United States
Environmental Protection
Agency
Office of Water
Enforcement and Permits
Washington, DC 20460
July 1986
Water
&EPA
Pretreatment Compliance
Inspection and Audit Manual
for Approval Authorities
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
OFFICE OF
WATER
MEMORANDUM
SUBJECT: Pret.reat.ment Compliance Inspections and Audits
FROM: JamygfK. Elder, Director
Office of Water Enforcement and Permits (EN-335)
TO: Users of the Pretreatment Compliance Inspection (PCI)
and Audit Manual for Approval Authorities
This manual provides Approval Authorities with information
and material on audits and inspections of approved local POTW
pretreatment programs. The manual should assist Approval Authorities
in providing effective oversight of approved pretreatment programs
under their jurisdiction.
The PCI and audit procedures are consolidated in this manual
because the preparation and follow-up steps for the two activities
are similar. Separate checklists for conducting PCIs and audits
are included in the manual. The audit checklist addresses all
materials contained in the PCI checklist, although some audit
questions seek more detailed information.
Audits and PCIs are complementary means of achieving effective
pretreatment program oversight. Audits, which are more comprehensive
and resource-intensive than PCIs, are most useful when conducted
approximately one year after program approval and again during the
POTW1s five-year permit term, preferably close to the time of
permit reissuance for the approved POTW. Initial audits allow
for identification of any problems the POTW may have in implementing
its program. Where appropriate, follow-up guidance or assistance
(including contractor assistance in some cases) may be provided
by the Approval Authority to the POTW. In cases where the POTW
has failed to implement important aspects of its program, the
audit may also provide an opportunity to determine whether enforce-
ment action against the POTW is needed. Audits performed just
prior to permit reissuance provide the Approval Authority with a
good opportunity to determine whether any modifications need to
be made to the pretreatment conditions in the POTW's NPDES permit
to address any deficiencies in the local program (e.g., to provide
greater detail on performance expectations for local permit
issuance or compliance inspections for lUs, to prescribe
methodologies for developing or assessing the need for local
limits, etc.)
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PCIs are less resource-intensive than audits. The PCI focuses
on the POTW's compliance monitoring and enforcement activities.
Optimally, PCIs should be performed annually during the interim
years between audits as part of routine NPDES municipal inspections.
PCIs should be included in the compliance inspection plans developed
between Regions and States.
I hope that you will find this manual to be a useful tool
for ensuring that your approved local pretreatment programs are
being implemented in accordance with the requirements of the
General Pretreatment Regulations (40 CFR Part 403).
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PRETREATMENT COMPLIANCE INSPECTION AND AUDIT
MANUAL FOR APPROVAL AUTHORITIES
Office of Water Enforcement and Permits
July 1986
U.S. Environmental Protection Agency
401 M. St. S.W.
Washington, D. C. 20460
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TABLE OF CONTENTS
1. INTRODUCTION 1-1
1.1 PRETREATMENT COMPLIANCE INSPECTION (PCI) * 1-1
1.2 AUDtT .-. 1-1
1.3 ORGANIZATION OF THE GUIDANCE MANUAL 1-2
1.4 PCI AND AUDIT SCHEDULING AND COORDINATION 1-3
1.5 RESOURCE REQUIREMENTS 1-^3
1.6 STRATEGIC PLANNING AND MANAGEMENT SYSTEM (SPMS)
COMMITMENTS 1-3
1.7 SOURCES OF ADDITIONAL INFORMATION 1-4
2. OVERVIEW AND BACKGROUND 2-1
2.1 PRETREATMENT PROGRAM AUTHORITY 2-1
2.2 FEDERAL REQUIREMENTS 2-1
2.2.1 Federal Categorical Pretreatment Standards 2-2
2.2.2 Prohibited Discharge Standards and Local Limits... 2-2
2.2.3 Overview of State Regulations 2-6
2.3 CONTROL AUTHORITY REQUIREMENTS AND RESPONSIBILITIES 2-7
2.3.1 Industrial Waste Survey 2-7
2.3.2 Industrial User Monitoring and Enforcement 2-8
2.3.3 Recordkeeping and Reporting Requirements 2-9
3. PCI AND AUDIT PROCEDURES 3-1
3.1 INTRODUCTION 3-1
3.2 PREPARATION 3-1
3.2.1 Review of the Control Authority's Program Status.. 3-1
3.2.2 Development of an Audit or Inspection Plan 3-2
3.2.3 Notification to the Control Authority 3-2
3.2.4 Equipment Preparation . 3-3
3.2.5 Coordination with Region and State 3-3
3.3 ENTRY PROCEDURES 3-3
3.3.1 Arrival 3-3
3.3.2 Presentation of Credentials 3-3
3.3.3 Consent 3-3
3.3.4 Problems with Entry or Consent 3-3
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Page
3.4 OPENING CONFERENCE 3-4
3.5 DOCUMENTATION. ..„...- 3-4
3.6 TOUR OF TOE POTW (Optional) 3~4
3.7 VISITS TO LOCAL INDUSTRIES (Optional) 3-5
3.8 CLOSING CONFERENCE 3-6
3.9 REPORT PREPARATION 3-6
3.9.1 Schedule for Report Submission 3-8
3.10 DATA ENTRY INTO PCS 3-8
3.11 FOLLOW-UP RESPONSE TO THE CONTROL AUTHORITY 3-8
3.11.1 PCI 3-8
3.11.2 Audit 3-8
4. PRETREATMENT COMPLIANCE INSPECTION (PCI) CHECKLIST 4-1
4.1 CONTROL AUTHORITY BACKGROUND INFORMATION 4-2
4.1.1 General Control Authority Information 4-2
4.2 COMPLIANCE MONITORING AND ENFORCEMENT PROCEDURES -
CONTROL AUTHORITY PERSONNEL RESPONSE 4-4
4.2.1 Control Authority Pretreatment Program Overview 4-4
4.2.2 Control Authority Pretreatment Program
Modifications 4-4
4.2.3 Control Authority Inspection and Monitoring of
Industrial Users (lUs) 4-6
4.2.4 Control Mechanism Evaluation 4-8
4.2.5 Enforcement Procedures 4-10
4.2.6 Compliance Tracking 4-12
4.3 COMPLIANCE MONITORING AND ENFORCEMENT - IU FILE
EVALUATION 4-14
4.3.1 File Contents 4-16
4.3.2 Control Mechanism Evaluation 4-16
4.3.3 IU Compliance Evaluation 4-18
4.3.4 IU Self-Monitoring Evaluation 4-18
4.'3.5 Control Authority Enforcement Initiatives 4-18
4.3.6 Narrative Coitments 4-21
4.4 SUMMARY EVALUATION OF CONTROL AUTHORITY PRETREATMENT
PROGRAM 4-22
4.5 SUPPORTING DOCUMENTATION 4-22
11
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TABLE OF CONTENTS
(CONTINUED)
Page
5. PRETREATMENT PROGRAM AUDIT CHECKLIST 5-1
5.1 INTRODUCTION 5-1
5.2 OVERVIEW OF THE AUDIT CHECKLIST 5-1
5.2.1 Checklist Cover Page 5-1
5.2.2 Section I: Control Authority Background
Information 5-1
5.2.3 Section II: POIW Pretreatment Program Fact
Sheet 5-1
5.2.4 Section III: Legal Authority and Control
Mechanism 5-2
5.2.5 Section IV: Application of Pretreatment
Standards 5-2
5.2.6 Section. V: Compliance Monitoring 5-2
5.2.7 Section VI: Enforcement 5-2
5.2.8 Section VII: Data Management and Public
Participation - 5-2
5.2.9 Section VIII: Program Resources 5-2
5.2.10 Section IX: POTW File Review 5-3
5.2.11 Section X: Evaluation and Summary 5-3
5.2.12 Supporting Documentation 5-4
5.3 AUDIT CHECKLIST
TABLE
2.1 INDUSTRIES SUBJECT TO CATEGORICAL PRETREATMENT STANDARDS 2-3
APPENDICES
APPENDIX A - EPA MEMORANDA FROM J. WILLIAM JORDAN AND MARTHA PROTHRO
Instructions For Completing Form 3560-3
APPENDIX B - SAMPLE FOLLOW-UP LETTER TO THE CONTROL AUTHORITY
APPENDIX C - POTW PRETREATMENT PROGRAM FACT SHEET
APPENDIX D - NPDES COMPLIANCE INSPECTION REPORT FORM 3560-3
ill
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I. INTRODUCTION
The pretreatraent compliance inspection (PCI) and the pretreatment program
audit have.been established to allow on-site review of pretreatment programs
in approved publicly owned treatment works (POTWs). The intent of this manual
is to provide guidance to EPA Regions and State personnel who are responsible
for conducting PCIs arct audics.
1.1 PRETREATMENT COMPLIANCE INSPECTION (PCI)
The PCI will expand the scope of existing municipal NPDES inspections to
include an evaluation of the approved POTW pretreatment program. The PCI is
designed to verify the compliance status of the POTW and focuses primarily on
the compliance monitoring and enforcement activities'of the POTW. It also
attempts to ascertain whether there have been changes to the approved program
which have not been reviewed by the Approval Authority. The PCI should
normally be conducted as an adjunct to other NPDES inspections to conserve
travel costs and staff time. Additionally, consolidation allows the inspector
to more easily integrate information about all areas of the POTW's operations.
PCIs are compatible with the following NPDES inspections:
o
Compliance Evaluation Inspections (CEI)
0 Compliance Sampling Inspections (CSI)
0 Performance Audit Inspections (PAI)
0 Diagnostic Inspections, and
0 Other nonroutine types of inspections such as toxics sampling and
biomonitoring inspections.
While not included in the PCI checklist, the EPA Region or State may
include additional activities with the PCI. These activities may include but
are not limited to the following:
0 Industrial User Inspection Overview - The inspector may overview the
POTW's industrial inspection and/or sampling procedures.
0 Sampling Inspections - The inspector may actually sample industrial
users within the POTW directly to determine compliance with
pretreatment standards.
0 QA/QC Procedure Inspections - The inspector can review either the POTW
or industrial user (IU) or both to assess the adequacy of quality
assurance and quality control analytical procedures at the laboratory.
This Manual, along with a PCI Workshop (offered by EPA to Regions and
States), provides basic guidance to conduct a PCI.
1.2 AUDIT
POTW pretreatment program audits are also performed as a means of
evaluating pretreatment program implementation. The audit is a comprehensive
review of all elements of an approved POTW pretreatment program. The audit
addresses all materials contained in the basic PCI although audit questions
are in some instances worded differently, and seek more detailed information.
The audit includes a review of the following elements of the POTW's program:
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0 Changes to the pretreatment program since approval
0 Legal authority and control mechanism
0 Application of pretreatment standards (categorical pretreatment
standards and local limits)
0 Compliance monitoring and enforcement efforts
0 Data management and public participation
0 Program resources.
In most instances, the audit is an independent activity which will not
be conducted with an NPDES inspection. Also, the audit is generally performed
by program office personnel rather than an inspector. While the results of
the PCI or audit may be the basis for enforcement activity, the audit is also
designed to provide guidance and technical assistance to the Control Authority
and to assess the need for modifications to the approved pretreatment program.
Consequently, the audit is designed to answer the following questions:
0 Is the POTW complying with existing requirements in its permit,
approved program, and the General Pretreatment Regulations?
0 Are any changes that the POTW is proposing to make in its program
appropriate and should such changes be officially incorporated via
program/permit modification?
0 Are elements of the previously approved program proving to be deficient
through experiences in implementation, and should changes in the
approved program be required via the NPDES permit?
0 Can the POTW benefit from specific and available resources which the
Approval Authority can provide such as guidance documents, computer
programs, etc.?
0 What follow-up actions on the part of the POTW are recommended to
improve the effectiveness of the existing program?
1.3 ORGANIZATION OF THE GUIDANCE MANUAL
This Manual is organized into five chapters:
0 Chapter One; Introduction provides a definition of the PCI and the
audit; describes the organization of the Manual and addresses the
issues of scheduling, resource requirements and Strategic Planning
and Management System (SPMS) commitments.
0 Chapter Two; Overview describes the National Pretreatment Program and
provides general information relating to the principal responsibilities
of POTWs, otherwise known as Control Authorities.
0 Chapter Three; PCI and Audit Procedures discusses those elements of
the PCI and audit that differ from other NPDES inspection procedures—
including specific aspects of preinspection preparation, entry, opening
conference, documentation, closing conference, inspection report, and
follow-up responses to the Control Authority.
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0 Chapter Four: PCI Checklist provides narrative guidance to the user
of the checklist. An explanation of the questions in the checklist
appears on the left-hand page (even-numbered) with the checklist
itself on the right-hand page (odd-numbered).
0 Chapter Five; Audit Checklist provides an overview of the audit
checklist and contains the checklist itself.
1.4 PCI AND AUDIT SCHEDULING AND COORDINATION
The PCI will generally be scheduled as an adjunct to a planned NPDES
inspection. This will usually avoid the need for scheduling separate visits
to the same POTW facility. Types of inspections that can be coordinated with
a PCI include the Compliance Evaluation Inspection (CEI), the Compliance
Sampling Inspection (CSI), the Performance Audit Inspection (PAI), Diagnostic
Inspections and other nonroutine municipal inspections. These inspections
are performed by EPA or States in accordance with a Compliance Inspection
Plan arrived at between EPA Regions and States.
Audits should be performed initially within one year of POTW pretreatment
program approval and at the time of NPDES permit reissuance (once every five
years). The more concise PCI would be performed during intervening years.
These are the minimum scheduling requirements for PCIs and audits. Each may
be conducted more frequently if circumstances so require.
1.5 RESOURCE REQUIREMENTS
The average audit is estimated to require between six and ten person-days.
Normally, two people will spend two days on-site, although more personnel may
be needed to cover all elements of an audit for a large POTW. The average
PCI is estimated to require two person-days with approximately one-half day on
site. The balance of the time required includes pre-inspection preparation
time and follow-up report preparation. Travel costs should normally be
considered incidental to the NPDES municipal inspection.
1.6 STRATEGIC PLANNING AND MANAGEMENT SYSTEM (SPMS) COMMITMENTS
The Agency has established SPMS commitments for Regions and States to
conduct PCIs and audits. Although an audit generally covers everything in
the PCI checklist, the activity should not be counted as both a PCI and an
audit. EPA Headquarters will track commitments for Regions and States based
on retrievals from the Permit Compliance System (PCS). Instructions on PCI
and audit entry codes and other procedures were outlined in the August 5,
1985 memorandum from J. William Jordan, and the August 30 and December 16,
1985 memorandum from Martha G. Prothro (See Appendix A.)
Training workshops will be provided to assist EPA Regions and States
with PCIs and audits. Regions should accompany State personnel on initial
inspections and audits and provide only periodic review after the Regions are
satisfied with State performance.
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1.7 SOURCES OF ADDITIONAL INFORMATION
This document assumes that the reader has some knowledge of the National
Pretreatment Program or has attended a PCI or audit training workshop.
Additional sources of pretreatment program information and inspection guidance
can be found in the following documents:
0 "Guidance Manual for POTW Pretreatment Program Development," Office of
Water Enforcement and Permits, U.S. Environmental Protection Agency.
October 1983.
0 "Procedures Manual for Reviewing a POTW Pretreatment Program Submission",
Office of Water Enforcement and Permits, U.S. Environmental Protection
Agency. October 1983.
0 "NPDES Compliance Inspection Manual", Office of Water Enforcement and
Permits (EN-338), U.S. Environmental Protection Agency. June 1984.
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2. OVERVIEW AND BACKGROUND
2.1 PRETREATMENT PROGRAM AUTHORITY
The Clean Water Act requires EPA to restore and maintain the chemical/
physical, and biological integrity of the Nation's waters. The principal
regulatory tool for reducing pollutant discharges is the National Pollutant
Discharge Elimination System (NPDES). The requirements of the National
Pretreatment Program are administered through the NPDES program. The NPDES
permit places requirements and standards on Control Authorities, including
the requirement for developing and implementing a local pretreatment program.
