSUE: The CA is required to investigate all instances of noncompliance with
pretreatment standards and requirements.
WHERE TO LOOK: Control mechanism, CA and IU sampling data, enforcement
orders, and compliance schedules.
HOW TO EVALUATE: The CA needs to identify noncompliance by comparing
sampling data with applicable limits and investigate any violations. Investigation
further involves requiring the IU to explain the violation. SlUs are required to
report any noncompliance identified in self-monitoring data within 24 hours of
becoming aware of the noncompliance.
The inspector should review the monitoring data for violations and then determine
whether the CA followed up on each violation with some form of enforcement
action. Look for documentation of the 24-hour notification and the repeat
sampling results. The inspector should also review IU reports submitted and
compare them to reports required under the control mechanism, any enforcement
order and/or compliance schedule. ,
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SECTION I
E.2. Calculation of SNC
ISSUE: The CA is required to calculate SNC in order to determine which
industries to publish at least annually in the largest local daily newspaper. The
CA must also report those IDs in SNC in its pretreatment program performance
reports to the State or EPA. SNC should be determined on a rolling quarter basis.
WHERE TO LOOK: CA and IU analytical reports, CA enforcement file,1
correspondence, and pretreatment program performance report.
Note: CAs should be evaluating SNC based on the procedures set forth in EPA's
September 9, 1991, memorandum on the Application and Use of the Regulatory
Definition of Significant Noncompliance for Industrial Users. According to these
procedures, the CAs should evaluate IU compliance status at the end of fixed
quarters established by the CA to correspond to its "pretreatment year. " At the
end of each quarter, all data from the previous 6-month time period is to be used
in the calculation of SNC violations. Under this system, each IU is evaluated for
SNC four times during the year and the total evaluation period covers 15 months
(i.e., beginning with the last quarter of the previous pretreatment year through
the end of the current year).
HOW TO EVALUATE: Evidence of SNC evaluation should be found in the CA's
enforcement file, the pretreatment program performance report submitted to EPA
or the State as well as in the CA and IU sampling reports. The inspector should
look for any SNC violations (such as violations that meet the criteria for chronic
or Technical Review Criteria [TRC], violations causing or contributing to
interference or pass through; violations requiring the CA's emergency response,
failure to meet compliance schedule deadlines by more than 90 days, failure to
submit required reports within 30 days of due dates, or any other violations
deemed SNC by the CA). If the inspector detects any SNC violations he/she
should determine if the CA has identified these violations as SNC, taken
appropriate enforcement, and published the IU in the newspaper. The inspector
should note any deficiencies in the CA's SNC determination.
E.3. Adherence to approved ERP
ISSUE: The CA is required to implement its approved Enforcement Response Plan
(ERP).
WHERE TO LOOK: CA enforcement file, inspection reports, CA and IU sampling
data, control mechanism, enforcement orders, compliance schedules, !and
correspondence.
HOW TO EVALUATE: The inspector needs to be familiar with the CA's ERP.
He/she needs to review the IU file for enforcement actions [e.g., reports. Notices
of Violation (NOVs), Administrative Orders (AOs), Consent Orders] taken by the
CA. Documentation of enforcement actions may be contained in correspondence
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SECTION I
or documentation of informal conversations between the CA and the user, or
official enforcement actions such as NOVs or AOs.
Implementation of the approved ERP involves timely and appropriate enforcement
and escalation of enforcement action where violations persist. The CA should
have noted and responded to any instance of noncompliance with local limits
and/or categorical pretreatment standards. At minimum, for minor violations the
CA should have notified the IU of the violation through a phone call, meeting, or
NOV.
The inspector should evaluate whether the enforcement actions taken were in
accordance with the time frames and responses established in the CA's approved
ERP. Where they were not, the inspector should document the occurrence and
note a deficiency.
E.4. Escalation of enforcement
ISSUE: The CA is expected to escalate enforcement for persistent violations.
; WHERE TO LOOK: CA enforcement file and enforcement orders (e.g., AOs,
Consent Orders, judicial actions, etc.).
HOW TO EVALUATE: The inspector should look at all enforcement actions (e.g.,
reports, NOVs, AOs, Consent Orders, etc.) taken against an IU for each type of
violation. The CA is expected to bring noncompliant users back into compliance
by timely and appropriate enforcement. This requires escalation of enforcement
activity for persistent violations per the CA's ERP. The inspector should look for
patterns of increasingly severe enforcement actions (e.g., NOVs followed by AOs)
where the past enforcement actions have not resulted in the IU achieving
consistent compliance. The inspector should note dates of the enforcement
actions and IU responses. He/she should evaluate where the past enforcement
actions have not resulted in the IU achieving consistent compliance and whether
escalation has proceeded in a timely manner. Even if the CA is following its ERP
procedures, if the enforcement actions are not effective in achieving compliance,
the inspector should make note of this problem. The CA's ERP procedures may
need to be modified.
E.5. Publication for SNC
ISSUE: The CA is required to annually publish a list of lUs found to be in SNC in
the largest local daily newspaper.
WHERE TO LOOK: Copy/clipping of notice and CA enforcement file.
HOW TO EVALUATE: The IU file or a central enforcement file should contain a
copy or clipping of the notice placed in the local newspaper. The CA may keep
this public notice in a separate file. If the IU has been in SNC at any time during
the year to which the publication pertains, then the IU must be included in the
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SECTION I
published list. Even those IDs that returned to compliance and are in compliance
at the time of publication must be included in the published list. lUs that are on
compliance schedules (but have had or continue to have SNC violations of
standards or requirements) must be published. The publication may take the form
of a legal notice; however, it may be more effective in the form of an article or
advertisement. Where the inspector identifies an IU in SNC that was not
published, a deficiency should be noted.
F. IU Compliance Status
The inspector should determine the compliance status of the IU based on his/her
independent determination and check this determination against whatever
information the CA has been reporting in its pretreatment program performance
reports to EPA or the State.
Self-monitoring and Reporting
F.1. Sampling at frequency specified in control mechanism/regulation
ISSUE: The SIU is required to sample at the frequency specified in its individual
control mechanism but not less than once per six months.
WHERE TO LOOK: Control mechanism, enforcement orders (e.g., AO, consent
decree, etc.), CA's ordinance, or approved program.
HOW TO EVALUATE: The sampling frequency may be contained in the control
mechanism, or in an enforcement document (such as an NOV, AO, consent
decree, etc.) issued to the IU. The frequency may also be established in the CA's
ordinance or approved program. The SIU must sample for all pollutants applied in
its control mechanism, including aJi parameters regulated under an applicable
categorical pretreatment standard, at least every six months. Sampling must be
appropriate (grab vs. composite) and at proper locations and times (during
representative process/discharge). The SIU must certify continuing compliance
with an approved TOMP as part of the self-monitoring (if appropriate).
