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
                                                                             i
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
                                                                 i
         -  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:
                                                                                i

      •  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
                                                                               i
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
                                                                                 !
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
                                                                              i
 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.
                                                                              i
                                                                              I
      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.
                                                                              i
 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
                                                                              i
 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
                                           8

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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
                                                                               I
general, certain precautions are essential:

      •  The inspector should not discuss any legal  or enforcement consequences with the
         pretreatment program contact.                                          '
                                                                               i
      •  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
                                                                               i
documented. "Documentation" refers to all notes, Checklists or copies taken to provide
                                                                               r
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
                                           12
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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
                                                                          i
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
                                                                          i
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.                                           !
                                                                          i
      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
                                         14

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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
                                          15

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program components. Then, in the "Comments" field beneath each of the major program
                                                                              i
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
                                                                              i
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

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                                 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).

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THIS PAGE INTENTIONALLY LEFT BLANK

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                                       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

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                                        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

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          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

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                                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

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                                 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

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                          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

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                           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

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THIS PAGE LEFT INTENTIONALLY BLANK

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                            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

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                             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
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                            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

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                            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

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                              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)
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                        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
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               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

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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

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                       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

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                       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

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                      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

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THIS PAGE LEFT INTENTIONALLY BLANK

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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

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                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

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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)

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                            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

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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)

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                              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

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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)

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                             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

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                        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)

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B-8

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                       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

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THIS PAGE LEFT INTENTIONALLY BLANK
               C-2
                                         ATTACHMENT C: WORKSHEETS

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                                           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

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THIS PAGE LEFT INTENTIONALLY BLANK
               C-4
                                         ATTACHMENT C: WORKSHEETS

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                                  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

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                             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

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                          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

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                             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

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                        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

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                           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

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                  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

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                             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

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                      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

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                               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

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          3.
PCI REFERENCE MATERIAL

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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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                                                                       SECTION I
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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       h.
                                                                  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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SECTION I

      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.
                                                            I
      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.
                                          8

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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
                                                         10

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                                                                        SECTION I

       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.
                                    11

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SECTION
            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.
                                          12

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                                                                       SECTION I

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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SECTION I
            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.                    ,
                                    15

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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
                                          16

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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
                                    17

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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
                                           18

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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.
                                    19

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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.
                                           20

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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.
                                     21

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SECTION I

      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
                                     23

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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.
                                        24

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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
                                          26

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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
                                     27

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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
                                          28

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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.
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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

-------
                                                                      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

-------
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

-------
                   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

-------

-------
                        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

-------
     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

-------
     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

-------

-------
             LIST OF DEVELOPMENT DOCUMENTS AND
ADDITIONAL U.S. EPA INDUSTRIAL TECHNOLOGY DIVISION PUBLICATIONS

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