The goal of EPA's National Pretreatment Program is to protect POTWs and
the environment from adverse impacts that may occur when hazardous or toxic
wastes are discharged into a sewage treatment system. This protection is
achieved mainly through the regulation of nondomestic users of POTWs that
discharge toxic wastes or unusually high concentrations of conventional
wastes.
EPA has promulgated the General Pretreatment Regulations in 40 CFR Part
403. These regulations use the terms "Approval Authority" and "Control
Authority" in reference to the different agencies that have responsibility
for pretreatment programs.
Approval Authorities are EPA Regional Offices or States to whom EPA has
delegated pretreatment approval authority responsibilities. Approval
Authorities must (1) oversee local pretreatment programs to determine whether
Control Authorities are properly implementing and enforcing their pretreatment
program requirements; (2) ensure that Control Authorities and industrial users
comply with applicable local pretreatment standards and requirements; (3)
evaluate the progress of pretreatment programs and identify any aspects of
pretreatment programs that need improvements, and (4) serve as Control
Authorities where no approved POTW programs exist.
Control Authorities are the agencies that must develop local pretreatment
programs; directly apply and enforce Federal, State, and local pretreatment
standards for industrial users; and comply with Federal, State, and local '
standards and requirements. When a pretreatment program is approved, the
POTW becomes the Control Authority. If the POTW does not have an approved
program or is not required to develop one, the Approval Authority (either the
approved State or EPA Region) acts as Control Authority. Approximately 1,400
POTWs are currently required to develop and implement a local pretreatment
program.
2.2 FEDERAL REQUIREMENTS
The General Pretreatment Regulations (40 CFR Part 403) specify the basic
requirements for the development and implementation of the Federal program.
The regulations address the various legal, procedural, technical, and adminis-
trative requirements and responsibilities for participating Federal, State,
and local governments. The sections that follow will discuss the more specific
aspects of the regulations.
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2.2.1 Federal Categorical Pretreatment Standards
Federal Categorical Pretreatment Standards have been or are being
established for specific categories of industries. Any industrial user
falling within one or more of these industrial categories mist meet, at a
minimum, numerical limits for certain pollutants that are typically present
in the waste discharges from those industries. Categorical pretreatment
standards are technology based standards and may be expressed as maximum
concentrations or production based, depending on the industrial category.
They may be superceded only by more stringent State or local limitations
where additional protection is necessary to comply with other limitations or
site-specific factors (i.e., water quality standards or sludge disposal
requirements). The current status of the various Categorical Pretreatment
Standards is shown in Table 2.1.
Categorical Pretreatment Standards may be modified for a particular
industrial discharger for any of the following reasons if proper documentation
is prepared and the request for modification is approved by the Approval
Authority (EPA or approved State):
0 Net/Gross Adjustment - Upon request of the industrial user and if
certain conditions are met, the applicable standard can be adjusted to
reflect allowance for a pollutant(s) in the industrial user's intake
water.
0 Removal Credit - A Control Authority may apply for authorization to
revise pollutant discharge limits in categorical pretreatment standards
to reflect removal of such pollutants by the POTW treatment plant.
However, EPA's removal credit regulation has been invalidated by an
April 1986 court ruling. Thus, until further court or regulatory
action restores the Agency's ability to provide removal credits, no
such credits are available.
0 Fundamentally Different Factors (PDF) Variance - An FDF variance may
be requested by an industrial user, a Control Authority, or other
interested person. The FDF variance is designed to compensate for
those situations where factors relating to an individual facility are
fundamentally different from factors as they were considered by EPA in
establishing a categorical standard. A standard may be subsequently
raised or lowered given the nature of the variance request.
2.2.2 Prohibited Discharge Standards and Local Limits
Section 403.5 of the General Pretreatment Regulations contains the
requirements for both Prohibited Discharge Standards and locally developed
limits. These limits apply to both categorical and noncategorical industries
and are in addition to the Federal Categorical Pretreatment Standards already
discussed. (EPA has authority to enforce Prohibited Discharge Standards and
locally developed limits, if necessary.)
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(Revised 4-22-86)
TABLE 2-1
INDUSTRIES SUBJECT TO CATEGORICAL PRETREATMENT STANDARDS
FINAL REGULATIONS
Industry Category
Timber Products Processing
Electroplating2
Iron & Steel
Inorganic Chemicals3
Certain Subparts
Phase I
Phase II
Petroleum Refining
Pulp & Paper Mills
Builders' Paper & Board Mills
Steam Electric Power Generating
Leather Tanning & Finishing
Porcelain Enameling
Coil Coating (Phase I)
-Steel Basis Material
- Galvanized Basis Material
- Aluminum Basis Material
Electrical & Electronic
Components (Phase I)
-Semi conductors
-Electronic Crystals
Metal Finishing
Copper Forming
Pharmaceuticals
Coil Coating (Phase II)
(Canmaking)
Electrical & Electronic
Components (Phase II)
-Cathode Ray Tube
-Luminescent Materials
Nonferrous Metals Manufacturing
Phase I
Phase II
Battery Manufacturing
Nonferrous Metals Forming
and Metal Powders
Pesticide Chemicals
Metal Molding and Casting
Date Issued PSES1
In Federal Effective Compliance
Register Date Date
1-26-81 3-30-81 1-26-84
1-28-81 3-30-81 4-27-84
(Nonintegrated)
6-30-84
(Integrated)
7-15-83 8-29-83 7-15-86 (TTO)
5-27-82 7-10-82 7-10-85
7-20-77 7-20-80
6-29-82 8-12-82 6-29-85
8-22-84 10-5-84 8-22-87
10-18-82 12-01-82 12-01-85
11-18-82 1-03-83 7-01-84
11-18-82 1-03-83 7-01-84
11-19-82 1-02-83 7-01-84
11-23-82 1-06-83 11-25-85
11-24-82 1-07-83 11-25-85
12-01-82 1-17-83 12-01-85
4-08-83 5-19-83 7-01-84
11-08-85(As)
7-15-83 8-29-83 6-30-84 (Part 443 TTO)
7-10-85 (Part 420 TTO)
2-15-86 (Final)
8-15-83 9-26-83 8-15-86
10-27-83 12-12-83 10-27-86
11-17-83 1-02-84 11-17-86
12-14-83 1-27-84 7-14-87
3-08-84 4-23-84 3-09-87 (Subparts A-M)
9-20-85 11-04-85 9-20-88 (Subparts N-AE)
3-09-84 4-23-84 3-09-87
8-23-85 10-7-85 8-23-88
10-4-85 11-18-85 11-18-88
10-30-85 12-13-85 10-31-88
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(Revised 02-03-86)
TABLE 2.1 (Continued)
INDUSTRIES SUBJECT TO" CATEGORICAL PRETREATMENT STANDARDS
PROPOSED REGULATIONS
Industry Category
Organic Chemicals and Plastics
and Synthetic Fibers
Plastics Molding and Forming
(Phthalates)
Date Issued In
Federal Register
3-21-83
(4-86)
Scheduled
Promulgation Date
3-86
(7-87)
IpSES - Pretreatment Standards for Existing Sources.
^Existing job shop electroplaters and independent printed circuit board manufacturers
must comply with only the electroplating regulations. All other electroplating
subcategories are now covered by both the electroplating and metal finishing
standards.
•^Final compliance date for Subparts A,B,L,AL,AR,BA, and BC is July 20, 1980. The
compliance date for Subparts AJ,AU,BL,BM,BN, and BO, except for discharges from
copper sulfate or nickel sulfate manufacturing operations, is August 22, 1987.
The compliance date for discharges from copper sulfate and nickel sulfate manu-
facturing operations and for all Subparts in Part 415 not previously specified
is June 29, 1985.
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Prohibited Discharge Standards
Prohibited Discharge Standards apply to all nondomestic sources introducing
pollutants into a POTW whether or not the source is subject to other Federal,
State, or local pretreatment'standards or requirements.
Prohibited Discharge Standards include general prohibitions and specific
prohibitions, as described below:
0 General Prohibitions - Section 403.5(a) generally states that pollutants
introduced into a POIW by a nondomestic source shall not pass through
the POIW or interfere with operation or performance of the works.
This requirement is generic in nature but becomes very important in
relation to locally developed limits, described later in this section.
In short, local limits are developed by Control Authorities to ensure
that the general prohibitions are met by industrial users.
0 Specific Prohibitions - Section 403.5(b) states that the following
pollutants shall not be introduced into any POIW:
- Pollutants that create a fire or explosion hazard in the POIW
- Pollutants that will cause corrosive structural damage to the POTW,
but in no case discharges with pH lower than 5.0, unless the system
is specifically designed to accommodate such discharges
- Solid or viscous pollutants in amounts that will cause obstruction
to the flow in the POTW, resulting in interference
- Any pollutant, including oxygen-demanding pollutants (BOD, etc.)
released in a discharge at a flow rate and/or pollutant concentration
that will cause interference with the POTW
- Heat in amounts that will inhibit biological activity in the POTW
resulting in interference, but in no case heat in such quantities
that the temperature at the POTW treatment plant exceeds 40°C (104°F),
unless the Approval Authority, upon request of the POIW, approves
alternative temperature limits.
Again, sane of the items above are generic in nature and are more clearly
defined by technically based local limits.
Local Limits
Local limits are the mechanism by which general and prohibited discharge
standards are applied in a technically based, defensible manner for individual
non-domestic users of the POTW system. Generally, these standards consist of
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numerical limits on the discharge of toxic metals, cyanide, 8005, phenols,
oil and grease, and toxic organics. They are normally expressed as maximum
limitations and usually apply at the point where the industry discharges to
the POTW collection system. Some Control Authorities, however, have both
average and maximum values and apply them at the end of industrial processes.
The basic philosophy behind locally derived limits is to prevent discharges
that contain^pollutants which interfere with treatment plant unit processes,
which pass through the treatment plant and adversely affect NPDES permit
compliance and receiving water quality, and which contaminate sludge to levels
that minimize disposal options.
In some cases, locally derived numeric limits will be more stringent than
Categorical Pretreatment Standards, because the limits, based on local,
site-specific conditions, are necessary to protect the POTW from interference
and pass through. The Control Authority is required to enforce the most
stringent pretreatment standard against an industrial user. In order for a
single maximum local limit to replace a maximum daily and a monthly average
(or 4-day) categorical standard, the local limit must be more stringent than
both values. If the single maximum local limit is more stringent than the
daily maximum contained in a categorical standard but less stringent than the
applicable long-term average (4-day or monthly average), then the POTW must
enforce the local limit and the long-term average (4-day or monthly). It is
also important to realize that local limits are normally applicable at end of
pipe while categorical standards apply to the end of a specific (regulated)
industrial process. Therefore, it may be necessary to enforce both limits
using different monitoring points. Alternatively, the categorical standard
may be adjusted to apply at the end of pipe by performing a mass balance
which accounts for dilution flows.
2.2.3 Overview of State Regulations
In certain instances, States have enacted State-wide or POTW-specific
regulations that can directly or indirectly affect the pretreatment require-
ments with which an industry must comply. Examples of these situations are
discussed below:
0 Sludge Disposal Regulations - Many States have sludge disposal
regulations that may affect an industrial user in one or two ways:
- Restrictions on POTW Sludge - If State regulations limit the type
and quantity of certain pollutants that may be present in a POTW's
sludge for the disposal option practiced by the municipality, local
limits for the industry may be necessary in order to maintain an
acceptable sludge quality.
- Restrictions on Industrial Sludge - An industry may generate a
sludge as a byproduct of their pretreatment system. State (and
Federal) regulations may then apply to the allowable storage,
transport, and disposal options available to the industry.
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0 Water Quality Limitations - Some States are issuing NPDES permits to
POTWs that contain limitations for toxic pollutants (especially toxic
metals). These NPDES limits for toxic pollutants are usually based on
achievement or maintenance of water quality standards that have been
calculated for the water body into which the POTW discharges. As with
the sludge disposal regulations, the Control Authority may develop
local limits for industries to control the industrial input of those
pollutants and thereby comply with its NPDES limitations.
2.3 CONTROL AUTHORITY REQUIREMENTS AND RESPONSIBILITIES
A POTW that receives pretreatment program approval becomes the Control
Authority and is responsible for:
Applying pretreatment standards and other requirements to industrial
users
i ° Performing routine industrial user monitoring
0 Taking appropriate compliance and enforcement action in cases of
noncorapliance
0 Ensuring industrial user compliance.
The major components of a Control Authority's pretreatment program are
discussed below.
2.3.1 Industrial Waste Survey
The industrial community must be accurately identified by the Control
Authority. The Industrial Waste Survey (IWS) is generally used to identify
and characterize industrial discharges to the POTW treatment plant. The IWS
is typically conducted during program development. The four 'activities that
generally comprise the IWS include:
0 Compiling a master list of potential industrial users (lUs) located in
the POTW service area.
0 Surveying each of these industries, usually by means of a questionnaire,
to collect the necessary information (i.e., the type of industry and
the quality and quantity of the wastewater discharge).
0 Conducting on-site industrial inspections to obtain complete and
accurate information.
0 Summarizing the data for use in developing the pretreatment program.
This information includes: the number of industrial users to be
regulated, types of industries, pollutants discharged, and volume of
waste discharged to the POTW system.
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An important component of effective pretreatment program iirplementation is the
periodic updating of the IWS information by the Control Authority to identify
new industrial discharges or changes in existing industrial discharges.
2.3.2 Industrial User Monitoring and Enforcement
Compliance monitoring by the Control Authority is essential for the
implementation of the pretreatment program. Information collected during
industrial monitoring activities provides the basis for compliance and enforce-
ment activities taken by the Control Authority against industrial users who
are found to be in violation of pretreatment standards and requirements.
Control Authority compliance activities include monitoring discharges/
receiving and reviewing industrial self - monitoring reports, and conducting
on-site inspections of industrial facilities. The goals of the Control
Authority compliance activities are the following:
0 Ensure industrial compliance with Federal categorical pretreatment
standards
0 Ensure industrial compliance with local discharge limitations, local
ordinances, and industrial user permit provisions
0 Ensure tnat required Federal and local self-monitoring and reporting
requirements are being met
0 Maintain accurate knowledge of industrial processes and their potential
impact on the POTW.
Control Authority compliance monitoring falls into two general categories:
0 Monitoring lUs and Their Wastewaters - This is achieved by inspections,
sampling, and flow measurement. Sample collection and flow measurement
must be performed with proper procedures if the results of the monitoring
program are to be valid or useful for purposes of compliance and
enforcement activities. Industrial user monitoring is generally
performed by the Control Authority and the industry (self-monitoring).
0 Monitoring the PCTW Treatment Plant - The Control Authority determines
impacts of industrial discharges on the POTW including assessment of
potential pass through or interference with treatment plant operations
or sludge disposal. This evaluation is supported by the results
obtained from POTW influent, effluent, and sludge sampling and analysis.
This data is critical to the development and continual re-evaluation
of the local limits and their ability to protect the POTW treatment
plant.
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The Control Authority has primary responsibility for taking appropriate
enforcement action against industrial users who fail to comply with pretreatment
standards and requirements. General types of enforcement mechanisms fall
into two categories:
0 Informal Actions
- Informal notice to industrial user (e.g., telephone call or meeting)
- Written notice of violation
- Establishment of a compliance schedule
0 Formal Actions
- Fines
- Civil suits
- Criminal suits
- Revocation of permit
- Termination of Service.
2.3.3 Recordkeeping and Reporting Requirements
The Control Authority and industrial users have several recordkeeping
and reporting responsibilities. The major requirements for each are described
in this section.
Notification to IU
The Control Authority must notify its industrial users of their obligation
to comply with federal and local pretreatment standards. The notification
should include:
0 A list of the applicable pretreatment standards and requirements.
0 A requirement for industrial users to sample their discharge(s) and
analyze for ttyose pollutants known or suspected to be in waste streams
that are limited by a standard. These results must be reported to the
Control Authority.