F.2. Analysis of all required pollutants
ISSUE: SlUs are required to obtain analytical results for all regulated parameters.
WHERE TO LOOK: Categorical regulations, control mechanism, IU analytical
reports, and TOMP.
Note: Unless the specific categorical pretreatment regulation specifies otherwise,
ClUs must monitor for all regulated parameters. There is one exception: EPA
established a policy that allowed lUs subject to 40 CFR Part 413 or 433
(electroplating or metal finishing) to demonstrate compliance with the total toxic
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SECTION I
organics limit by sampling only for those organics reasonably expected to be
present in the wastestream. However, the lUs must sample for all the other
regulated parameters (cyanide, cadmium, etc.) even if these parameters are not
expected to be in the wastestream.
HOW TO EVALUATE: Categorical industries are subject to categorical standards
even where the CA has failed to incorporate these in the control mechanisms.
Therefore, analytical results must include data on aN regulated parameters, even if
such pollutants are not expected to be present in the wastestream. Example: A
metal finisher doing only zinc plating is still required to be sampled for silver,
nickel, etc., even though silver, nickel, etc. are not used in the process. In this
case, the analytical data record would indicate "not detected or below
detectable" for each of the constituents not present in the discharge.
F.3. Submission of BMR/90-Day Report
ISSUE: ClUs must submit a BMR within 180 days of the effective date of the
categorical regulation and 90-Day Compliance Reports within 90 days of the date
for final compliance with the applicable pretreatment standards (established in the
categorical regulations). In the case of new source ClUs, the BMRs must be
submitted at least 90 days prior to discharge and the 90-Day Compliance Reports
must be submitted within 90 days following commencement of discharge.
WHERE TO LOOK: BMR, control mechanism application form, 90-Day
Compliance Report(s), and periodic IU compliance reports.
Note: For most existing sources, the BMR and 90-Day Compliance Report
deadline is passed. Each new source discharger must fulfill these requirements.
Categorical dischargers that currently discharge directly to a receiving stream but
plan to discharge to the POTW would be considered an existing source, but
would still be required to submit BMR and 90-Day Compliance Reports.
HOW TO EVALUATE: The inspector should verify that the reports were
submitted on time and include results for all parameters required to be sampled
and contain all the information required by 40 CFR 403.12. The control
mechanism application may serve as the BMR if it contains all the elements listed
in 40 CFR 403.12(b). In some cases, the dates for the submission of these
reports may have passed prior to implementation of the local program and the
reports may not be in the files. In this event, the inspector should verify that
equivalent data is in the files of ClUs.
F.4. Periodic self-monitoring reports
ISSUE: I Us are required to submit self-monitoring reports at a frequency specified
in their individual control mechanism, but not less than once per six months.
WHERE TO LOOK: IU self-monitoring reports.
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SECTION I
HOW TO EVALUATE: The ID'S self-monitoring report should contain sampling
documentation. Documentation should at least include: sample date and time,
location, sampling method/type, sampler's name, sample preservation techniques,
dates of analyses, name of analyst, analytical technique/method (40 CFR 136),
and analytical results. Self-monitoring reports should also include certification of
the ID'S compliance with any approved TOMP.
F.5. Reporting all required pollutants
ISSUE: lUs are required to report analytical results for all regulated parameters.
WHERE TO LOOK: Control mechanism, CA's ordinance, categorical regulations,
and IU analytical reports.
HOW TO EVALUATE: Categorical industries are subject to categorical standards
even where the CA has failed to incorporate these into the lU's control
mechanism. Therefore, analytical results must include data on all regulated
parameters, even if such pollutants are not expected to be present in the
wastestream. Where pollutants are not present, the analytical data record would
indicate "not detected or below detectable" for each of the these constituents.
F.6. Signatory/certification of reports
ISSUE: SlUs are required to sign all self-monitoring reports and provide a
certification statement [as found in 40 CFR 403.6(a)(2)(ii)] that the information is
accurate and complete.
WHERE TO LOOK: IU self-monitoring reports, BMR, and 90-Day Compliance
Reports.
HOW TO EVALUATE: The inspector should verify that these reports are signed
and certified by the responsible corporate officer, general partner or proprietor
[see 40 CFR 403.12(1)].
F.7. Submission of compliance schedule progress reports by required dates
ISSUE: lUs on compliance schedules are required to submit compliance schedule
progress reports on meeting milestone requirements by the reporting date(s)
specified in the compliance schedule.
WHERE TO LOOK: Compliance schedule, control mechanism, and enforcement
orders.
HOW TO EVALUATE: The compliance schedule may be contained in the control
mechanism, an AO, or other enforcement document. A compliance schedule may
also have been submitted by the IU in its BMR or 90-Day Compliance Report.
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SECTION f
The inspector should verify that the reports were received by the CA on time and
included all required information. If the reports are late or incomplete a deficiency
should be noted.
F.8. Notification within 24 hours of becoming aware of violations
• Discharge violation
• Slug load
• Accidental spill
ISSUE: IDs are required to notify the CA of any discharge violation identified in
self-monitoring within 24 hours of becoming aware of the violation. IDs are also
required to provide immediate notice to the CA of any discharge with the
potential to cause harm to the POTW (i.e., slug loads/accidental spills).
WHERE TO LOOK: ID self-monitoring reports, letter, or phone call
documentation.
HOW TO EVALUATE: The inspector should verify that the CA was notified of
discharge violations within 24 hours. In the case of slug loads/accidental spills,
the inspector should verify that notice was given as soon as the IU could
reasonably be expected to have been aware of the slug load or spill.
F.9. Resampling/reporting within 30 days of knowledge of violation
ISSUE: lUs are required to resample and report to the CA within 30 days of
becoming aware of a discharge violation. If the repeat sampling performed
indicates a violation the IU must repeat the sampling and analysis; this cycle
continues until the sampling indicates compliance.
WHERE TO LOOK: IU analytical report.
Note: The IU does not have to resample if the CA performs sampling at the IU at
least once per month or has sampled the IU between the time of the initial sample
and the lU's receipt of the sample results. The IU need only resample for the
pollutant(s) found to be in violation. For example, if the IU was sampling for six
different metals and had a copper violation, the IU would resample for copper, not
all six metals.
HOW TO EVALUATE: The inspector should verify that the IU resampled and
reported the data within 30 days of becoming aware of the discharge violation.
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F.10. Notification of hazardous waste discharge
ISSUE: All I Us are required to notify the CA in advance of any discharges of
listed or characteristic hazardous waste to the POTW.
WHERE TO LOOK; Letter or report.
HOW TO EVALUATE: This requirement is tied to the 40 CFR 403.12(j) and (p)
requirements that lUs submit to the CA, EPA, and the State information
concerning wastes discharged to the POTW that, if disposed of differently, would
be considered a listed or characteristic hazardous waste. The information
submitted to the CA must include the name of the waste, the hazardous waste
number and types of discharge (batch, continuous, or other). Note that this is a
one time reporting requirement unless the lU's discharge changes. Also, this
requirement does hot apply to pollutants which are already reported under a self-
monitoring requirement.
F.11. Submission/implementation of slug discharge control plan
ISSUE: lUs required to submit and implement a slug discharge control plan must
do so in accordance with CA specifications.
WHERE TO LOOK: Control mechanism, enforcement order (e.g., compliance
schedule, AO, etc.), or letter.
HOW TO EVALUATE: The requirement to submit and implement such a plan may
be contained in the lU's control mechanism or an AO or other enforcement
document. The plan itself should be in the lU's file and may be variously titled:
spill prevention plan or accidental discharge control plan. All IU plans must at
least contain: description of actual and potential slug/batch discharges;
description of all stored chemicals; procedures for notifying of all slugs;
preventative measures, containment structures or equipment; clean-up
procedures/equipment; and any special measures for controlling toxic organic
slugs [40 CFR 403.8(f)(2)(v)].
F.12. Notification of significant changes
ISSUE: lUs are required to promptly notify the CA in advance of any substantial
changes in the volume or character of pollutants in their discharge. lUs with
alternative categorical pretreatment standards (through use of the CWF or FWA)
are required to immediately report any material or significant change in the flow
values used in the calculations to derive the alternative limits. lUs operating
under a control mechanism incorporating equivalent mass or concentration limits
calculated from a production-based standard must notify the CA within 2
business days after the IU has a reasonable basis to know that the production
level will significantly change within the next calendar month.
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SECTION I
WHERE TO LOOK: CA and IU sampling data, IU self-monitoring report, letter,
phone call documentation, and meeting notes.
HOW TO EVALUATE: These notifications are usually in the form of letters and
may be in the correspondence file. In some cases, these notifications may be by
telephone and should be documented by the CA in its telephone log or by
memoranda to the file. Change in products, processes, raw/base materials,
discharge points, discharge time (batch), treatment, etc. could affect the
production flows, pollutants and pollutant concentrations or mass in the ID'S
discharge. The inspector should look for these types of changes as well and
evaluate whether these changes had an affect upon production, flows, and the
volume or character of pollutants. Changes are substantial, significant or material
changes if the changes would result in the application or derivation of different
numerical limits or additional regulated pollutants.
Discharge
F.13. Noncompliance with discharge limits (but not SNC)
ISSUE: lUs are required to comply with all applicable discharge limits.
WHERE TO LOOK: Control mechanism, CA's ordinance, categorical regulations,
and analytical data.
HOW TO EVALUATE: The applicable limits would be found in the control
mechanism, the CA's ordinance and applicable categorical pretreatment
regulations (PSES, PSNS). The sampling data (both the CA's and lU's) should be
found in the file or in separate sampling files. The inspector should compare the
CA and IU sampling data against the applicable limits, identify all violations, and
determine if the violations meet the SNC criteria. (This documentation should be
made after the inspector has determined that the discharge limits are
appropriate.) If these violations do not meet the SNC criteria, the inspector
should note that the IU is or has been in noncompliance (but not in SNC).
F.14. SNC
a. Chronic violations
b. TRC
c. Pass through or interference
• Spill or slug load
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SECTION I
d. Other discharge violations (specify)
ISSUE: lUs are in SNC with discharge standards if the discharge meets any of
the conditions identified in a-d above.
WHERE TO LOOK: Control mechanism, CA's ordinance, categorical regulations,
and analytical data.
HOW TO EVALUATE: SNC is calculated on a rolling quarter basis; at the end of
each quarter, all data available from the previous six-month time period are used
to calculate Chronic and TRC SNC. Any discharge that causes pass through or
interference at the treatment works is SNC. An "other discharge violation" would
include any that caused the CA to exercise its emergency powers or that the CA
deemed as SNC. The inspector should compare CA and IU sampling data and
note any SNC violations. He/she should indicate on the Checklist if the ID was in
SNC at any time during the four most recent full quarters evaluated.
Reporting
F.15. Noncompliance with reporting requirements (but not SNC)
ISSUE: lUs are required to comply with all applicable reporting requirements.
WHERE TO LOOK: Control mechanism and enforcement orders (e.g., NOVs,
AOs, etc.).
HOW TO EVALUATE: In addition to reports required by the control mechanism,
enforcement orders may also contain reporting requirements. Any report
submitted after the due date is considered noncompliance. Any report submitted
lacking required data is also considered noncompliance.
F.16. SNC with reporting requirements
ISSUE: lUs are in SNC with reporting requirements if reports are incomplete or
not received by CA within 30 days of their due date.
WHERE TO LOOK: Control mechanism and enforcement orders (e.g., NOVs,
AOs, etc.).
HOW TO EVALUATE: Control mechanisms and enforcement orders may contain
reporting requirements. The inspector needs to verify that the reports were
submitted on time. If reports were more than 30 days late or were lacking
requisite data more than 30 days beyond the due date, the inspector should verify
that the IU was published or will be published for SNC.
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SECTION I!
SECTION II: SUPPLEMENTAL DATA REVIEW/INTERVIEW
Each of the questions in Section II of the Checklist is listed below along with an
explanation of the issue or intent of the question. Guidance is provided on how the inspector
can evaluate the CA's compliance with implementation requirements and on what constitutes a
deficiency. The suggestions made in the "Where to Look" are possible places where the
inspector may find the documentation or data but the inspector need not look in all the
suggested places to ascertain the information. The majority of the data or answers to the
questions can be supplied by the CA through the interview process (but documentation should
be provided for any verbal answers and verified by reviewing the data or information contained
in the files or pretreatment program performance reports).
A. CA Pretreatment Program Modification
A.1. Did the CA make substantial changes to the pretreatment program that
were not approved by the Approval Authority (e.g., definitions, limits,
etc.)?
A.2. Is the CA in the process of modifying any approved pretreatment program
component (including legal authority, local limits, DSS requirements, etc.)?