0 A statement that requires industrial users to submit compliance schedules
if they are not currently in compliance.
0 A specific deadline date for the submission of all information.
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These requirements are usually set forth in an appropriate control
mechanism such as a permit or other form of legally binding agreement between
the Control Authority and industrial user. The Control Authority should also
notify the lUs through written communications when various reports are due.
These reports include compliance schedule progress reports, final compliance
reports, self-monitoring reports, or other required submissions.
Control Authority Reports to Approval Authority
The Control Authority may be required to submit an annual report to the
Approval Authority which may contain the following information.
0 Status of IU compliance
0 Identification of enforcement actions taken against significant
violators
0 Status of general pretreatment program management.
These types of reporting requirements and the information to be included
in each report will typically be specified in the NPDES permit where the POTW
has a local program. These reports (normally required at least annually) will
usually provide important background information to the inspector performing
the PCI.
Industrial User Reporting Requirements
The Federal regulations require industrial users subject to categorical
pretreatment standards to submit various reports to the Control Authority.
The Control Authority is responsible for reviewing, evaluating, and responding
to these reports. These reports include:
0 Baseline Monitoring Reports (BMRs)
0 Compliance Schedule Progress Reports
0 Final 90-Day Compliance Reports
0 Periodic Compliance Reports
0 Notices of Slug Loading.
Baseline Monitoring Reports (BMRs). As a first step in applying pretreatment
standards, the Control Authority must have basic data about its industrial
dischargers that are subject to the standards. This includes information
describing the industry's operation, discharge flow, pollutant type and
concentration, whether the IU is in compliance with applicable regulations
and, if not, what the IU plans to do to come into compliance within the
required time period. The General Pretreatment Regulations, in 40 CFR Part
403.12(b), require every industrial user subject to a Categorical Pretreatment
Standard to submit this information in a report within 180 days after the
effective date of the applicable standard; this report is commonly referred
to as the baseline monitoring report (BMR). The BMR must contain the following
information:
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0 Name and address of the facility, and names of the operator and owners
0 List of environmental control permits held by the industrial user
0 Description of operations, including the.average rate of production,
SIC codes, and a schematic process diagram indicating discharge points
0 Flow and pollutant measurements
0 Certification by an authorized representative of the industry of
whether applicable pretreatment standards are being met, and if not, a
description of the additional operation and maintenance (O&M) or
pretreatment facilities that are needed to comply with the standards
0 A schedule by which the industrial user will provide the additional
O&M or pretreatment needed to comply with the applicable pretreatment
standards.
If an industrial user has already submitted this information during IWS
activities or in a permit application and this information is still current,
it need not be resubmitted in the BMR. The Control Authority may also require
noncategorical lUs (which must meet local standards instead of categorical
standards) to submit a similar report, as the information would be useful to
the Control Authority.
Compliance Schedule Progress Reports. An IU that is not in compliance with
discharge standards and other limitations as indicated in its BMR must develop
and submit a compliance schedule of actions enabling it to meet the applicable
discharge limitations. , Section 403.12(c) of the General Pretreatment Regula-
tions describes the conditions for industrial users required to submit
compliance schedules.
90-Day Compliance Reports. This report specifies whether or not the IU has
achieved compliance with the applicable Categorical Pretreatment Standard.
As specified in Section 403.12(d) of the General Pretreatment Regulations,
this report is required from the industry within ninety days following the
compliance date of the standard and must include:
0 Sampling data for all regulated pollutants
0 Flow measurements for regulated wastewaters
0 Statement of compliance
0 Where necessary, a statement as to whether additional changes or
equipment is needed to obtain compliance.
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Semi-Annual Compliance Reports. Section 403.12(e) of the General Pretreatment
Regulations requires industrial users subject to categorical standards to
report the results of self-monitoring of their regulated waste discharges to
the Control Authority ate least semi-annually, usually during the months of
June and December unless otherwise specified by the Control Authority. The
reports must indicate the type and concentration of pollutants and include a
record of estimated or measured average daily flows.
Notices of Slug Loading. Industrial users are required [40 CFR 403.12(f)] to
notify the POTW immediately of any slug loading (e.g., spill, pretreatment
system malfunction, etc.) from the user to the POIW. Immediate notification
is usually by telephone, and a written follow-up report is usually required
within five calendar days.
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3. PCI AND AUDIT PROCEDURES
3.1 INTRODUCTION
This Chapter provides guidance for those responsible for conducting pretreat-
nent audits and PCI*?. In particular, the purpose of this chapter is to highlight
for the auditor or inspector those general procedures that will result in a
well-organized and thorough review. The basic procedural elements are similar
for an audit and a PCI, consisting of:
Preparation
Conducting the audit/PCI
Documentation and report preparation
Follow-up response to Control Authority
Data entry into PCS.
Each of these elements is discussed below in relation to both the audit and the
PCI. Although a PCI is usually performed in conjunction with an NPDES inspection,
the PCI includes some additional components and procedures which are not covered
in other NPDES guidance. These are highlighted in the discussion below.
3.2 PREPARATION
Preplanning is necessary to ensure that the audit or inspection is properly
focused and is conducted smoothly and efficiently. This planning should include
the following:
Review of the Control Authority's program status and background information,
Development of an audit/inspection plan,
Notification to the Control Authority (optional, but recommended),
Equipment preparation, and
Coordination with Region and State.
3.2.1 Review of the Control Authority's Program Status
Collection and analysis of readily available background information on the
Control Authority will aid in the effective planning and overall success of the
PCI or audit. Materials obtained from Approval Authority files such as the
original pretreatment program application, POTW compliance history, annual reports,
pretreatment program fact sheet, previous audit or PCI results, etc., will enable
the reviewer to become familiar with the Control Authority's program. Reviewing
the pretreatment program status and background information will allow Approval
Authority personnel to identify any key issues before the site visit and to
utilize the time spent during the site visit efficiently by requesting only
updates or verification of previously-submitted information.
Appendix C contains a fact sheet which can be used to summarize background infor
mation that should be available to the auditor or inspector prior to conducting the
site visit. This information may be located throughout Approval Authority files or
may already be summarized in a similar format as the result of a previous audit or
PCI. Completion of a fact sheet in preparation for an audit is strongly recomended.
A fact sheet has been incorporated in the audit checklist as Section II. The fact
sheet should be updated each time that an audit is performed. For a PCI, on the
other hand, the inspector should limit preparation to review of an already-completed
fact sheet, if possible. The use of a fact sheet facilitates a comparison of the
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POTW's approved program requirements with the POTW's operating practices. The
fact sheet summarizes the carmitments made by the POTW in its approved program
submission and any pretreatment requirements in the POTW's permit or other enforce-
able documents. Thus, the fact sheet provides a basis for determining Whether
the POTW is implementing its pretreatment program as approved.
3.2.2 Development of an Audit or Inspection Plan
This manual sets forth recommended procedures and checklists for conducting
the PCI or aud|t. Should it be necessary for the auditor or inspector to deviate ,
from the suggested approach, development of a written plan is recommended. The
plan should define the objectives of the activity, the tasks required to fulfill
the objectives, and the schedule. For example, sampling of the POTW treatment
plant or selected lUs will not be a regular part of an audit or PCI, but may be
necessary in some cases to verify such things as POTW compliance with sludge
disposal regulations or IU compliance with applicable discharge limitations. An
audit/inspection plan generally addresses the following items:
0 Objectives
- What is the purpose of the audit or inspection (i.e., investigative,
enforcement action support, or problem identification or correction)?
- What is to be accomplished (e.g., area of the Control Authority's
program to be evaluated or specific concerns to be addressed)?
8 Tasks
- What information must be collected to fulfill the objectives?
- What tasks are to be completed?
0 Procedures
- What procedures are to be used?
- Will the audit/PCI require special procedures?
0 Resources
- What will be the time requirements and order of activities?
- What will be the milestones?
8 Coordination
- What coordination with laboratories or other regulatory agencies is
required?
These issues are addressed by this guidance for the suggested approach.
3.2.3 Notification to the Control Authority
Notification is recommended so Control Authority personnel are available at
the time of the audit or inspection. However, Approval Authorities may find prior
notification less advantageous for PCIs than for audits. Notification, if pro-
vided, should be written. The inspector/auditor should request that the infor-
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nation necessary for the evaluation be compiled or developed prior to the site
visit. Information that may be requested includes a list of all significant
industrial users (SIUs) that are currently in nonccmpliance, the duration of
noncompliance and description of the action(s) the POTW has taken against each
IU to secure compliance.
In addition, the notification should request information regarding on-site
safety requirements in the event a facility inspection or sampling is performed
during the visit/ especially when an IU will be sampled.
3.2.4 Equipment Preparation
Some safety equipment may be required at certain industries. In general,
only safety glasses will be needed, but in some instances hard hats and/< : safety
shoes may also be necessary. The Control Authority inspection personnel should
know what equipment will be required and either the POTW or the industry may have
equipment available for the use of the inspection team.
In most cases, safety and sampling equipment will not be required unless the
review of the program status or background information indicates a need for
sampling of the POTW or selected Ills. In the event sampling is necessary, the
appropriate equipment should be prepared according to the particular sampling
needs. Consult the standard procedures in the EPA NPDES Compliance Inspection -
Manual for more specific information.
3.2.5 Coordination with Region and State
Regardless of whether the State or EPA is the Approval Authority, both
parties may wish to be present at the audit/PCI. Adequate time and notification
should always be given to encourage both State and EPA staff participation. When
the State is the Approval Authority, the State should play the lead role in
conducting the audit/PCI. Regions should accompany State personnel on initial
audits/PCIs and provide only periodic review after the Regions are satisfied with
the States' performance.
3.3 ENTRY PROCEDURES
3.3.1 Arrival
Arrival at the facility should be during normal working hours unless
circumstances require otherwise. The pretreatment program contact should be
located immediately upon arrival. If the review team is at the Control
Authority to perform other NPDES inspections, each program contact or official
should be informed of the team's arrival.
3.3.2 Presentation of Credentials
When the pretreatment program contact has been located, the review team
members should be introduced and present their credentials. In the case of a PCI,
the credentials must be presented to the pretreatment program contact, even if
the inspector has already done so in the context of another NPDES inspection
conducted at the Control Authority that same day.
3.3.3 Consent
For a PCI, specific consent to conduct the PCI should be obtained from the
oretreatment program contact in order to avoid possible confusion between the
various inspections conducted at the Control Authority.
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3.3.4 Problems with Entry or Consent
The auditor/inspector should respond to problems with entry or consent in
the nanner detailed in NPDES inspection guidance.
3.4 OPENING CONFERENCE
Once credentials have-been presented and legal entry has been established,
the review team can proceed to outline the audit/inspection plans with the pre-
treatment program contact. The opening conference should include discussion of
the purpose of the visit, the authorities under which the audit/inspection is
being conducted, and the procedures that will be followed. In addition to the
information that is normally discussed with facility officials during the opening
conference of an NPDES inspection, the PCI inspector should discuss any considera-
tions unique to a PCI. This conference should include at least an overview of
the checklist, the reviewer's intent to review files of specific lUs, and any
other elements necessary to make the determinations required by the checklist and
the audit/PCI plan.
3.5 DOCUMENTATION
Documentation is a general term referring to all print and mechanical media
produced, copied, or taken to provide evidence of suspected violations or to support
the conclusions of the audit/inspection. Types of documentation include the
completed audit or PCI checklist, field notebook, statements, photographs, drawings
and maps, printed matter, mechanical recordings, and copies of permits and records.
All PCI documentation should be obtained in the same manner as other NPDES inspections.
The auditor/inspector should provide strong documentary support of discrepancies
uncovered during an audit/inspection. Documentation serves to "freeze" the actual
conditions existing at the time of the audit or inspection so that evidence may be
examined objectively at a later date by permits and compliance personnel.
The basis of all documentation relating to the POTW's pretreatment program is
the checklist which provides accurate and inclusive documentation of all pretreat-
ment activities. It will form the documentary basis for all determinations made
by the reviewer. The reviewer should document the source(s) of the response to
each question in the checklist.
3.6 TOUR OF THE POTW (Optional)
Since an audit (or, in some cases, a PCI) may be conducted independently of
an NPDES inspection, the review team may wish to tour the treatment plant to
observe plant operations and identify any visible effects of industrial discharges
on unit processes. During the tour, the team should:
0 Evaluate laboratory capabilities
0 Note any unusual wastewater characteristics or plant operations which
could be the result of industrial discharges, such as:
- Unusual odor
- Unusual discoloration
- Excessive/unusual corrosion of equipment, structures
- Excessive oil and grease
- Biological upsets (excessive foaming, sludge bulking, excessive
trickling filter sloughing, low gas production in digesters)
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- By-passing of slug loads/accidental discharges of toxic or high
strength wastes
0 Note any processes/equipment not on-line, and causes
0 Note sampling points.
If unusual conditions are noted which are not representative of normal, well-
run operations, the team should:
0 Photograph the unusual conditions (if possible)
0 Discuss observations with POTW staff
1 ° Determine the history and cause of the unusual condition(s)
0 If industrial discharges are the suspected cause, attempt to identify the
specific industry(ies)
- Determine if industry is in compliance with discharge limits and
requirements
0 Discuss corrective measures, if needed
0 Note recommendations for follow-up (possibly schedule an NPDES inspection).
3.7 VISITS TO LOCAL INDUSTRIES (Optional)
Accompanying POTW staff on a visit to a local industry is a valuable source
of information about the POTW's inspection procedures and its knowledge of its
lUs. It is important to converse with POTW staff actually involved in IU inspec-
tions, rather than the pretreatment program director. If an IU is selected for
a.visit, it is recommended that the lU's file be reviewed during the PCI/audit
in order to determine whether the information contained in the files is consistent
with the observations made during the IU visit. The industry visits may be used
to:
0 Evaluate POTW procedures for:
- Site inspection
- Sampling of industrial process wastestreams
- Gaining access to an industrial site
- Documenting a sampling event
0 Evaluate POTW inspectors'
- Knowledge of categorical standards, the location of regulated process
lines, and industrial compliance status
- Relationship with industry officials
- Safety precautions
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0 Provide support to the POTW's requests for submission of industrial reports
and compliance with discharge standards
° Inform industries of EPA's or the State's continued oversight role in
the pretreatment program.
The procedures for industry visits are flexible. They may be conducted in
a very structured manner, and directed toward specific problems, or the Approval
Authority may wish to simply set ground rules and then follow the POTW inspector's
lead. They may also simply evaluate the communication between the POTW and the
industry. The approach must be determined on a case-by-case basis. The approach
should be discussed with the POTW personnel prior to the IU visit.
3.8 CLOSING CONFERENCE
Control Authority personnel are usually anxious to discuss the findings of
the audit/inspection prior to the review team's departure. A closing meeting or
conference should be held for the presentation and discussion of preliminary
findings. This closing meeting is also an ideal time for final questions and
details to be resolved. The inspector/auditor should be prepared to discuss
general follow-up procedures (transmittal of findings to Approval Authority
personnel, etc.) that will occur. The final meeting should be used as an
opportunity to request the compilation of data or information that was not
available at the time of the visit. Closing conference discussion should be
guided by rules established by the Regional Administrator or State Director
regarding permittee contacts in the Region/State.
3.9 REPORT PREPARATION
The adequacy of follow-up to correct problems or deficiencies noted during a
PCI or audit depends in large part on the report package prepared by the inspector.
The material must be organized and arranged in a manner that will allow compliance
and permits personnel to make maximum use of the information.
The objective of the report is to organize and coordinate all relevant
information and evidence in a comprehensive, usable manner. To meet this objective,
information in an audit or inspection report must be:
0 Accurate. All information must be factual and based on sound inspection
practices. Observations should be the verifiable result of firsthand
knowledge.
° Relevant. Information should be pertinent to the subject of the report.
0 Comprehensive. Suspected violations should be substantiated by as much
factual, relevant information as is feasible to gather.
0 Coordinated. All information pertinent to the subject should be organized
into a complete package. Documentary support (e.g., photographs,
statements, sample documentation, etc.) accompanying the report should be
clearly referenced to the checklist so that anyone reading the report
will get a complete, clear overview of the situation.
Although specific information requirements for an audit or inspection report
will vary, most reports will contain the same basic elements:
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0 Completed Form 3560-3 (or equivalent)
0 Copy of completed checklist
0 Supplementary narrative information
• Documentary support.
Form. 3560-3. theNPDES.Compliance Inspection Report Form 3560-3 (see Appendix D)
is a standard cover sheet that is completed after an NPDES inspection and
incorporated into the final inspection report. This form accotimodates a pre-
treatment code to indicate that an audit or PCI was performed. This form or its
equivalent must be prepared to provide for data entry into PCS. Instructions
for completing this form are contained in memoranda from J. William Jordan and
Martha G. Prothro which are found in Appendix A.
PCI and Audit Checklists. The checklists are provided in Chapters 4 and 5. Each
checklist gives a detailed item-by-item discussion of the information that must
be considered when planning and conducting a PCI or audit. The checklist will
aid the reviewer in performing the PCI or audit and will serve as the basic
documentation of results.
Supplementary Narrative Information. Supplementary narrative information will
generally be included on the checklist. When a narrative report is necessary to
describe results more fully; the contents of the supplemental report should focus
on supporting or explaining the findings in the checklist and may include
recommendations for follow-up actions.
Documentary Support. All documentation that is produced or collected to provide
evidence of suspected violations should be included as a part of the checklist.
Types of documentation include statements, photographs, drawings and maps, printed
matter, mechanical recordings, and copies of permits and records. A specific
example of important documentation might be a series of repeated violations as
documented in an industrial user's file, yet a complete lack of any compliance
action by the POTW. Copies of the monitoring results will document that the
repeated violations existed and the absence of any documented follow-up action
by the POTW will indicate the Control Authority's neglect.
3.9.1 Schedule for Report Submission
The report containing the results of the PCI or audit should be submitted to
the appropriate permits and compliance personnel. A complete report should be
submitted within 30 days if sampling was not performed during the site visit.
Where sampling was included as part of either the audit/PCI or the NPDES
portion of the inspection, a complete report should be submitted within 45 days.
3.10 DATA ENTRy INTO PCS
As indicated previously, the PCI or audit report must include Form 3560-3
and the information must be entered into PCS to receive credit in the Strategic
Planning and Management System (SPMS). If the State enters data into PCS directly,
a form equivalent to Form 3560-3 may be used if it at least contains the same
data elements as Form 3560-3. In either case, data entry of information related
to the PCI/audit should be completed within 90 days of the date of the event.
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3.11 FOLLOW-UP RESPONSE TO THE CONTROL AUTHORITY
3.11.1 PCI
After the compliance evaluation or enforcement office receives the conplete
PCI report from the inspector, that office should review the PCI report to determine:
1) whether the PCI identified violations of applicable pretreatment regulations and
pretreatnent-related NPDES permit requirements, and 2) whether other deficiencies
exist which are not in violation of pretreatment regulations or NPDES permit re-
quirements but render the Control Authority's pretreatment program less effective.
Unless violations or deficiencies are noted during the PCI which are considered
to be of such significance that formal enforcement action should be undertaken
against the Control Authority, ccnpliance personnel should forward to the Control
Authority a copy of Section IV (Summary Evaluation Section) of the completed PCI
checklist and a letter listing the Control Authority's violations or deficiencies
(if any) noted during the PCI. The compliance person and the inspector should
jointly review Section IV of the completed PCI checklist and the follow-up letter
prior to mailing.
The follow-up letter should clearly distinguish between violations of
regulatory and/or permit requirements as compared to deficiencies which should
be remedied to improve pretreatment program implementation. This follow-up
letter should request that the Control Authority submit a written description-of
proposed corrective actions within 15 days of receipt of the letter. Appendix B
presents a sample of such a follow-up letter.
However, if the PCI does reveal significant violations which warrant formal
enforcement action against the Control Authority, it is strongly recommended that
neither the follow-up letter as described above nor the summary evaluation be
sent to the Control Authority. Instead, a formal enforcement approach (e.g.,
Administrative Order, warning letter, Consent Agreement, etc.) should be followed.
Upon review of the information contained in the PCI report, compliance personnel
may identify a need to obtain additional information from the Control Authority
by such means as 308 letters, audits, additional NPDES inspections, etc., before
making a decision regarding the need for enforcement action. In such instances,
a follow-up response to the Control Authority beyond requests for additional
information may be withheld at the discretion of compliance personnel, pending
the receipt of such additional information.
3.11.2 Audit
As with the PCI, a letter transmitting the findings and recommendations of
the audit should be sent to the Control Authority. It should be sent to the POTW
manager (e.g., Director of Public Vforks), mayor or city manager with a copy sent
to the local pretreatment contact. The letter should clearly distinguish between
violations of regulatory and/or permit requirements as compared to deficiencies
which should be remedied to render the Control Authority's pretreatment program
more effective. The sample follow-up letter in Appendix B is equally applicable
to a PCI or an audit.
When it is sent to the POTW, the transmittal letter may be accompanied by a
completed copy of the audit checklist and/or a narrative report. The narrative
report would critically evaluate each element of the program as it was assessed
in the checklist, based on both the program as it was approved and the effectiveness
of the element as it has been implemented. The Approval Authority has flexibility
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in deciding Whether to send the entire checklist, just the sumrary and evaluation
portion of the checklist, or a narrative report to the POTW. In many cases, a
letter to the PO1W containing the audit findings and recommendations may be sufficient.
Depending on the findings and observations, other follow-up activities may
be necessary, such as:
0 Issue an administrative order requiring the POTW to respond to the audit
findings within a definite tine period
0 Modify the NPDES permit to include a compliance schedule containing
specific conditions and requirements
0 Modify the approved program
0 Schedule future audits or pretreatment compliance inspections to determine
if audit findings have been implemented
0 Initiate enforcement action against the POTW and/or industrial users.
There is a need for close coordination between pretreatment auditors and
pretreatment compliance inspectors to avoid duplication of efforts. Because of the
subjectivity inherent in any review, auditors and inspectors should work very
closely together and discuss their findings before an official report is forwarded
to the POTW, particularly when separate visits are planned by each in the same
year. Every attempt should be made to avoid the possibility of conflicting
reports being filed which would be misleading to the POTW as well as potentially
adversely affecting any enforcement action.
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4. PRETREATMENT COMPLIANCE INSPECTION (PCI) CHECKLIST
The PCI checklist was developed primarily to assist NPDES inspectors in
performing the inspection,- but- will also serve as the documentation for PCI
findings. The checklist is organized into four sections:
0 Control Authority Background Information
0 Evaluation of Compliance Monitoring and Enforcement - Control Authority
Personnel Response
0 Evaluation of Compliance Monitoring and Enforcement - IU File Review
0 Summary Evaluation.
Overall, the checklist questions are designed to be self-explanatory, which
is particularly helpful to NPDES inspectors who are just being introduced to
the PCI. The first Section represents a summary of background information.
The second Section of the checklist relies upon Control Authority personnel
responses which would be given to the NPDES inspector during an informal
interview. The third Section of the checklist is completed based on an
intensive review of selected industrial user files. The focus of Section II
is to evaluate a Control Authority's efforts to determine and ensure industrial
user compliance with pretreatment standards and requirements and to ascertain
the level of information which management has about the pretreatment program.
The file review found in Section III provides the opportunity to verify
information provided during the interview and to assess the effectiveness of
the procedures used to manage the pretreatment program. The file review
covers:
0 Industrial user inspection frequency
0 Control Authority sampling of industrial user effluents
0 Status of IU permits or other control mechanisms
0 Industrial user self-monitoring and reporting frequency
0 Nature and frequency of violations
0 Type and effectiveness of Control Authority compliance actions
0 Overall adequacy of Control Authority files and documentation.
The fourth Section of the PCI checklist represents a sunmary evaluation which
the inspector will complete in conjunction with EPA Regional or State pretreat-
ment program staff. It includes needed follow-up actions which are identified
as either required or recommended.
The inspector should have a basic knowledge of the Control Authority's
approved program and NPDES permit requirements relating to pretreatment prior
to conducting the PCI. Additionally, the inspector should be aware of the
Control Authority's treatment facilities and compliance history. The sources
of this background information will include EPA and State files, the Control
Authority's pretreatment program submission, annual reports, previous audits
or PCIs, etc. In most cases, important background information should have
been extracted from these various sources and summarized on a "Fact Sheet",
particularly in those cases where a pretreatment program audit has been
previously performed. The "Fact Sheet" has been recommended for completion
prior to the first pretreatment program audit and should be updated on
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subsequent audits. It can also be updated as a result of a PCI at the
discretion of the Region or State. If the "Fact Sheet" has not been coirpleted
previously/ the inspector may wish to complete it prior to conducting the
PCI. Appendix C of this guidance contains the "Fact Sheet" which can be used
to record specific information'about the Control Authority.
In the following pages, the discussion of the intent and use of the PCI
checklist appears on the left hand pages (even numbered) with the corresponding
portion of the checklist appearing on the right hand pages (odd numbered).
4.1 CONTROL AUTHORITY BACKGROUND INFORMATION
Section I of the PCI checklist summarizes key information about the
Control Authority and its pretreatment program. Section I should be completed
before the inspection using information from the POTW program file and/or
the Fact Sheet which may have been prepared previously. The information should
then be confirmed during the conference. Additionally, the inspector should
consult pretreatment program personnel to determine if the scope or focus
of the PCI should be modified to address specific compliance questions.
4.1.1 GENERAL CONTROL AUTHORITY INFORMATION
Part A summarizes background information about the Control Authority,
including NPDES permit information, previous audits or PCIs and the Control
Authority's pretreatment program contact. Where applicable, the NPDES
permit language and Approval Authority enforcement documents (administrative
order, consent decree, etc.) would be attached to the completed PCI checklist.
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CONTROL AUTHORITY PRETREATMENT COMPLIANCE INSPECTION (PCI) CHECKLIST
Date(s) of PCI:
Inspector(s) Name(s):
Control Authority Representatives:
SECTION I: CONTROL AUTHORITY BACKGROUND INFORMATION
A. General Control Authority Information
1. Control Authority Name:
2. Mailing Address:
3. Is the Control Authority currently operating under any consent
decreef administrative order or other enforcement action that
specifies pretreatment requirements or affects the Control
Authority's pretreatment program? Yes No
If yes, attach a copy.
4. Date of last PCI/Audit: Circle Type: PCI Audit
5. Date of last 'Control Authority Report to Approval Authority:
6. Pretreatment Contact Name:
Title:
Telephone:
Section I Completed By: Date:
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4.2 COMPLIANCE MONITORING AND ENFORCEMENT PROCEDURES—CONTROL AUTHORITY
PERSONNEL RESPONSE
Sections II and III of the PCI checklist primarily deal with the Control
Authority's application of pretreatment standards and evaluation of the
Control Authority's compliance and enforcement activities. Section II is
completed from direct.responses by Control Authority personnel, while Section
III will entail a detailed review of selected industrial user files to evaluate
the effectiveness and appropriateness of the Control Authority's:
0 Control mechanisms
0 Inspection and monitoring procedures
0 Compliance and enforcement procedures.
4.2.1 Control Authority Pretreatment Program Overview
The inspector will obtain background information about the Control
Authority's pretreatment program in Part A, prior to discussion about the
Control Authority's compliance monitoring and enforcement program. If the
Approval Authority desires more detailed information about the Control
Authority's program, the "Fact Sheet" in Appendix C may be used and verified
during this preliminary discussion.
4.2.2 Control Authority Pretreatment Program Modifications
Part B requires the inspector to inquire about any significant changes
made to the Control Authority's pretreatment program since approval (or the
last PCI or audit, whichever occurred last). The inspector should briefly
describe these changes on a separate sheet and indicate on the checklist if
the proposed changes were submitted to the Approval Authority for approval.
Please note that the inspector should advise the Control Authority that all
program modifications must be submitted to the Approval Authority for approval.
Listed below are some examples of changes which a Control Authority might
make to its approved program:
0 Legal Authority
- modified sewer use ordinance
- incorporation of new jurisdictions/interjurisdictional agreements
0 Control Mechanism Modification
- modified provisions of IU permits
0 Local Limits
- revision of existing local limits
0 Resources
- change in personnel commitments
- budget reallocations.
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SECTION II. COMPLIANCE MONITORING AND E3SIFORCEMENT--CONTROL AUTHORITY
PERSONNEL RESPONSE
A. Control.Authority Pretreatment Program Overview
1. How many industrial users (lUs) are currently identified by
the Control Authority in each of the following groups?
industries subject to categorical pretreatment standards
significant* noncategorical industrial users
other noncategorical industrial users
TOTAL
2. The Control Authority has defined "significant" industrial user
to mean:
3. Approximately what percent of the total wastewater flow to the
POTW treatment plant(s) is from the industrial users?
4. During the past year, has the Control Authority experienced
any sludge contamination or problems in the collection system
or at the treatment plant created by discharges from nondomestic
sources?
Yes No
If yes, describe:
B. Control Authority Pretreatment Program Modifications
1. Has the Control Authority made any changes to its
pretreatment program from that stated in its approved
pretreatment program submission, since the last PCI or audit?
(Check below those program elements that have changed
and briefly describe each on a separate sheet.)
Submitted for
Program Element Changed Approval
Yes No
Legal Authority
Control Mechanism Implementation
Local Limits
Inspection and Monitoring Program
Enforcement Program
Resources
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4.2.3 Control Authority Inspection and Sampling of Industrial Users (IUsj
The General Pretreatment Regulations [40 CFR Part 403.8(f)(2)(v)] require
Control Authorities to carry out inspection and sampling procedures to determine
whether IUs are in compliance or noncompliance with applicable pretreatment
standards and requirements. Control Authority inspections and sampling serve
specific, individual purposes. Sampling, and flow measurement if necessary,
are used to determine if an industry is in compliance with pollutant limita-
tions at a given time. A properly conducted industrial inspection should
include a review of records and the treatment facility and provides a different
assessment for the Control Authority such as:
0 Determination of industrial process changes that may impact pollutant
load
0 Review of IU monitoring records
0 Operational status of pretreatment equipment
0 Evaluation of the potential for spills
0 Development of a working rapport with the IU.
This portion of the checklist evaluates whether the Control Authority has
performed inspection and sampling at each Significant Industrial User (SIU)
consistent with its approved progam and/or NPDES permit and whether it has
inspected and sampled at least once a year. (EPA recommends that each SIU be
inspected and sampled at least once a year.) Industries whose discharge is
likely to interfere with treatment plant operations or ones with a poor
compliance history should be on more frequent inspection and sampling schedules
than those SIUs that discharge compatible wastes or demonstrate continued
compliance.
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C. Control Authority Inspection and Monitoring of Industrial Users
1. Was each categorical and noncategorical significant industrial
user inspected by the Control Authority:
a) At least once in the past year? Yes No
b) In accordance with the frequency required
in the NPDES permit or approved program?
Yes No
2. Was each categorical and noncategorical significant industrial
user sampled by the Control Authority:
a) At least once in the past year? Yes No
b) In accordance with the frequency'required
in the NPDES permit or approved program?
Yes No
3. What percentage of SIUs were not sampled or inspected at
least once in the past year?
Total Number of SIUs Sampled Inspected
[At the discretion of the Approval Authority and the NPDES
inspector, the names of significant industrial users that have
not been sampled and inspected within the last year can be
attached to this PCI.]