ISSUE: The CA is required to notify the Approval Authority of any substantial
changes it intends to make in its pretreatment program. Substantial changes
should not be made without approval by the Approval Authority.
WHERE TO LOOK: Pretreatment program performance report, CA's ordinance,
interjurisdictional agreements, available resources, and IU files.
HOW TO EVALUATE: During the interview, the inspector should elicit
information about any modifications to the pretreatment program. If the CA
personnel cannot readily identify changes, the inspector may want to specifically
inquire about the following:
• New service areas
• New/revised interjurisdictional agreements
• New SlUs
• SlUs dropped from program
• Changes to ordinances or regulations
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SECTION II
• Changes to the control mechanisms (e.g., permits) issued to SlUs including
changes in content, format, or standard conditions
• Changes in inspection and sampling frequencies and/or priorities
• Changes to local limits (modifications of the numerical values or the addition
or deletion of pollutants)
• Revisions to ERP.
If changes have occurred, the inspector should document what the changes are
and the reasons for the modifications. Use Section II.A. Question 1 of the
Checklist to record any modification that the CA has made that has not been
approved and use Section II.A. Question 2 to record any proposed modifications
the CA is considering. Obtain a copy of all completed program modifications that
have not been submitted to the Approval Authority for approval.
B. IU Characterization
B.I. How and when does the CA update its IWS to identify new Ills or
changes in wastewater discharges at existing (Us?
ISSUE: The CA is required by 40 CFR 403.12(i)(1) to provide EPA or the State
with an updated list of lUs or a list of deletions or additions keyed to a previously
submitted list. This list must be submitted to EPA or the State at least annually
as part of the CA's pretreatment program performance report.
WHERE TO LOOK: Pretreatment program performance report, inspection reports,
control mechanisms, correspondence, and current list of lUs.
HOW TO EVALUATE: The inspector should record any deficiencies with respect
to the following issues:
• Is the CA updating its Industrial Waste Survey (IWS) in accordance with its
approved pretreatment program?
• Is the CA identifying all new users?
• Are there lUs the CA has overlooked or miscategorized?
• Is the definition of SIU the same as stated in the CA's approved program?
• What types of facilities does the CA regulate but does not consider as SlUs?
Although the regulations require an annual update (and that is what most
approved programs specify), most CAs have found that it is more efficient to
update the IWS information on a continuing basis. While this may be the ideal
approach, CAs tend to concentrate on updating their existing lUs and miss many
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SECTION I!
new lUs discharging to the system. Information on existing IDs is generally
updated through inspections, permit applications, and notices of proposed
discharge changes.
The inspector should look for information regarding new IDs and document how
the CA goes about identifying new lUs. Usual methods employed are:
notification by other municipal departments and/or contributing municipalities;
periodic review of phone books. Chamber of Commerce listings, etc.; and drive-
bys through industrial parks or other industrialized areas. Drive-bys are
particularly helpful since identification of new IDs in existing leased spaced can be
especially difficult.
The inspector should review the phone book yellow pages and drive through
industrial/commercial areas to identify any industries not on the CA's list. Inquiry
should be made regarding these facilities and documentation obtained to indicate
why they are not included in the program. ;
It is important for the inspector to identify what criteria the CA is using to
determine whether an IU is significant. It is not unusual -for the ordinance and/or
program submission to have one definition of SID and for the pretreatment staff
to be using another definition. Any alternate definitions should be recorded by
the inspector. The CA must regulate all SlUs [as defined in 40 CFR 403.3(t)].
Frequently, identification of new IDs or changes to existing lUs in contributing
jurisdictions is weak. The inspector should review a map of the CA's service area
and inquire how the CA identifies new lUs and changes in existing lUs that are
located in contributing municipalities. The CA should have procedures for IWS
update in these areas. They might include: authority to conduct its own IWS
update in those areas via an interjurisdictional agreement; notification by the
contributing municipality of new lUs and changes in existing lUs, joint inspections
with the contributing municipality. The inspector should document any
deficiencies.
B.2. How many Ills are currently identified by the CA as: a. SlUs (as defined
by the CA), including ClUs and noncategorical SlUs; b. other regulated
noncategorical SIUs; and c. what is the total number for a. + b.?
ISSUE: The CA is responsible for categorizing its lUs as to whether they are
subject to categorical pretreatment standards and if not, whether they are
considered an SIU.
WHERE TO LOOK: POTW pretreatment program performance report, inspection
reports, control mechanisms, correspondence, and current list of lUs.
HOW TO EVALUATE: The inspector should examine the current list of I Us
regulated under the program and ask if the list is correct. If so, a copy of the list
can be attached and the numbers entered on the Checklist. The inspector should
verify that the CA is correctly identifying SIUs and ClUs by discussing selected
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SECTION II
IDs with the pretreatment staff and verify any questionable information by
reviewing the ID files.
C. Control Mechanism Evaluation
C.1. a. How many SlUs (as defined by the CA) are required to be covered by
an individual control mechanism?
b. How many SlUs are not covered by an existing, unexpired permit or
other individual control mechanism?
ISSUE: Under 40 CFR 403.8(f)(1)(iii), the CA is required to issue individual
control mechanisms to all SlUs.
WHERE TO LOOK: CA permit tracking system, individual control mechanisms,
lists of lUs, and pretreatment program performance report.
HOW TO EVALUATE: The inspector should inquire as to the number of control
mechanisms issued to SlUs and compare this number to the number of SlUs to
determine if control mechanisms have been issued to all SlUs. It should be noted
that the Federal regulations require the issuance of individual control mechanisms
(e.g., permit, order, etc.). It should also be noted that the responses to these
questions are based on the CA definition of SIU, not the Federal definition.
C.2. How many control mechanisms were not issued within 180 days of the
expiration date of the previous control mechanisms?
ISSUE: A CA is considered to be in RNC if it fails to issue, reissue, or ratify
control mechanisms for at least 90% of its SlUs within 180 days of the expiration
date of the previous control mechanisms.
WHERE TO LOOK: CA permit tracking system, individual control mechanisms,
lists of lUs, and pretreatment program performance report.
HOW TO EVALUATE: The inspector should inquire as to the CA's control
mechanism reissuance procedures, including the amount of time that lapses
between control mechanism expiration and reissuance. In some instances the
expiration date on the control mechanism may have passed and a new control
mechanism has not been reissued, but the CA has issued a letter to the SIU
stating that the control mechanism is in force until a new control mechanism is
issued. In other instances the control mechanism's expiration date may have
been exceeded but the control mechanism contains a clause stating that the
control mechanism will continue to be in force until a new control mechanism is
issued. These instances would still be considered as deficiencies if the control
mechanism was not reissued within 180 days. There may be instances where an
administrative extension could be granted (e.g., awaiting approval of revised local
limits) to extend this 180 days period. However, lack of adequate CA staff and
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SECTION II
resources or simply a failure to issue/reissue permits in a timely manner are not
acceptable instances for granting an extension. It should be noted that the CA
must have the appropriate legal authority to extend a control mechanism.
D. Application of Pretreatment Standards and Requirements
D.1. a. How many SlUs were not evaluated for the need to develop slug
discharge control plans in the last 2 years?
b. List the SlUs below or attach additional sheets as needed.
ISSUE: The CA is required to evaluate each SIU to determine the need for a slug
discharge control plan for the facility once every 2 years. This evaluation should
include an inspection of the IU facility to identify the potential for accidental spills
and other slug discharges (e.g., nonroutine batch discharges) to the sewer.
WHERE TO LOOK: Inspection reports, control mechanisms, orders,
correspondence, or phone call documentation.
HOW TO EVALUATE: If there is no evidence that the CA has conducted these
evaluations, a deficiency should be noted. The inspector should obtain a list of
those lUs that the CA has not evaluated.
D.2. Did the CA apply all applicable categorical standards and local limits to (Us
whose wastes are hauled to the POTW?
ISSUE: All industries whose wastes are discharged to a POTW, regardless of the
manner in which it is discharged, are considered lUs and are subject to
pretreatment standards and requirements. The CA is required to apply all
applicable standards to hauled industrial wastes. ;
WHERE TO LOOK: Control mechanism, hauled waste manifest forms, and
sampling data on hauled wastes.
HOW TO EVALUATE: The inspector should ask whether the POTW receives any
hauled industrial wastes. If the answer is yes, the inspector should ask the CA to
describe its mechanism for controlling such wastes. Any permits issued to the
hauler or the IU should be evaluated for the correct application of pretreatment
standards, as discussed under Section I.C above. If the CA has no mechanism
for regulating this waste, it is a deficiency.
If the CA states that the POTW does not accept hauled industrial wastes, only
sanitary (and, perhaps, grease trap) wastes, the inspector should ask how the CA
ensures that no industrial wastes are discharged. The CA should have oversight
procedures such as random sampling and analysis for toxics (e.g. chemical
specific analyses or a some type of biological inhibition or toxicity test) of the
hauled wastes. It should also employ a manifest system which it checks for
29
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SECTION II
validity at least on a random basis. Documentation from these procedures should
also be reviewed.
D.3. Did any lUs notify the CA of a hazardous waste discharge?
ISSUE: All IUs, whether or not they have been issued individual control
mechanisms, are required to notify the CA, EPA, and the State of any wastes
which would be considered hazardous (listed or characteristic) if discharged other
than to the municipal sewer. All IUs are subject to this Federal requirement
regardless of notification by the CA. However, the CA should notify IUs of this
requirement.
WHERE TO LOOK: CA notification to IU, control mechanism, correspondence, or
self-monitoring reports.
Note: This notification must be in writing and be submitted within 180 days from
the effective date of the rule which was August 23, 1990. IUs which commence
discharging after the effective date of the rule must provide this notification no
later than 180 days after the discharge of the listed or characteristic hazardous
waste. This notification does not apply to pollutants already reported by the IU
under the self-monitoring requirements of 40 CFR 403.12. However,
notifications of changed discharges (including the listed or characteristic
hazardous wastes) must be submitted under 40 CFR 403.12(j).
HOW TO EVALUATE: The inspector should ask whether the CA has provided
notice to IUs of this requirement and, if so, how. Documentation of this notice
should be reviewed by the inspector. He/she should also ask which IUs have
notified the CA of a hazardous waste discharge.
E. Compliance Monitoring
E.1. Identify required and actual frequency of inspections, sampling (by CA),
self-monitoring, and reporting of ClUs and other SlUs and explain any
differences noted in the required and actual frequencies.
ISSUE; Under 40 CFR 403.8(f)(2)(v), the CA is required to inspect and sample all
SlUs at least once a year. According to 40 CFR 403.12(e), ClUs are required to
self-monitor and submit reports twice per year and 40 CFR 403.12(h) requires the
same self-monitoring and reporting from noncategorical SlUs. Additionally, the
CA's approved pretreatment program or NPDES permit may specify required
sampling, inspection, self-monitoring or reporting requirements.
WHERE TO LOOK: CA approved program, NPDES permit, 40 CFR 403.12, CA
inspection and monitoring plan, CA inspection and monitoring documentation, and
IU self-monitoring reports.
30
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SECTION II
HOW TO EVALUATE: The inspector should review the CA's approved
pretreatmerh program and NPDES permit to determine if either specifies CA
inspection and sampling frequency or SID self-monitoring and reporting
requirements. These frequencies, if specified, should them be compared to the
Federal regulations (CA inspection and sampling once per year and SIU self-
monitoring and reporting twice per year), and the most stringent frequency be
entered as the required frequency. The inspector should then inquire as to the
CA's actual frequency of these activities. Documentation of the actual frequency
should be sought (e.g. a schedule for the year). If the actual frequency is less
than the required frequency, the inspector should inquire as to the reason for the
difference and document the reason on the Checklist.
E.2.
In the past 12 months, how many, and what percentage of SIUs were not
sampled or not inspected at least once.
F.
F.I.
Under 40 CFR 403.8(f)(2)(v) CAs must inspect and sample each SIU at
least once a year. The number and percentage of SIUs not inspected or not
sampled at least once in 12 months is a Water Enforcement National Data Base
data element. i
WHERE TO LOOK: CA inspection and sampling tracking system, sampling and
inspection records, and list of SIUs.
HOW TO EVALUATE: The inspector should inquire as to the number of SIUs not
sampled at least once, not inspected at least once, or not sampled or not
inspected at least once in the past 12 months. The inspector should then use
this number and the number of SIUs discharging to the CA to determine the
percentage of SIUs not inspected or sampled. If it is determined that some SIUs
were not inspected or sampled at least once during the past 12 months, the
inspector should inquire as to the reason for the deficiency and document the
reason in the Checklist.
Enforcement
As an enforcement action, did the CA use notice or letter of violation.
AOs, administrative fines, show cause hearings, compliance schedules,
permit revocation, civil suits, criminal suits, termination of service, other
(specify)?
ISSUE: The CA must investigate instances of noncompliance with local limits
and/or categorical discharge standards and take appropriate enforcement actions
to return the IU to compliance.