4. Does the Control Authority's basic inspection of an industrial
user consist of:
0 Inspection of the manufacturing facilities? Yes No
0 Inspection of the pretreatment facilities? Yes No
0 Inspection of chemical storage areas? Yes No
0 Inspection of chemical spill prevention areas? Yes No
0 Inspection of hazardous waste storage areas? Yes No
0 Inspection of the sampling procedures? Yes No
0 Inspection of laboratory procedures? Yes No
0 Inspection of the monitoring records? Yes No
5. Are categorical lUs required to perform sampling and submit
self-monitoring reports as follows:
a) At least twice per year? Yes No
b) In accordance with the frequency in the approved program or
NPDES permit? Yes No
6. Are significant noncategorical lUs required to perform sampling
and submit self-monitoring reports? Yes No
What is the range of sampling frequencies?
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4.2.4 Control Mechanism Evaluation
Section 403.8(f)(2)(iii) of the General Pretreatment Regulations requires
Control Authorities to have-the legal authority to control each Ill's discharge
through some type of "control mechanism." The most commonly used type of
control mechanism is the industrial user permit, although the Control Authority
may choose to use some other mechanism such as a contract or an ordinance.
Like the NPDES permit, the IU permit is tailored to each industrial user and
specifies pretreatment standards and requirements with which the IU must
comply. This portion of the checklist examines whether all significant
industrial users (SIUs) are covered by a control mechanism and whether the
Control Authority has incorporated Categorical Pretreatment Standards as they
are promulgated. In Section III, the file review, the inspector will actually
examine the control mechanism to see whether it covers the essential elements.
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D. Control Mechanism Evaluation
1. Is each significant industrial user covered by an existing,
unexpired permit-, contract, or other control mechanism?
Yes __ No
2. If not, what percent of the SIUs are not covered by a control
mechanism?
Briefly explain why all SIUs are not covered by a control
mechanism:
3. Are SIU permits modified to reflect changes to the Categorical
Pretreatment Standards and the General Pretreatraent Regulations
within three months of the change?
Yes No
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4.2.5 'Enforcement Procedures
In the event of IU noncompliance, the Control Authority must take necessary
action to bring an IU back into compliance within the shortest possible time
frame. Generally, this portion evaluates whether the Control Authority does
the following:
0 Has reviewed IU self-monitoring reports to determine compliance
status
0 Has a current knowledge of the compliance status of all IUs
0 Has taken effective enforcement action/ and
0 Has established an enforcement response guide.
The Control Authority must have procedures to review all data that
relates to the compliance of its IUs. This review must compare information
from self-monitoring, inspection, and compliance schedule progress reports to
the appropriate requirements. The Control Authority must know when reports
are due, what monitoring is required, and what results are acceptable. The
inspector does not need to know all of these details, but he does need to
determine whether the appropriate Control Authority personnel know and
understand these requirements.
The Control Authority should have procedures for responding to IU
violations. The "Pretreatment Compliance Monitoring and Enforcement Guidance"
recommends that the Control Authority develop an enforcement response guide
which identifies the possible enforcement responses for a particular violation.
While all Control Authorities may not yet have developed such a document, the
Control Authority should have developed an approach to determining appropriate
enforcement response which provides for escalation when compliance is not
achieved.
This checklist uses the definition of "significant noncompliance"
identified in the "Pretreatment Compliance Monitoring and Enforcement Guidance"
as the basis for measuring performance. That definition has not yet been
finally adopted, but a final definition will be in place by the beginning of
FY 1987. Where the Region/State currently uses a different definition for
identifying that noncompliance which is considered to be significant, the
NPDES inspector may apply the Regional/State definition.
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E. Enforcement Procedures
1. Does the Control Authority routinely evaluate SIU self-monitoring
reports and compare results to the applicable pretreatment
standards and pretreatment conditions contained in the control
mechanism? Yes No
2. Approximately what percentage of all IDs which needed to install
pretreatment technologies to meet applicable pretreatment
standards have done so? %
3. Indicate the percent of SIUs that are in significant noncompliance
(SNC) with the following at the time of the PCI:
0 Applicable Pretreatment Standards
0 Self-Monitoring Requirements
0 Reporting Requirements •
4. Approximately what percent of all the SIUs were subject to any
kind of enforcement action during the last 12
months?
5. What types of enforcement actions (informal and formal) has the
Control Authority used?
Type of Action Type of Action Used
Verbal warning
Written notice or letter of violation
Issue compliance schedule
Revoke permit
Consent decree
Civil penalties (fines)
Criminal penalties
Termination of service
Other (Specify)
6. Of those SIUs identified as being in significant noncompliance
in the last annual report, identify all SIUs who have not returned
to compliance as of the time of the inspection, how long since
they were first identified as being in significant noncompliance,
what enforcement actions have been taken to return these SIUs
to compliance, and when such actions were taken. (If the annual
report did not include such a list, identify all SIUs now in
significant noncompliance, the period of time since they were
identified as in significant noncorapliance, the enforcement actions
which have been taken, and when those actions were taken.)
7. Does the control authority have procedures that define the appropriate
enforcement response and time frames to initiate the response for
different types and patterns of IU violations.
Yes No (If yes, attach a copy.)
8. Has the control authority published the annual list of
significant violators. Yes No (If yes, obtain a copy.)
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4.2.6 Carpiiance Tracking
Part F of Section II is intended to determine if the Control Authority
has mechanisms in place *o regularly track and document the compliance status
of its industrial users.
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Compliance Tracking
1. Does the Control Authority maintain an individual record or
file on each significant industrial user which includes
complianee information (i.e., monitoring data, IU reports,
notices of violation, etc.)?
Yes No
2. Does the Control Authority maintain a management system
(manual or computerized) to track IU compliance status?
Yes No
Section II Completed By: Date:
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4.3 COMPLIANCE MONITORING AND ENFORCEMENT - IU FILE EVALUATION
This Section of the PCI checklist will help the inspector to evaluate
the validity of the data developed thus far in the inspection by verifying
whether or not the prescribed procedures have been followed in the case of a
particular industrial user. The inspector will select a random but represen-
tative number of significant industrial user files to perform this evaluation.
The inspector should review at least five SIU files or 10 percent of the total
number of SIU files. At least two of the files reviewed should be for cate-
gorical lUs and at least 2 should be SIUs identified as being in significant
noncompliance. In the case of large Control Authorities, review of 10 SIU
files will probably be adequate instead of 10 percent. Conversely, for small
Control Authorities there may be less than five SIUs; in this case, it is
suggested that all the SIU files be reviewed.
Complete and current industrial user files should at least contain
copies of the following information:
0 IU' permit application
0 Fully executed and current IU discharge permit or other appropriate
control document
0 IU reports (i.e., baseline monitoring report)
0 On-site inspection reports
0 Monitoring results (both Control Authority and IU self-monitoring)
0 Compliance schedule, if applicable
0 Telephone log
0 All correspondence between the Control Authority and IU, including
notices of violations, enforcement actions, etc.
From this information, the inspector can assess the adequacy of the
Control Authority's monitoring program, assess the compliance of selected
industrial users and determine if the Control Authority's pretreatment program
is being effective 'in identifying noncompliance and achieving IU compliance.
This file review will allow the inspector to:
0 Evaluate the Control Authority's control mechanism
0 Determine if pretreatment standards are being properly applied to
lUs
0 Assess the Control Authority's monitoring and inspection program
(i.e., frequency, completeness, documentation)
0 Determine whether the Control Authority is responding to noncompliance
on a timely basis.
0 Assess the compliance of specific lUs with applicable pretreatment
standards
d Evaluate the Control Authority's overall recordkeeping system, and
0 Collect documentation on IU noncompliance or situations where the
Control Authority is not exercising adequate compliance/enforcement
response.
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The checklist provides the inspector with specific questions to determine
the adequacy of the Control Authority's activities as demonstrated by the
industrial user files. If the SIU files do not document a Control Authority's
monitoring and inspection activities/ it is possible that the Control Authority's
efforts might be misrepresented by the files. This will not normally be the
case, but may be an area for discussion in the close-out interview. This
Section allows the inspector to record his findings on 5 IU files. Additional
copies of this Section of the checklist may be used where more than five
files will be reviewed. Appropriate narrative comments should be recorded on
the supplemental comment sheet with the industry name and address.
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4.3.1 File Contents
The Control Authority must maintain complete and accurate files on each
SIU to effectively track" and document compliance history. At all times
Control Authority personnel must have ready access to well-organized
information. For each selected SIU file, the NPDES inspector should find each
of the items shown on the checklist in Part A.
4.3.2 Control Mechanism Evaluation
Each SIU permit or other control mechanism should contain requirements
that are tailored to the SIU. The NPDES inspector.will evaluate the control
mechanism and determine whether it contains most of the essential elements of
an effective control mechanism.
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SECTION III: COMPLIANCE MONITORING AND ENFORCEMENT - IU FILE EVALUATION
The inspector should select a representative number of significant
industrial user files to perform the file evaluation. The inspector
should review at least five SIU files or 10 percent of the total number
of significant industrial- users. At least 2 of the files reviewed
should be for categorical.IUs and at least 2 should be SIUs identified
as being in significant noncorapliance. In the case of large Control
Authorities, review of 10 SIU files will probably be adequate instead
of 10 percent. Evaluate the contents to determine if the appropriate
response to each of the following questions is yes (mark with an "X")
or none or no (mark with an "0"). Numerical responses are also required
in some cases. Appropriate narrative comments should be recorded in
Section F.
FILE EVALUATION CRITERIA File 1 File 2 File 3 File 4 File 5
A. File Contents
1. Does the IU file contain:
a) Completed IMS questionnaire?
b) IU permit application?
c) IU reports (BMR, 90 day
report, etc.)?
d) Discharge permit?
e) Sampling results?
f) Chain of custody forms?
g) IU self-monitoring results?
h) Correspondence?
i) Telephone log?
j) Inspection Report(s)?
k) Is the IU in Compliance?
B. Control Mechanism Evaluation
1. Is the IU discharge permit,
contract, etc. current
(unexpired)?
2. Does it contain applicable
discharge limitations?
3. Are types of samples (grab or
composite) for self-monitoring
specified?
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4.3.3 IU Compliance Evaluation
The review of an IU file will allow the inspector to evaluate the frequency
of the Control Authority's inspection and sampling efforts over the past
year. Ihe inspector will also determine if all the pollutant parameters
specified in the control mechanism were evaluated during the Control Authority's
sampling events and whether the type of samples used (i.e., grab/ composite)
are appropriate and will reflect the discharge characteristics. The inspector
will also evaluate whether there is adequate documentation in the inspection
and sampling reports to support enforcement actions. Ihe purpose of these
questions is to determine if the Control Authority is undertaking the necessary
activities to determine IU compliance.
4.3.4 IU Self-Monitoring Evaluation
Part D of this section of the checklist requires the inspector to
determine if monitoring reports were submitted to the Control Authority by
the industrial user and to determine if the proper parameters were evaluated.
Unless specifically required by the IU permit or other control mechanism, only
categorical industrial users are required by the General Pretreatment Regula-
tions to submit semiannual periodic compliance reports. The control mechanism
should be reviewed by the inspector, specifically for IU self-monitoring and
reporting requirements, to determine if all the required reports have been
submitted during the past year.
4.3.5 Control Authority Enforcement Initiatives
The NPDES inspector must review the monitoring records to identify
violations of pretreatment standards. Where such violations exist, the
inspector should note how quickly the Control Authority took action. The
Control Authority should always notify an IU of a violation of a pretreatment
standard or requirement. This notice should preferably be in writing but may
be verbal as long as an adequate record of the notification exists. The
inspector also should determine if the enforcement response was escalated by
the Control Authority if noncompliance continued or recurred until compliance
was achieved.
4.3.6 Narrative Comments
The last page of Section III allows the inspector to identify the actual
files that were reviewed and record any appropriate comments that arise during
the file evaluation.
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FILE EVALUATION CRITERIA File 1 File 2 File 3 File 4 File 5
B. Control Mechanism Evaluation (Cont. )_
4. Is sample locations) identified?
5. Are applicable IU self-monitoring
and reporting requirements
specified?
C. IU Compliance Evaluation
1. Within the last twelve months:
a) How many inspections of this
IU were performed by the Control
Authority?
b) How many Control Authority
sampling visits were performed?
2. Were all the parameters
specified in the control
mechanism evaluated?
3. Will the type of samples used
accurately reflect discharge
characteristics?
4. Does the IU inspection report
have adequate documentation
to support potential enforce-
ment actions? Did it include
the following:
a) Date and time of inspection?
b) Name of company official
contacted?
c) Verification of production
and flow rates, if needed?
d) Problems with pretreatment
facilities?
e) Problems with monitoring
equipment and techniques?
f) Identification of sources
and types of wastewater
(regulated, unregulated/
dilution flow, etc.)?
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File 1 File 2 File 3 File 4 File 5
5. Did the sampling report for
the IU include:
a) Sampling methods -used?
b) Wastewater. flow at time of
sampling?
c) Sample custody procedures?
d) Determination of results
for all parameters?
D. IU Self-Monitoring Evaluation
1. Did the IU report on all
required parameters in the
control mechanism?
2. Did the IU comply with the
reporting frequency required
in the control mechanism?
sampling frequency?
E. Control Authority Enforcement
Initiatives
1. Did the Control Authority
identify all IU violations:
a) in Control Authority
monitoring results?
b) in IU self-monitoring results?
2. Was the IU notified of all
violations?
3. Was follow-up compliance/
enforcement action taken
by the Control Authority?
4. Did the Control Authority's
action result in the IU
achieving compliance within
three months?
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F. Narrative Comments
FILE 1
Industry Name
Industry Address
Type of Industry
Comments:
File/ID No.
IU Flow:
SIC:
FILE 2
Industry Name
Industry Address
Type of Industry
Comments:
File/ID No.
IU Flow:
SIC:
FILE 3
Industry Name
Industry Address
Type of Industry
Comments:
File/ID No.
IU Flow:
SIC:
FILE 4
Industry Name
Industry Address
Type of Industry
Conments:
File/ID No.
IU Flow:
SIC:
FILE 5
Industry Name
Industry Address
Type of Industry
Conments:
File/ID No.
IU Flow:
SIC:
Section III Completed By:
Date:
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4.4 SUMMARY EVALUATION OF CONTROL AUTHORITY PRETREATMENT PRDGRAM
The sunmary evaluation checklist is provided as a mechanism for the
inspector to record and evaluate his/her observations as well as a convenient
means for transmitting information back to the Control Authority. The format
allows the inspector to -evaluate the facts collected and to make judgments
about the adequacy of the Control Authority's pretreatment program. Since
the NPDES inspector .is normally a fact finder and may not have a complete
understanding of the pretreatment program, the summary evaluation should be
reviewed by program personnel and concurred in before it is sent to the
Control Authority. There may be some situations in which the Approval Authority
may choose not to transmit this summary evaluation to the Control Authority.
In particular, this might be the case where an enforcement action is contem-
plated and transmission of this information might hinder the case.
4.5 SUPPORTING DOCUMENTATION
During the course of the PCI, the Inspector is asked to collect
information which will be attached to the completed PCI checklist. As a
reminder to the Inspector, an Attachment Cover Sheet is included that can be
checked-off as information is collected during the PCI. If the Control
Authority is notified of the inspection in advance, the inspector may wish to
request this documentation at that time.
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SECTION IV: SUMMARY EVALUATION OF CONTROL AUTHORITY PRETREATMENT PROGRAM
A. Control Authority Monitoring and Inspection
Is the Control Authority's monitoring program adequate to accurately
identify SIU noncompliance consistently?
Yes No
Explain:
B. IU Self-Monitoring
Does the Control Authority receive regular (at least semiannual)
self-monitoring reports from its categorical industrial users?
Yes No
Explain:
C. Control Mechanisms
Has the Control Authority administered pretreatment standards and
requirements through an effective permit system or other control
mechanism? Yes No
Explain:
D. Control Authority Enforcement
When violations occur, does the Control Authority routinely notify
the SIU of the violation and escalate the enforcement response if
violations continue?
Yes No
Explain:
Do the Control Authority's enforcement actions usually result in SIU
compliance within three months? Yes No
Explain:
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Does the Control Authority have a good understanding of the
conpliance status of all its SIUs at any given point in
tine? Yes No
Explain:
E. Follow Up Actions:
Record any recommendations for follow-up activity with the Control
Authority below. Distinguish between those actions by the Control
Authority which are required to comply with pretreatment requirements
and those which are recommended to improve the effectiveness of the
pretreatment program.
F. Other Findings
Do the findings of the PCI support the statements made in the Control
Authority's last annual report to the Approval Authority?
Yes No
Explain:
Record any other pertinent findings from the PCI below:
Note: The inspector should attach necessary documentation to this completed
checklist as requested throughout the PCI checklist.
Inspector Signature(s) ~~ Date of Report
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ttCUMENTATION
FOR
PRETREATMENT COMPLIANCE INSPECTION CHECKLIST
Example of any enforcement action (i.e., administrative order)
Containing pretreatment findings or requirements (I.A.)
Description of significant changes to the Control Authority's
pretreatment program (II.B.)
Names of lUs that have not been sampled or inspected within the
last year (II.C.) - OPTIONAL
List of SIUs not in compliance, duration of noncompliance, and
type of action taken by the Control Authority (II.E.)
Control Authority procedures that define appropriate enforcement
response for IU violations (II.E.)
Annual list of significant violators (II.E.)
Other documentation (i.e., copies of Control Authority file
information to support Inspector findings. List the additional
supporting documentation below).
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5. PRETREAIMENT PROGRAM AUDIT CHECKLIST
5.1 INTRODUCTION
A checklist has been prepared to assist with the performance of
pretreatment audits. The reconraended checklist is both detailed and com-
prehensive since audits represent a relatively new activity, and the Agency
wants to ensure that:
o Audits are complete.
o Audits accomplish the desired objectives.
The audit checklist is contained in section 5.3 of this chapter. It contains
ten sections, each of which is discussed below.
5.2 OVERVIEW OF THE AUDIT CHECKLIST
5.2.1 Checklist Cover Page
The cover page is used to record the date of the on-site inspection, the
audit participants, and the name of a principal reviewer. The principal reviewer
would be the primary person whose judgement is involved in completion of the-
checklist. This person must necessarily be a representative of the Approval
Authority.
5.2.2 Section I; Control Authority Background Information
This section of the checklist summarizes general information about the POTW,
its wastewater treatment facilities, and the results of the last audit or PCI.
The section is purposefully brief because detailed information about the Control
Authority is often already on file and available to the auditor. Because the
auditor must know the general characteristics of the POTW treatment plant(s),
particularly when evaluating local limits, a section requiring information on
each treatment plant is included. Once Section I has been completed as part
of the first audit, it will always be available for future audits and PCIs and
will require only minor updating.
5.2.3 Section lit POTW Pretreatment Program Fact Sheet
The fact sheet summarizes the POTW's approved pretreatment program
requirements. It should be completed prior to the on-site audit. The
approved program requirements may be contained in several documents, including
the NPDES permit, the original pretreatment program submission, enforcement
orders, and letters sent by the Approval Authority to the POTW officially
acknowledging or approving program modifications. Part A of the fact sheet
is an inventory of all such documents comprising the approved pretreatment
program. The rest of the fact sheet provides a description of the approved
program and is completed based on the documents listed in Part A. The fact
sheet will help the auditor to determine whether the POTW is implementing its
pretreatment program as approved. The fact sheet should be updated before
each audit or PCI if there have been any changes in the approved program
requirements.
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5.2.4 Section III; Legal Authority and Control Mechanism
This section of the checklist evaluates the POTW's basic legal authority
and mechanisms to effectively control users within and outside its primary
jurisdiction. Regardless of the fact that the POTW's legal authority was re-
viewed during program approval, the POTW's sewer use ordinance, regulations,
etc., may need to be reevaluated, as approved control mechanisms when implemented
sometimes prove to be ineffective. This reevaluation is particularly important
during the first audit.
5.2.5 Section IV; Application of Pretreatment Standards
This portion of the checklist solicits an in-depth evaluation of:
o The POTW's efforts to identify, characterize, and notify industrial users
o The POTW's application of categorical pretreatment standards and local
limits to its industrial users
o The technical basis for the POTW's local limits
o The effectiveness of the pretreatment standards to prevent
interference, pass through, and sludge contamination.
The auditor should determine whether the POTW has sound procedures for
notifying users, updating the industrial waste survey, and administering the
control mechanism. Deficiencies in these areas may indicate that the POTW
should develop formal, written procedures. In addition, it is important that a
detailed review of IU permits (or other control mechanisms) be carried out to
ensure they are correctly written. If limits are not correctly applied in the
permits, the POTW may be falsely reporting IU compliance. Permit application forms
and other relevant forms should also be examined.
5.2.6 Section V; Compliance Monitoring
Section V of the checklist summarizes the results of discussions with POTW
personnel about their compliance monitoring activities, such as POTW monitoring
and inspection frequencies, inspection procedures, sampling protocol, and IU
self-monitoring requirements. Since Section V relies primarily on extemporaneous
POTW personnel responses, this section also gives a good evaluation of the POTW's
depth of understanding of its industrial community.
5.2.7 Section VI; Enforcement
This portion of the checklist summarizes the results of discussions with POTW
personnel about their enforcement procedures. It evaluates the POTW's compliance
tracking system and enforcement management strategy. The section generally asks
for the POTW's response to instances of IU noncompliance, the names of significant
users that the POTW has determined are not in compliance, and the types of
enforcement actions used by the POTW.
5.2.8 Section VII: Data Management and Public Participation
Section VII evaluates the POTW's efforts to effectively manage data and
involve the public, where appropriate.
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5.2.9 Section VIII; Program Resources
This section assists the reviewer in determining if the POTW has adequate
personnel, equipment, and funding to operate the pretreatment program. Differences
between the current resource and funding levels and those levels that are required
by the approved program are noted. The reviewer is also asked to make judgements
about the adequacy of tfie current resources.
5.2.10 Section IX; POTW File Review
The file review portion of the checklist will evaluate many of the same pre-
treatment program elements discussed in Sections V and VI, except it will rely
on a different source of information. Industrial user files will be reviewed
to determine the extent to which the POTW is conducting compliance monitoring
and taking enforcement actions.
This file review will allow the reviewer to:
o Evaluate the POTW's control mechanism
o Determine if categorical pretreatment standards are being applied properly
o Assess the POTW's monitoring and inspection program (i.e., frequency,
completeness, documentation)
o Predict the overall compliance rate of lUs with pretreatment standards
o Evaluate the POTW's overall recordkeeping system.
The checklist contains specific questions to determine the adequacy of the
POTW's activities as demonstrated by the industrial user files. This section of
the checklist allows the reviewer to record findings on five IU files. Additional
copies of this section of the checklist may be used where it is necessary to
review more than five IU files. Appropriate narrative comments may be recorded
on the supplemental comment sheet with the industry name and address.
5.2.11 Section X; Evaluation and Summary
Section X contains several questions which prompt the auditor to evaluate
the information collected in the checklist Sections III through IX on each POTW
pretreatment program element. Several items require the auditor to provide a
yes/no answer about the adequacy of these elements. The auditor should use his/
her best professional judgement for these items, basing this judgement on the
effectiveness of the program as it has been implemented. This section of the
checklist also contains several questions designed to address the POTW's compliance
with the requirements of the General Pretreatment Regulations. Citations to
specific regulatory provisions are provided and the auditor can indicate whether
or nat the POTW meets each basic provision.
Finally, Section X enables the auditor to summarize the key findings of
the audit and to recommend follow-up actions on the part of the POTW. It is
important that the audit summary distinguish between those actions the POTW is
5-3
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required to take based on the General Pretreatment Regulations, the terms of its
NPDES permit, or its approved program and those actions Which are recommended to
the POTW as good practices to improve its program. Accordingly, space is provided
for the auditor to identify areas in which the POTW's pretreatment program does
not fully comply with either regulatory, NPDES permit, or approved program re-
quirements and to suggest necessary corrective actions. An example would be,
"POTW is not enforcing TTO standards for metal finishers. Required Action:
Immediately notify Ills of noncompliance and notify Approval Authority of plans
and schedule for appropriate enforcement response." Space is also provided to
address needs for improvements in the pretreatment program's adequacy and
effectiveness. Each program area which is not adequately implemented and the
recommended POTW actions to correct the deficiencies may be noted by the auditor.
An example is, "The POTW's enforcement procedures and policies vary on a case-by-
case basis and are not based on a documented enforcement management strategy.
Suggested Action: Develop a formal, written enforcement response strategy to use
as a consistent guide for enforcement activities and submit to Approval Authority
for review."
Section X of the checklist is useful in preparing the audit findings and
recommendations which are sent to the POTW. It aids the auditor to distinguish
between regulatory or permit requirements and program effectiveness issues. This
distinction between findings of POTW noncompliance and other recommendations - for
program improvements should be followed in the letter that is sent to the POTW
containing the audit conclusions.
5.5.12 Supporting Documentation for Audit Checklist
During the course of the audit, the auditor is asked to collect information
which will be attached to the completed checklist. As a reminder to the auditor,
an attachment cover sheet is included that can be checked off as information is
collected during the audit. If the Control Authority is notified of the audit in
advance, the auditor may wish to request this documentation ahead of time.
5.3 AUDIT CHECKLIST
The complete checklist for performing POTW pretreatment program audits follows.
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POTW PRETREATMENT PROGRAM AUDIT CHECKLIST
CHECKLIST CONTENTS:
Section I:
_. Section II:
Section III:
Section IV:
Section V:
Section VI:
Section VII:
Section VIII:
Section IX:
Section X:
Attachments:
Control Authority Background Information
POTW Pretreatment Program Fact Sheet
Legal Authority and Control Mechanism
Application of Pretreatment Standards
Compliance Monitoring
Enforcement
Data Management and Public Participation
Program Resources
POTW File Review
Evaluation and Summary
Supporting Documentation for Audit Checklist
POTW NAME:
DATE(S) OF ONSITE REVIEW:
Title
Organization
Phone Number
(Principal Reviewer)
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POTW PRETREATMENT PROGRAM AUDIT CHECKLIST
SECTION I: CONTROL AUTHORITY BACKGROUND INFORMATION
INSTRUCTIONS: Complete background information prior to en-sita audit.
A. General Information:
1) Name of Permittee:
2) Mailing Address:
3) Pretreatment Contact Name:
Title:
Telephone:
4) Frequency of POTW pretreatmant program reporting to Approval
Authority (e.g., annually, quarterly): .
5) Date of last POTW pretreatment program report:
6) Date of last PCI/Audit: Circle type: PCI Audit
7) Comments on results of last PCI/Audit and last pretreatment program
report:
8) Number of treatment plants:
NPDES permit number(s) Plant name(s)
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SECTION Is CONTROL AUTHORITY BACKGROUND INFORMATION (Continued)
B: POTW Treatment Plant Information
(Complete this section for each treatment plant operated under NPDES permit
by the POTW)
1) Name of Treatment Plant:
2) Location Address:
3) NPDES Permit Number: Expiration Date:
4) POTW Treatment Plant Wastewater Flow
Design Daily Average (Dry Weather): mgd
Actual Daily Average (Dry Weather): mgd
Design Peak: mgd
5) Sewer System: % Separate % Combined
6) Percent Industrial Flow: %
7) Level of Treatment: 8) Type of Process (es):
Primary
Secondary
Tertiary
9) Method of Sludge Disposal: 10) Quantity of Sludge:
Land Application dry tons/yr.
Incineration dry tons/yr.
Landfill ' dry tons/yr.
Public Distribution dry tons/yr.
Other (specify) dry tons/yr.
11) Receiving Stream Name:
12) Stream Classification:
13) 301 (h) Waiver Applied for: Yes No, Granted: Yes No
Date of Application:
Date Approved or Denied:
14) If the treatment plant is not in regular compliance with its NPDES
permit, list the parameters commonly violated and the suspected
cause(s):
Parameters Violated Cause(s)
Section I Completed By: Date:
Title: Telephone:
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POTW PRETREATMENT PROGRAM AUDIT CHECKLIST
SECTION II: POTW PRETREATMENT PROGRAM FACT SHEET
INSTRUCTIONS: Ccrplete entire Fact Sheet prior, to on-site audit. Parts B
thru H should be completed based on the approved program
documents identified in Part A.
A. Inventory of Documents Comprising the Approved Pretreatment Program
1) Original Pretreatment Program Submission Approval Date:
2) Does NPDES permit contain pretreatment requirements or conditions?
Yes No
If yes, attach a copy of NPDES pretreatment conditions (e.g.,
reporting requirements, implementation requirements, etc.).
3) List in chronological order all program modification requests. Indicate
whether request was contained in a letter, annual report, or other,
and whether request was approved, denied, or not yet acted upon.
Date of Where Brief Description of Approval Authority
Request Contained Nature of Request Response and Date
4) Is the POTW currently operating under any consent decree, administrative
order or other document which contains pretreatment program requirements?
Yes No
If yes, attach copy.
B. Legal Authority and Control Mechanism
1) POTW authority to implement and enforce pretreatment standards and
requirements is contained in (cite legal authority):
Date Enacted/Adopted
2) Are all Industrial Users (lUs) located within the jurisdictional boundaries
of the POTW? Yes No
If no, what type of legal agreement provides the authority to enforce
pretreatment standards in outlying jurisdictions?
interjurisdictional agreement
contracts with Itte
other (describe):
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SECTION II;. POTW PRETREATMENT PROGRAM FACT SHEET (Continued)
•3) If a raultijurisdictional situation exists, do the approved program
documents specify who should have lead responsibility for carrying out
each aspect of the pretreatnent program in the outlying jurisdiction?
Yes No N/A
If yes, identify Who undertakes the following (POTW or outlying jurisdiction):
establishing local limits
issuing IU control documents
receiving reports (BMRs, etc.T
sampling and analysis
inspections of lUs
compliance tracking
enforcement
pretreatment program administration
4) What IU control mechanisms are intended to be used by the POTW?
_—__^______ permits
contracts
orders
__ sewer use ordinance (SUO) only
other (describe):
5) According to the approved program documents, approximately how many
IU permits or other control documents were intended to be issued by
the POTW?
6) How often are the control documents intended to be reissued?
C. Industrial User Characterization
1) How many lUs were identified in each of the following groups?
categorical lUs
significant* noncategorical lUs
other regulated** noncategorical lUs
other nondomestic users
TOTAL
*The POTW has defined "significant" IU to mean:
** By "other regulated" lUs is meant lUs that the POTW surcharges,
inspects, controls through a permit, or otherwise regulates, but
which are not considered significant for purposes of the pretreat-
ment program.
The POTW's "other regulated" lUs include:
2) Does the POTW intend to update its industrial waste survey
(IWS)? Yes No How often?