WHERE TO LOOK: Pretreatment program performance report, IU file review, and
documentation provided by CA during interview.
HOW TO EVALUATE: This question is an information gathering prompt to the
inspector to collect information on the types of enforcement actions the CA has
31
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SECTION II
used in response to ID violations. In order to identify any deficiencies in the CA's
enforcement, the inspector should obtain more than just what types of
enforcement actions the CA has used. The inspector should request a list of IDs
that have been in noncompliance which also indicates for each IU:
• Violations (types and dates of occurrence)
• Enforcement actions taken [type of enforcement action(s) and date(s)]
• Current compliance/noncompliance status.
This catalogue of enforcement actions will enable the inspector not only to know
the range of enforcement actions taken but how many enforcement actions were
necessary and how long it took before compliance was achieved.
The inspector should request that the CA provide this information before or during
the PCI. This information may have been reported in the CA's pretreatment
reports; however, the inspector may want to request an update to this
information. The inspector can use the file review to verify this enforcement
information the CA has provided by comparing what is found in the lU's file with
what the CA has reported.
F.2. Did the CA comply with its approved ERP?
ISSUE: Once approved by the Approval Authority, the CA's Enforcement
Response Plan (ERP) constitutes a modification of the approved program. As
such, the CA is obligated to conduct its enforcement activities in a manner
consistent with the procedures established in the ERP.
WHERE TO LOOK: ERP, enforcement orders (e.g., NOVs, AOs, Consent Orders,
etc.), compliance schedules, correspondence.
HOW TO EVALUATE: Since the ERP modifies the approved pretreatment
program, the procedures outlined therein supersede those described in the
program submission. The CA's enforcement activities, as documented in the IU
files and described by the pretreatment staff, should reflect the ERP procedures,
including time frames. The inspector should bear in mind that this is not
necessarily the case for enforcement activities conducted prior to ERP approval.
If the CA does not have an approved ERP, the inspector should determine
whether the CA conducted its enforcement activities in accordance with the
procedures described in the approved program. Where the approved program
does not contain enforcement procedures, the inspector should identify any
instance where the enforcement activities of the CA appear to be ineffective in
obtaining compliance.
32
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SECTION 11
F.3. Indicate the number and percent of SIUs that were identified as being in
SNC with applicable pretreatment standards and reporting requirements,
self-monitoring requirements, and pretreatment compliance schedules for
the most recent full quarter.
ISSUE: A low percent of SlUs in SNC may be indicative of effective enforcement.
The CA should take an escalated enforcement action (at least an AO) against an
SIU that has reached SNC status.
WHERE TO LOOK: Pretreatment program performance report, ID file review, and
documentation provided by CA during interview.
HOW TO EVALUATE: If the CA's pretreatment program performance report
provides the number and list of SlUs in SNC (in the CA's pretreatment year), the
inspector should record this data in Attachment A: Pretreatment Program Status
Update, Section B: Pretreatment Program Status. Item No. 4. If this information
was not in the CA's pretreatment program performance report, then prior to the
PCI the inspector should request the CA to compile the following information and
send it to the inspector before the PCI or have it available during the PCI: the
number (and percent) of SlUs that were in SNC during the four most recent full
quarters. (There may be cases in which an SIU is in SNC for more than one
quarter. An SIU is only counted once even if that SIU was in SNC for several
quarters.) The inspector should record this information in Attachment A:
Pretreatment Program Status Update. Section B, Item No. 4.
During the PCI, the inspector should obtain the number and percent of SlUs in
SNC for the most recent full quarter. This SNC information should be recorded in
Section II: F. Enforcement. Item No. 3. If the CA's definition of SNC differs
from EPA's, the inspector should indicate if the recorded information is based on
SNC as defined by the CA or by EPA. The inspector should note any deficiencies
in the information provided by the CA. ;
F.4. Did the CA publish all SlUs in SNC in largest daily newspaper in
accordance with NPDES permit requirements?
ISSUE: The CA is required to publish (on an annual basis) all SlUs that had been
in SNC during the reporting year.
WHERE TO LOOK: Pretreatment program performance report.
HOW TO EVALUATE: The inspector should obtain a copy of the CA's publication
of significant violators (if a copy is not in the CA's pretreatment report to EPA or
the State). It may be necessary to determine whether the CA's definition of
"significant noncompliance" is consistent with the Federal definition. If the
inspector identifies any lUs determined to be in SNC during the file review that
were not published and should have been published, a deficiency should be noted.
33
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SECTION II
F.5. How many SlUs were in SNC with self-monitoring requirements and were
not inspected and/or sampled (in the four most recent full quarters)?
ISSUE; There are three ways the CA has to obtain information about the
compliance status of its lUs; through IU self-monitoring, CA inspections, and CA
sampling. If an IU has not complied with its self-monitoring requirements and the
CA has not conducted any inspections or sampling of the IU, then the compliance
status of the IU is unknown.
WHERE TO LOOK: The inspector can request two lists: a list of lUs not sampled
or inspected and a list of lUs in SNC for self-monitoring.
HOW TO EVALUATE: The inspector can compare the two lists and find those
SlUs appearing on both lists.
F.6. a. Did the CA experience interference, pass through, fire or explosions
(flashpoint, etc.), corrosive structural damage, flow obstructions,
excessive flow rates, excessive pollutant concentrations, heat
problems, interference due to O&G, toxic fumes, illicit dumping of
hauled wastes, worker health and safety, or other (specify) caused by
industrial discharges?
b. If yes, did the CA take enforcement action against the Ills causing or
contributing to pass through or interference?
ISSUE; The CA must investigate and take enforcement actions against lUs
causing or contributing to pass through or interference.
WHERE TO LOOK: POTW's Discharge Monitoring Reports (DMRs) and sludge
analytical data, wastewater treatment plant's log book, pretreatment program
performance report, and interview.
HOW TO EVALUATE: The inspector should interview CA personnel (including
sampling technicians or service maintenance crews) to determine if the CA has
experienced any interference, pass through, or collection system or treatment
plant operational problems caused by IU discharges. He/she should also review
NPDES DMR effluent and sludge data as well as the wastewater treatment plant's
operation log book for violations. Additionally, the CA may have reported these
incidents in its pretreatment program performance report or kept a separate file
on these incidents.