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SECTION II: POTW PRETREAIMENT PROGRAM FACT SHEET (Continued)
D. Local Limits
1) Does the program submission indicate historical problems caused by
IU discharges?
inhibition/upset (describe.)
pass through (describe)
sludge (describe)
other (describe)
2) Attach a copy of the local limits contained in the approved program
submission attached
no local limits exist
3) Hew were the local limits derived?
technical basis (describe)
preexisting in ordinance, basis unknown
other (describe)
4) Does the POTW's NPDES permit(s) contain limits or monitoring require-
ments for any toxic/priority pollutants? Yes No
If yes, list pollutants:
If yes, how many analyses per year for:
Influent Effluent Sludge
metals
organics
bicmonitoring
EP toxicity
E. Standards and Requirements for Industrial Users
1) Do the approved program documents indicate that the POTW has lUs
subject to any of the following requirements (indicate approximate
number, if known):
Yes No Approximate
Number
a. combined wastestream formula
b. production-based categorical
standards
c. total toxic organic (TTO)
limits
d. solvent management plans
2) Does the POTW have approval to grant removal credits to categorical
lUs? Yes No If yes, list parameters:
3) Does the POTW have a spill prevention and control plan to address
toxic discharges from lUs? Yes No
4) Does the program include procedures for accepting hazardous wastes by
truck, rail, or dedicated pipeline? Yes No N/A
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SECTION II: POTW PRETREATMENT PROGRAM FACT SHEET (Continued)
5) Does the program include procedures for notifying lUs of Resource
Conservation and Recovery Act (RCRA) obligations? Yes No
F. Compliance Monitoring
1) Does the program submission establish a proposed frequency for
conducting:
Minimum Frequency (times/yr/IU)
Categorical Significant Noncategorical
onsite IU inspections
POTW monitoring of lUs __^
self-monitoring by lUs
reporting by lUs
G. Enforcement
1) Check those compliance/enforcement options that are available to
the POTW in the event of IU noncompliance:
notice or letter of violation
establishment of IU compliance schedule
revocation of permit
injunctive relief
________ fines; maximum amount: $ /day/violation
criminal penalties
termination of service
2) Does the program submission highlight any particular lUs as being
problem dischargers?
IU Name Reason
H. POTW Resources
1) How many full-time equivalents (FTEs) will be ccranitted to the
POTW's pretreatment program? FTEs
(An FTE is sometimes referred to as a man-year. For example, two
persons working half-time all year are equivalent to one FTE.)
2) Which of the following equipment is to be available for
pretreatment program implementation? Indicate the number of units
where possible.
Number
vehicle(s)
automatic sampler(s)
flow meter(s)
portable pH meter (s)
gas detector(s)
self contained breathing
unit(s)
other safety equipment
(describe)
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SECTION II: POTW PRETREATMENT PROGRAM FACT SHEET (Continued)
3) How does the POTW intend to fund the pretreatment program?
Percent of Total Funding
_POTW general operating fund
~IU permit fees
jtonitoring charges
"industry surcharges
"other (describe)
Total 100%
4) What is the total estimated level of annual funding required to
implement the POTW pretreatment program?
$ /year
Other Supporting Comments!
SECTION II Completed By: Date:
Title: Telephone:
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POIW PRETREATMENT PROGRAM AUDIT CHECKLIST
SECTION III. LEGAL AUTHORITY AND CONTROL MECHANISM
INSTRUCTIONS: Complete during on-site audit based on POTW interview.
A. Legal Authority
1) Is the P01W!s current legal authority (i.e., sewer use ordinance) the
sane as that in the approved program? Yes No
If no, provide reasons for any changes:
If no, highlight the changes (deletions, additions and changes) on
a copy of the ordinance, rules, regulations, etc. and attach them
to the checklist.
2) Has the POTW experienced any practical difficulty implementing and
enforcing the provisions of its Sewer Use Ordinance (SUO) or other
legal authorities? Yes No
If yes, briefly explain:
B. POTW Jurisdiction
1) Is the current jurisdictional situation the same as that documented
in the approved program? Yes No
If no, briefly describe any changes:
2) If all contracts or agreements necessary to regulate lUs in outlying
jurisdictions were not officially enacted at the time the program was
approved, have they since been enacted? Yes No N/A
3) Have procedures been implemented in outlying jurisdictions which
adequately address the following:
o Updating industrial waste survey Yes No
o Notification of IUS Yes No
o Permit issuance Yes No
o Receipt and review of IU reports Yes No
o Inspection and sampling Yes No
o Analysis of samples Yes , No
o Enforcement Yes No
Briefly describe any deficiencies:
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SECTION III: LEGAL AUTHORITY AND CONTROL MECHANISM (Continued)
C. Control Mechanism
1) Is the POTW implementing the approved control mechanism (i.e., IU
discharge permit system, contracts, etc)? Yes No
If no, explain:
2) Do all of the required lUs have current (unexpired) control documents?
Yes No
If no, explain:
Give number control documents issued/number, required: /
Give number currently expired:-
3) If the control mechanism is an ordinance only, how are lUs notified
of what specific standards and requirements they must meet?
4) Does the POTW have a control mechanism for regulating IDs whose wastes
are trucked to the POTW? Yes No
N/A
Describe the control mechanism:
Other Supporting Comments;
Section III Completed by: Date:
Title: Telephone:
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POTW PRETKEATMENT PROGRAM AUDIT CHECKLIST
SECTION IV: APPLICATION OF PRETREATMENT STANDARDS
INSTRUCTIONS: Conplete during on-site audit based on POTW interview.
A. Industrial User Characterization
1) How often has the POTW updated its Industrial Waste Survey (IWS) to
identify new lUs or changes in wastewater discharges?
Method used to update survey:
review of newspaper/phone book
review of plmrtoing/building permits
permit reapplication requirements
onsite inspections
review of water billing records
other (describe)
2) Give the current number of lUs of each of the following types:
# categorical lUs
# significant noncategorical industries
# other regulated noncategorical lUs
# other nondomestic users
TOTAL
3) Is the POTW's definition of "significant" IU the same as in the
approved program? Yes Nb
If no, explain:
4) How are categorical lUs identified and categorized?
5) Have any new lUs been added since the original IWS which are capable
of causing interference or pass through or contribute significantly to
the treatment plant's toxic loading? Yes No
If yes, specify:
6) Have any new lUs been added since the original IWS which are located
in outlying jurisdictions where the POTW has no inter jurisdictional
agreements or IU contracts? Yes Nb
If yes, specify: ^
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SECTION IV: APPLICATION OF PRETREATMENT STANDARDS (Continued)
B. Local Limits
1) Has the POTW made (or proposed) any changes to its local limits which
have not been approved? Yes No
(Note that any changes to local limits should be submitted and approved
before adoption.)
Describe any unapproved changes (attach copy):
2) What was the principal reason for changing or proposing to change
limits?
3) Did the POTW technically evaluate the need for local limits for at
least the following six pollutants (See EPA Memorandum, "Local Limits
Requirements for POTW Pretreatment Programs," August 5, 1985):
Headworks Analysis local
Completed? Limits Adopted?
Yes No
Cadmium
Chronium
Copper
Lead
Nickel
Zinc
4) Was site-specific monitoring data used in the calculations? Yes
No N/A
If yes, indicate types of site-specific data used:
sampling data: influent effluent sludge
ambient receiving water monitoring data
biomonitoring data
priority pollutant analyses
other (specify)
5) How did the POTW identify pollutants of concern other than the basic
six metals and evaluate the need for local limits for them?
6) If there is more than one treatment plant, were the local limits
established specifically for each plant? Yes No N/A
7) Have there been instances of treatment plant inhibition/upsets during
the past year? Yes ND
If yes, briefly describe:
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SECTION IV: APPLICATION OF PRETREATMENT STANDARDS (Continued)
8) Does the POTW attempt to determine if such inhibition/upsets are related
to industrial wastes and to trace the problem to the IU?
Yes No N/A
9) Have there been instances of pass through the past year?
Yes No
If yes, briefly describe:
10) If any NPDES permit violations have been caused by discharges of
high-strength conventional wastes, what measures are being taken to
correct the problem?
11) Have POTW workers experienced industrial waste related injuries or
illnesses? Yes No
If yes, explain:
12) How many times were the following monitored for toxics during the past
year?
Influent Effluent Sludge
metals '
organics
biomonitoring
EP toxicity
13) Has monitoring at the treatment plant shown a noticeable change in
whole effluent toxicity or in the quantity of metals or toxic organics
in influent, effluent or sludge? Yes No
If yes, provide details:
C. Standards and Requirements for Industrial Users
1) Has the POTW notified its industrial users of the pretreatment standards
and requirements they must meet? Yes No
2) Does the POTW compare local limits against federal categorical stan-
dards and apply the most stringent standards to categorical lUs?
Yes No N/A
3) Is the method of remaining abreast of categorical regulations adequate
to ensure that the POTW is prepared to properly implement categorical
standards? Yes No N/A
4) For industries with combined wastestreams, is the combined wastestream
formula being correctly applied? Yes No N/A
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SECTION IV: APPLICATION OF PRETREATMENT STANDARDS (Continued)
5) For lUs subject to production-based standards, do limitations in
control documents incorporate them properly?
Yes No N/A
6) Are all applicable local, State, and federal standards included in
control documents issued to lUs? Yes No
7) Are TTO standards or alternatives (solvent management plans or oil &
grease monitoring) being implemented for lUs subject to TTO limitations?
Yes No N/A
8) If the POTW has removal credits authority, is it correctly granting
removal credits to lUs? Yes No N/A
9) If applicable, is the POTW maintaining its approved removal credits
efficiency? Yes No N/A
10) Has the POTW notified lUs of RCRA obligations?
Yes No
11) Are all applicable categorical standards and local limits applied tCT
lUs whose wastes, are trucked in to the POTW?
Yes No N/A
12) If any of the answers to questions 1-12 are "no", briefly explain:
13) List below any available EPA guidance materials which the POTW does
not have, but should have:
Other Supporting Garments;
Section IV Completed by: Date:
Title: Telephone:"
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POTW PRETREATMENT PROGRAM AUDIT CHECKLIST
SECTION V: COMPLIANCE MONITORING
INSTRUCTIONS; Ccnplete during on-site audit based on POTW interview.
A. Inspection and Monitoring
1) What is- the current frequency (attach schedule, if available) for:
ttimes/year/IU
Categorical Significant Nonoategorical
1. POTW sanpling of lUs
2. POTW inspections of lUs
3. IU self-monitoring
4. IU reporting
2) Are the monitoring and reporting frequencies the same as those described
in the approved program?
Frequency Reason for change
same less greater
1. POTW sanpling of IU
2. POTW inspections of lUs
3. IU self-monitoring
4. IU reporting
3) The following question is optional, at the discretion of the Approval
Authority. If any significant or categorical lUs were either not
sampled or not inspected within the last year, then list the lUs and
provide a reason, (attach additional pages if necessary)
Date Inspection/
Sanpling is
Name of IU Reason Planned
4) Are composite samples used to evaluate compliance with categorical
standards when appropriate? Yes No N/A
5) Does the POTW sample for all regulated pollutants? Yes No
6) Are samples split with industrial personnel:
o if requested? Yes No
o if necessary to verify IU self-monitoring results? Yes No
7) Are chain-of-custody procedures employed (attach copy of chain of
custody form, if available)? Yes No
8) Do all sampling and analytical procedures conform to EPA methodologies
(including 40 CFR Part 136)? Yes No
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SECTION V: COMPLIANCE MONITORING (Continued)
9) Indicate where the following pollutant analyses are performed
(i.e./ irihouse laboratory, contract laboratory, etc.) and method
used (AC, GC, GC/MS, wet chemistry, etc.):
metals
cyanide
organics
10) Is a QA/QC program implemented for sampling? Yes No
for analysis? Yes No
11) Hew much time normally elapses between sample collection and obtaining
analytical results?
12) Is the Control Authority prepared to take samples on short notice
(i.e., vehicles, personnel, preservatives, etc. readily available)?
Yes No
Briefly describe any deficiencies in demand monitoring capabilities.
13) Are sampling location, techniques, preservatives, etc., clearly detailed
for sampling personnel before they take a sample? Yes No
Briefly describe any deficiencies in the ability to perform routine
compliance monitoring.
14) Do the POTW's inspections of lUs consist of:
o Inspection of manufacturing facility? Yes No
o Inspection of chemical storage areas? "^^ Yes ^^ No
o Evaluation of hazardous waste generation? Yes No
o Inspection of spill prevention and control
procedures? Yes No
o Inspection of pretreatment facilities? Yes ~ No
o Inspection of IU sampling procedures? Yes No
o Inspection of lab procedures? Yes No
o Inspection of monitoring records? Yes No
B. IU Self-Monitoring and Reporting
1) Are categorical lUs required to sample for all pollutants regulated in
the categorical standards? Yes No N/A
2) Does the POTW routinely review the periodic IU self-monitoring reports
and.compare the results to the applicable pretreatment standards?
Yes No N/A
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SECTION V: COMPLIANCE MONITORING (Continued)
3) Have the following reports been received from all categorical IDs
for vfliich the due date has passed?
Number Received Number Required
Baseline Monitoring Reports
(BMRs) ,
Compliance Schedule Milestone
Reports
90-Day Final Compliance
Reports
Periodic Self-Monitoring
Reports
Is the information contained in these reports analyzed and verified
by the POTW? Yes No N/A
4) Are Ills required to report spills, slug discharges, etc., to the
PC/IW? Yes No
5) If the answer to any of questions (l)-(4) is no, briefly explain:
Other Supporting Comments;
Section V Completed by: Date:
Title: Telephone:
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POTW PRETREATMENT PROGRAM AUDIT CHECKLIST
SECTION VI: ENFORCEMENT
INSTRUCTIONS: Complete during on-site audit based on POTW interview.
1) Estimate the number of lUs that are currently in significant noncompliance
with pretreatment standards and whether nonccmpliance results frcm
lack of pretreatment facilities or O&M problems.
Number of lUs In Non-Compliance
a) Noncompliance with Total Lack of Treatment O&M
Categorical Standards
b) Noncompliance with local
Limits
2) Estimate the number of lUs that are currently in significant non-
compliance with:
Number of lUs in Noncampliance
a) Self-Monitoring Requirements
b) Reporting Requirements
3) Approximately how many (or what percent) of all the lUs were subject to
any kind of enforcement action during the last 12 months?
4) Indicate whether the following types of compliance/enforcement actions
have been used by the POTW during the past 12 months:
Yes No
Verbal warning
Written notice or letter of violation
Issue compliance schedule
Revoke permit
Consent decree
Civil penalties (fines)
Criminal penalties
Termination of service
Injunction relief
Other (Specify)
5) Has the Control Authority used any unusual enforcement techniques
that are effective which other POTWs could benefit by knowing about?
Yes No
If yes, briefly describe:
6) Has the POTW published an annual notice of significant violators (40 CFR
403.8(£)(2)(vii))? Yes No
7) Does the POTW require the development of compliance schedules when
installation of pretreatment facilities or additional O&M is necessary
for an IU to achieve compliance with applicable pretreatment standards?
Yes No
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SECTION VI: ENFORCEMENT (Continued)
8) How many lUs are currently on conplianoe schedules?
Have any of these lUs been allowed more than 3 years from the effective
date of a categorical standard or local limit to achieve compliance?
Yes No
If yes, provide details:
9) Have all New Source Categorical lUs been compliant from the first day
of discharge ? Yes No N/A
10) Does the control authority have procedures that define the appropriate
enforcement response and time frames to initiate the response for
different types and patterns of IU violations? Yes No
(if yes, attach a copy).
11) Provide the following information for all significant industrial users
(SIUs) currently in significant noncompliance (Attach additional pages
if necessary.):
Date of Enforcement Action
Name of SIU 1st Violation Taken to Date Date of Action
The PCTW's annual report may include this information. The appropriate
sections of the report may be updated and substituted for the listing
described above.
Other Supporting Comments:
Section VI Completed by: Date:
Title: Telephone:
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POTW PRETREATMENT PROGRAM AUDIT CHECKLIST
SECTION VII: DATA MANAGEMENT AND PUBLIC PARTICIPATION
INSTRUCTIONS: Complete during on-site audit based on POTW interview.
A. Data Management
1) Are files/records? ccnputerized hard copy both
2) Does POTW have an ample source of technical documents for
implementing its pretreatment program? Yes No
3) Does the POTW keep apprised of current regulations? Yes
No
If yes, describe how:
4) Are data on permit issuance and compliance status readily available?
Yes No
5) Are inspection and sampling records well organized and readily retrievable?