The inspector should review available documentation and should inquire of the CA
personnel if there have been any problems of this type. The inspector should
pursue any indication of collection system or wastewater treatment plant
problems (particularly those where pass through or interference has resulted) by
gathering the following information: description of the problem, known or
purported cause, and the names of the lUs known or suspected of causing or
34
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SECTION II
contributing to the problem. If the CA could not determine the cause or the IDs
responsible, the inspector should inquire as to why this was not possible. The
inspector should review the files of the IDs causing or contributing to the problem
to verify that an enforcement action was taken.
F.7. a. How many SlUs are on compliance schedules?
b. List these SlUs by name and compliance schedule end dates.
ISSUE: The CA should establish compliance schedules for SlUs in accordance
with its approved ERP. These compliance schedules should identify specific
actions the SlUs are to take and establish specific dates by which these actions
are to be completed. The dates should represent the shortest possible time
frames in which the SlUs can realistically achieve compliance.
WHERE TO LOOK: Pretreatment program performance report, IU file review, and
documentation provided by CA during interview.
HOW TO EVALUATE: The inspector should review the enforcement files of all or
several of the SlUs on compliance schedules. The inspector should determine
whether the IU is meeting the compliance schedule milestone dates, whether the
CA has requested periodic compliance schedule progress reports from the lUs,
and whether the CA is escalating its enforcement actions when the lUs have not
met the compliance schedules or not achieved consistent compliance at the end
of the compliance schedule.
F.8. Were any ClUs allowed more than 3 years from the effective date of a
categorical standard to achieve compliance?
ISSUE: The CA can not extend the compliance date established in the regulation
pertaining to specific categorical pretreatment standards;. Unless the standard
specifies otherwise, ClUs are allowed 3 years from the effective date of the
standards to achieve compliance. The CA should notify the ClUs of any
promulgated categorical pretreatment standards and establish, in the control
mechanism, a construction schedule for any CIU that is not consistently meeting
the categorical pretreatment standards. Those scheduler should be developed in
a manner that will ensure that the CIU is consistently achieving compliance by the
date established in the Federal regulation. For those ClUs that have not achieved
consistent compliance by the established date, the CA should initiate an
appropriate enforcement action. At a minimum, the ClUs should receive an AO or
similar enforcement action established in the CA's ERP 'For violations of
enforcement compliance schedules. The CA should consider imposing penalties
based on recovering any economic benefit the CIU has derived by delay in
achieving compliance.
WHERE TO LOOK: Pretreatment program performance report, IU file review, and
documentation provided by CA during interview.
35
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SECTION II
HOW TO EVALUATE: The inspector should review the enforcement files of all or
several of the ClUs that have not achieved consistent compliance by the date
established by the Federal regulations. The inspector should determine whether
the CA has taken an enforcement action (at least an AO or similar enforcement
action required by the CA's ERP) and whether the CA has assessed a penalty.
The inspector should review compliance schedules and determine if the specific
actions and dates established represent an accelerated schedule to achieve
compliance in the shortest possible time. The inspector should obtain the
necessary information that will enable a determination of whether EPA or the
State should take an enforcement action against the IU and/or an enforcement
action against the CA.
F.9. Did the SlUs return to compliance within 90 days, within the time
specified in the ERP, through a compliance schedule?
ISSUE: Generally, effective enforcement is defined as a return to compliance
within 90 days. Some situations make this time frame impossible. If it is unlikely
that compliance can be achieved within 90 days even with a good faith effort on
the part of the IU, the IU should be put on a compliance schedule. All
enforcement activity must be consistent with the CA's ERP.
WHERE TO LOOK: Pretreatment program performance report, IU file review, and
documentation provided by CA during interview.
HOW TO EVALUATE: The inspector should identify, through file reviews and
interview discussion, instances where the CA has not taken effective
enforcement against lUs in noncompliance. When compliance was not achieved
within 90 days, the CA should have escalated enforcement to a formal stage
(e.g., a show cause hearing, an AO, etc.). Generally, penalties should have been
assessed against the IU which were significant enough to negate the economic
benefit gained by not complying with the standards.
Where compliance within 90 days was not achievable (e.g., due to the need for
installation of complex and/or costly equipment), the IU should have been placed
on a compliance schedule and progress toward compliance should have been
monitored. All compliance schedules should have contained milestone dates and
the CA should have taken additional enforcement actions for missed milestones.
36
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B
BIBLIOGRAPHY OF MATERIALS ON
POTW PRETREATMENT PROGRAM DEVELOPMENT,
IMPLEMENTATION, AND OVERSIGHT
-------
-------
B
BIBLIOGRAPHY OF MATERIALS ON
POTW PRETREATMENT PROGRAM DEVELOPMENT,
IMPLEMENTATION AND OVERSIGHT
TABLE OF CONTENTS
PAGE
STATUTORY AND REGULATORY INFORMATION 1
POTW PROGRAM OVERSIGHT 2
GENERAL PROGRAM DEVELOPMENT AND IMPLEMENTATION 2
PRETREATMENT PROGRAM IMPLEMENTATION COMPUTER MODELS/PROGRAMS . . 3
APPLICATION OF CATEGORICAL PRETREATMENT STANDARDS 3
MEMORANDUM 4
NATIONAL PRETREATMENT PROGRAM REVIEW AND EVALUATION 4
OTHER 5
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BIBLIOGRAPHY OF MATERIALS ON
POTW PRETREATMENT PROGRAM DEVELOPMENT,
IMPLEMENTATION, AND OVERSIGHT
The guidance manuals, memoranda, and reports identified in this list have been developed by
the U.S. Environmental Protection Agency Office of Water. This list is not an order form.
Many materials on this list are no longer available for distribution. Efforts are underway to
provide essential documents to EPA Libraries Nationwide and to make materials available
through the National Technical Information Service (NTIS - 5285 Port Royal Road, Springfield,
VA 22161 [703/487-4600]). If you have any questions regarding these materials or would like
to obtain a copy of any of the documents, please contact the EPA Regional or State
Pretreatment Coordinator in your area.
STATUTORY AND REGULATORY INFORMATION
Clean Water Act (incorporating the Water Quality Act of 1987)
EPA Administrated Permit Programs: The National Pollutant Discharge Elimination System
(NPDES) (40 CFR Part 122)
Guidelines Establishing Test Procedures for the Analysis of Pollutants (40 CFR Part 136)
General Pretreatment Regulations (40 CFR Part 403)
Categorical Pretreatment Standard Regulations (40 CFR Parts 405 - 471)
• For regulatory information the following documents can be purchased:
Code of Federal Regulations (CFR)
Federal Register
Federal Register Index
Federal Register List of CFR Sections Affected.
• For information on these documents contact:
Superintendent of Documents ;
U.S. Government Printing
Washington, DC 20402
(202) 783-3238
Rev. September 25, 1991
-------
POTW PROGRAM OVERSIGHT
Procedures Manual for Reviewing a POTW Pretreatment Program Submission (October
1983)
Pretreatment Implementation Review Task Force (January 30, 1985)
Pretreatment Compliance Inspection and Audit Manual for Approval Authorities (July
1986)
Guidance for Implementing RCRA Permit-by-Rule Requirements at POTWs (July 1987)
Guidance for Reporting and Evaluating POTW Noncompliance with Pretreatment
Implementation Requirements (September 1987)
NPDES Compliance Inspection Manual (May 1988)
Basic Inspector Training Course Fundamentals of Environmental Compliance Inspections
(February 1989)
NPDES Compliance Monitoring Inspector Training
- Laboratory Analysis (April 1990)
- Legal Issues (May 1990)
- Biomonitoring (June 1990)
- Overview (August 1990)
- Sampling (October 1990)
GENERAL PROGRAM DEVELOPMENT AND IMPLEMENTATION
Guidance Manual for POTW Pretreatment Program Development (October 1983)
RCRA Information on Hazardous Wastes for POTWs (September 1985)
Environmental Regulations and Technology - The National Pretreatment Program (July
1986)
Pretreatment Compliance Monitoring and Enforcement Guidance (July 1986)
Guidance Manual for the Identification of Hazardous Wastes Delivered to Publicly Owned
Treatment Works by Truck, Rail, or Dedicated Pipe (June 1987)
Guidance Manual for Preventing Interference at POTWs (September 1987)
Guidance Manual on the Development and Implementation of Local Discharge Limitations
Under the Pretreatment Program (December 1987)
Guidance Manual for Control of Slug Discharges to POTWs (February 1989)
Industrial User Permitting Guidance Manual (September 1989)
Rev. September 25, 1991
-------
Guidance for Developing Control Authority Enforcement Response Plans (September
1989)
Guidance Manual for POTWs to Calculate the Economic Benefit of Noncompliance
(September 1990)
Supplemental Manual on the Development and Implementation of Local Discharge
Limitations Under the Pretreatment Program: Residential and Commercial Toxic Pollutant
Loadings and POTW Removal Efficiency Estimates (May 1991)
Pretreatment Bulletins
No. 1 (September 1985)
No. 2 (March 1987)
No. 3 (November 1987)
No. 4 (July 1988) ;
No. 5 (January 1989)
No. 6 (June 1989)
No. 7 (January 1990)
No. 8 (September 1990)
No. 9 (January 1991)
PRETREATMENT PROGRAM IMPLEMENTATION COMPUTER MODELS/PROGRAMS
PRELIM 3.0 Users Manual and Diskette (January 1987)
Pretreatment Compliance Monitoring and Enforcement Software (June 1988)
PRELIM 4.0 Users Manual and Diskette (May 1991)
APPLICATION OF CATEGORICAL PRETREATMENT STANDARDS
Guidance Manual for Electroplating and Metal Finishing Pretreatment Standards (February
1984)
Guidance Manual for Pulp, Paper, and Paperboard and Builder's Paper and Board Mills
Pretreatment Standards (July 1984)
Guidance Manual for the Preparation and Review of Removal Credit Applications
(July 1985)
Environmental Regulations and Technology - The Electroplating Industry (September
1985)
Guidance Manual for Iron and Steel Manufacturing Pretreatment Standards (September
1985)
Guidance Manual for the Use of Production-based Pretreatment Standards and the
Combined Wastestream Formula (September 1985)
Rev. September 25, 1991
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Guidance Manual for Implementing Total Toxic Organic (TTO) Pretreatment Standards
(September 1985)
Guidance Manual for Leather Tanning and Finishing Pretreatment Standards (September
1986)
Guidance Manual for Battery Manufacturing Pretreatment Standards (August 1987)
Non-Consent Decree Categorical Pretreatment Standards (August 1988)
Guidance Manual for Aluminum, Copper, and Nonferrous Metals Forming and Metal
Powders Pretreatment Standards (February 1989)
MEMORANDUM
Pretreatment Compliance Strategy (October 28, 1983)
Guidance to POTWs for Enforcement of Categorical Standards (November 5, 1984)
Local Limits Requirements for POTW Pretreatment Programs (August 5, 1985) (In Local
Limits Guidance Manual)
NPDES and Pretreatment Inspection Reporting for FY 1986 Office of Water Accountability
System (August 6, 1985)
Audits of POTWs with Approved Pretreatment Programs (August 30, 1985)
Discharge of Wastewater from CERCLA Sites into POTWs (April 15,1986)
Pretreatment Audit Reporting Requirements (December 16, 1985)
Non-Consent Decree Categorical Pretreatment Standards (August 24, 1988)
Guidance on Penalty Calculation for POTW Failure to Implement an Approved
Pretreatment Program (December 22, 1988)
Conventional Pollutants Regulated by Categorical Pretreatment Standards (February 16,
1989)
Application and Use of the Regulatory Definition of Significant Noncompliance for
Industrial Users (September 9, 1991)
NATIONAL PRETREATMENT PROGRAM REVIEW AND EVALUATION
Assessment of the Impacts of Industrial Discharges of Publicly Owned Treatment Works
(December 1981)
The Pretreatment Regulatory Impact Analysis (1983)
Rev. September 25, 1991
4
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Assessment of Industrial Waste Control Programs in Three Municipalities (1983)
Fate of Priority Pollutants in Publicly Owned Treatment Works (September 1982)
Report to Congress on the Discharge of hazardous Wastes to Publicly Owned Treatment
Works (February 1986)
GAO Report- Improved and Enforcement Needed for Toxic Pollutants Entering Sewers
(April 1989)
Report to Congress on the National Pretreatment Program (July 1991)
OTHER
Best Management Practices Guidance Document (June 1981)
NPDES Compliance Flow Measurement Manual (September 1981)
Handbook for Sampling and Sample Preservation of Water and Wastewater (September
1982) (NTIS number PB83-124503)
Fate of Priority Pollutants in Publicly Owned Treatment Works (September 1982)
Technical Support Document for Water Quality-Based Toxics Control (September 1985)
Summaries of 40 CFR Part 136 and 40 CFR Parts 405-471 (October 1988)
CERCLA Site Discharges to POTWs Guidance Manual (August 1990)
Rev. September 25, 1991
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LIST OF DEVELOPMENT DOCUMENTS AND
ADDITIONAL U.S. EPA INDUSTRIAL TECHNOLOGY DIVISION PUBLICATIONS
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