Yes No
6) Can IU monitoring data be retrieved by:
o
o
0
o
o
o
o
o
Industry name _
Pollutant type _
Industrial category or type
SIC code _
IU discharge volume
Geographic location _
Receiving treatment plant (i.e., if there
is more than one plant in the system) _
Other (specify)
Yes
Yes
Yes
Yes
Yes
Yes _
Yes _
No
No
No
No
No
No
No
7) Are all records maintained for at least 3 years? Yes No
B. Public Participation
1) Are program records available to the public? Yes No
2) Have lUs requested that data be held confidential? Yes No
3) Does the POTW have provisions to address confidentiality? Yes
No
4) Has public comment been solicited during revisions to the SUO
and/or local limits [403.5(c)(3)]? Yes No N/A
5) Are there significant public or community issues impacting the
POTW's pretreatment program? Yes No
If yes, please explain:
Section VII Carpleted by: Date:
Title: Telephone;
5-24
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POIW PRETREATMENT PROGRAM AUDIT CHECKLIST
SECTION VIII: PROGRAM RESOURCES
INSTRUCTIONS: Complete during on-site audit based on POIW interview.
A. Personnel and Equipment
1) Does the POTW have the same or greater resources (full time
equivalents-and equipment) than was stated in the submission?
Yes No
If no, describe the nature of the reduced resources:
2) Are an adequate number of personnel available for the following
program areas:
,o IU sampling Yes No
o IU sample analyses Yes No
o IU inspections Yes No
o Administration (including recordkeeping/
data management) Yes No.
o Legal Yes No
o Data analysis, review and response Yes No
3) Do available personnel have appropriate
training? Yes No
4) Is the available sampling equipment adequate? Yes No
5) Is the available safety equipment adequate? Yes No
6) Is the number of vehicles available adequate? Yes No
7) Does the POTW have access to adequate analytical
equipment? Yes No
o Conventional pollutant analysis equipment (i.e.,
lab oven, precision balance, pH meter) Yes No
o Atomic adsorption spectrophotometer Yes No
o Gas chromatograph Yes No
o Gas chronatograph/mass spectrometer Yes No
B. Funding
1) Is the POTW's annual budget for program implementation the same or
greater than that projected in the POTW submission?
Yes No
If no, describe the reason(s) it is less:
5-25
-------
SECTION VIII: PROGRAM RESOURCES (Continued)
2) Have any problems in program implementation been observed vdiich appear
to be related to inadequate funding? Yes No
If yes, describe:
3) Is funding expected to continue near the current level? Yes
No (Increase Decrease )
Other Supporting Comments;
Section VIII Completed by: Date:
Title: Telephone:
5-26
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POIW PRETREATMENT PROGRAM AUDIT CHECKLIST
SECTION IX: POTW FILE REVIEW
INSTRUCTIONS: Review the POlW's files on a representative sample of SIUs
(at least 5 files), attempting to include at least two significant
noncomplv.ing.IUs and two categorical lUs. If the question is
correct or should be answered yes, mark with an "X." If the
appropriate response is none or no, then mark an "0." Numerical
responses may also be required. Narrative comments should be
recorded in part G.
IU #1 IU #2 IU #3 IU #4 IU #5
A. File Contents
1) Does the IU file contain:
a) Industrial waste survey
information?
b) Description of wastewater
flows and pollutants?
c) Discharge permit application?
d) Control document?
e) POTW sampling results?
f) POTW inspection report(s)?
g) IU reports (BMR, 90-day, etc.)?
h) IU self-monitoring results?
i) Correspondence?
j) Telephone log?
k) Meeting notes?
1) Determination of IU compliance
status?
B. Control Mechanism Evaluation IU tl IU #2 IU 13 IU f4 IU #5
1) Is the IU discharge permit,
contract, etc. current (i.e.,
unexpired)?
2) Does it cite the POTTO'S
legal authority?
3) Does it contain correct
discharge limitations?
4) Are types of samples for
self-monitoring specified?
5) Is sample location(s)
identified?
6) Are applicable IU reporting
requirements specified?
7) Are standard conditions
included for:
o Right of entry?
o Records retention?
o Penalty provisions?
o Revocation of permit?
o Nontransferability?
o Notice of slug loading?
o Permit expiration date?
5-27
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SECTION DC: POTW FILE REVIEW (Continued)
C. POIW Compliance Monitoring Evaluation IU #1 IU #2 IU #3 IU #4 IU #5
Within the last twelve nonths:
1) How many times was the IU inspected?
2) Approximately how many sampling
visits were nade to the IU?
3) Were-all the parameters specified
in the control mechanism evaluated?
4) Indicate TTO monitoring status*
5) Are monitoring results well documented?
o Date sample taken
o Type of sample
o Sampler name
o Condition of sample,
preservatives added, etc
o Chain of custody form
o Analytical procedures used
6) Did the IU inspection report have
adequate documentation to support
potential enforcement actions?
Did it include:
6 Date and time of inspection?
o Nane of company official contacted?
o Verification of production and flow
rates, if needed?
o Identification of sources and types
of wastewater (regulated, unregulatedT"
dilution flow, etc.)?
o Problems with pretreatment facilities?_
o Evaluation of IU self-monitoring
equipment and methods?
o Other (describe)
D. IU Self-Monitoring Evaluation IU #1 IU #2 IU #3 IU #4 IU #5
1) Have periodic IU self-monitoring
reports been submitted?
2) Were the required parameters
evaluated?
3) Did the IU comply with the
reporting requirements in the
control mechanism?
*(N) not regulated, (M) monitoring data submitted, (S) solvent management plan
submitted, (U) monitoring data/SMP required but not included in file.
5-28
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SECTION IX: - POTW FILE REVIEW (Continued)
E. POTW Enforcement Initiatives IU »1 IU t2 IU »3 IU #4 IU 15
1) Did the POTW identify all
IU violations:
o In POTW monitoring results?
o In IU self-monitoring results?
2) Was the IU notified of all
violations?
3) Was compliance/enforcement action
taken by the POTW?
4) Did the POTW's action result in
the IU achieving compliance
within 3 months?
F. Spills/Slug Loading IU fl IU #2 IU #3 IU #4 IU #5
1) Has the industry been responsible
for spills or slug loads
discharged to the POTW?
2) If yes, does the file contain
documentation regarding:
a) Notification by the IU of
the spill or slug?
b) POTW response to notification?
c) POTW response to the
discharge?
d) the effect of the spill
on the POTW?
Notes:
5-29
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SECTION IX: POTW FILE REVIEW (Continued)
G. Narrative Cements Fran POTW File Review
FILE 1
Industry Name
Industry Address
Type of Industry
Comments:
File/ID No.
Flow(gpd);
SIC:
FILE 2
Industry Name
Industry Address
Type of Industry
Comments:
File/ID No.
Flow(gpd);
SIC:
FILE 3
Industry Name
Industry Address
Type of Industry
Comments:
File/ID No.
Flow(gpd);
SIC:
FILE 4
Industry Name
Industry Address
Type of Industry
Comments:
File/ID No.
Flow(gpd);
SIC:
FILE 5
Industry Name
Industry Address
Type of Industry
Comments:
File/ID No.
Flow(gpd);
SIC:
SECTION IX Completed by:
Title:
Date:
Telephone:
5-30
-------
POTW PRETREATMENT PROGRAM AUDIT CHECKLIST
SECTION X: EVALUATION AND SUMMARY
INSTRUCTIONS: Complete during or after on-site audit based on reviewer's
analysis of program documentation and implementation. Distinguish between
required POTW actions necessary to achieve compliance with the POTW permit,
approved program; or General Pretreatment Regulations and recanmended actions
to improve or refine the existing program.
A. Legal Authority and Control Mechanism (Section III)
1) Does the POTW have adequate legal authorities to implement and enforce
pretreatment standards and requirements upon all nondonestic/industrial
users (i.e., mobile sources, lUs in outside jurisdictions)?
Yes No
2) If the POTW's legal authority has been changed since program approval,
does it still have the requisite authorities per 40 CFR 403.8(f)(l) to:
Yes No
Deny or condition new or increased contributions (i) -
Apply and enforce pretreatment standards (ii)
Control each IU through permit, contract, etc. (iii)
Require development of IU compliance schedules (iv)(A)
Require submission of IU reports (iv)(B) • ___
Conduct IU inspectians and sampling (v)
Obtain remiedies for noncompliance (vi)(A)
Halt or prevent discharges (vi)(B)
Comply with confidentiality requirements (vii)
3) Have effective procedures been established to implement interjurisdictional
agreements? Yes No N/A
4) Has the POTW implemented an adequate control mechanism to regulate:
Yes No
0 Categorical industrial users?
0 Significant noncategorical industrial users?
0 Waste haulers?
5) Has the POTW issued all of the necessary control documents?
Yes No
6) Describe required POTW actions necessary to achieve compliance with
legal authority requirements:
7) Describe recommended POTW actions to improve the existing legal authority
and interjurisidictional agreements.
5-31
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SECTION X: EVALUATION AND SUMMARY (Continued)
B. Application of Pretreatment Standards (Section IV)
1) Has the POTW developed technically based local limits that will
sufficiently protect the POTW treatment plant from interference,
pass through, and sludge contamination and protect worker safety
[403.5(c) and (d)]? Yes No
2) Are pretreatment standards (local limits and categorical standards)
being properly applied to all industrial users, including:
Yes No
Correct categorization of industries
Application of more stringent standard
(local limits vs. categorical standards)
Designation of proper sampling location(s)
Application of production-based standards
Use of the combined wastestream formula
Sample type and frequency
Use of an effective control mechanism
Other
3) Is the POTW implementing adequate procedures per
40 CFR 403.8(f)(2) to:
Yes No
0 Identify and locate all lUs (i)
0 Notify lUs of all applicable standards
and requirements including RCRA (iii)
4) Describe required POTW actions necessary to adequately apply pretreatment
standards:
5) Describe recotinended POTW actions to improve the POTWs applicaton of
pretreatment standards:
5-32
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SECTION X: EVALUATION AND SIM1ARY (continued)
C. Compliance Monitoring (Section V)
1) Does the POTW perform (in contoination with IU self-monitoring) adequate
inspections and Barreling of its IUs, consistent with 40 CFR 403.8
(f)<2). to:
Yes No
0 Identify the character and volume of pollutants
from all IUs (ii)
* Receive and review industrial user reports (iv)
e Assess industrial user compliance (v)
0 Investigate instances of nonconpliance (vi)
0 Produce admissible evidence in an enforcement
action (vi)
2) Does the POTW inplement the categorical IU reporting requirements
as specified in 40 CFR Part 403.12? yes No
3) Describe required POTW actions necessary to comply with all compliance
monitoring requirements:
4) Describe reconroended POTW actions to improve the POTW's compliance
monitoring program:
D. Enforcement (Section VI)
1) In the event of IU nonconpliance, does the POTW take appropriate and
necessary enforcement action to bring IUs back into compliance in a
timely manner? Yes No
5-33
-------
SECTION X: EVALUATION AND SUMMARY (Continued)
2) Describe required POTW actions necessary for proper enforcement of all
pretreatment standards and requirements:
3) Describe reconnended POTW actions to improve enforcement of pretreatment
standards and requirements:"
E. Data Management and Public Participation (Section VII and DC)
1) Does implementation of the POTW's pretreatment program include:
Yes No_
0 Annual publication of significant violators
[403.8(f)(2)(vii)]
0 Notice to interested parties when local
limits are developed [403.5(c)(3)]
0 Adequate procedures for handling confidential
information [403.14(a)]
0 Unrestricted access to effluent data provided
to the public [403.14(b)]
0 Maintenance of records for at least three years
[403.12(n)(2)]
0 Well-documented activities in IU files
2) Describe required POTW actions necessary for compliance
with data management and public participation requirements:
5-34
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SECTION X: EVALUATION AND SUMMARY (Continued)
3) Describe recarmended POTW actions to improve data itanagement and public
participation:
F. Program Resources
1) Does the POTW have adequate personnel, equipment, supplies, and funding
and technical guidance documents to effectively implement all elements
of its pretreatment program [40 CFR 403.8(f)(3)]?
Yes No
2) Describe the required POTW actions necessary to comply with all resource
requirements:
3) Describe reccmnended POTW actions to iirprove its ability to implement
its pretreatment program:
Section X Completed by: Date:
Title: Telephone:
5-35
-------
SUPPORTING DOCUMENTATION
FOR
AUDIT CHECKLIST'
NPDES permit conditions for pretreatment program development
or inplementation (II.A)
Copy of administrative order, consent decree or other document
containing pretreatment program requirements (II.A)
Copy of local limits from the approved program (II.D)
Copy of POTW SUO if changed since program approval (III.A)
(Highlight the changes that have been incorporated.)
Copy of local limits if changed since program approval (IV.B)
POTW sampling and inspection schedule for regulated lUs (V.A)
list of lUs not sampled or not inspected in the past year (V.A)
(Optional)
Copy of POTW chain-of-custody form (V.A)
List of all noncompliant industries and history of enforcement
actions taken (VI)
5-36
-------
APPENDIX A
EPA MEMORANDA
FROM J. WILLIAM JORDAN AND MARTHA PROTHRO
INSTRUCTIONS FOR COMPLETING
FORM 3560-3
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
6 1S35
OFFICE OF
WATER
MEMORANDUM
SUBJECT
FROM:
TO:
NPDES and Pretreatment Inspection Reporting for
FY 198jfc Off£cev*J3SvWate'r Accountability System
Enforce
an7^Dlt€c
Division (E
Water Management Division Directors, Regions I-X.
Environmental Service Division Directors, Regions
In FY 1986, the Office of Water Accountability System will
require EPA and State commitments for POTW pretreatment inspections,
industrial user pretreatment inspections, NPDES inspections, and a
commitment to inspect each major facility during the year (EPA and
State inspections combined). For this measure, the list of major
facilities will be those designated as major in PCS as of July 31,
1985. The inspection strategy encourages Regions to use resources
efficiently. This can be accomplished by combining the pretreatment
inspection for the POTW and/or the industrial user with an NPDES
inspection. The purpose of this memorandum is to provide guidance
for reporting NPDES and pretreatment inspections in PCS and to
confirm that all inspections, including pretreatment inspections,
will be tracked on a one quarter "lag" basis.
We will not allow the entry of multiple inspections at a
single facility on a single day, but it will be acceptable to enter
the code for the POTW pretreatment inspection or industrial user
pretreatment inspection on the day(s) following the other NPDES
compliance inspection. This method should only be used for
pretreatment inspections and static biomonitoring inspections that
are coupled-with other NPDES compliance inspections. Any other
multiple inspections at a single facility within a five day period
must have reasonable justification.
If the inspection involves an industrial user(s), a separate
entry should be made with the inspection type "I" and the POTW
permit number. You must also indicate the number of lUs covered
during the inspection under comments in Columns 21 through 23.
A-l
-------
- 2 -
Please "right justify" the number in these three columns (e.g.,
"003" for 3 IU's that have been inspected). This approach will
allow us to track pretreatment inspections of industrial users and
POTWs separately. We can also separate lUs in approved POTWs from
those in unapproved POTWs based on their approval status data. A
'Y1 in the Pretreatment Program Required Indicator (PRET) indicates
an approved POTW in PCS.
Although we are not presently requiring detailed lists of the
name and SIC code for each industrial user inspected, this informa-
tion should be maintained by the Regions. We may request this
information later to help develop an inspection strategy for
industrial users. If you have any questions concerning this issue/
please call either Gary Polvi at (FTS 475-8313) or Ed Bender at
(FTS 475-8331).
cc: PCS User Group
A-2
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. O.C. 20460
301985 OFFIC60F
WATER
MEMORANDUM
SUBJECT: Audits of POTWs with Approved Pretreatment
Programs
r ' N i -
FROM: Martha G. Prothro, Director r*\ . Vu . v -AL/ _^v
Permits Division (EN-336) %l VLAs* ^^-^ N VCT'K'VCl,
TO: Water Management Division Directors
Regions l-X
The purpose of this memorandum is to provide final draft
procedures for conducting a POTW pretreatment audit and to describe
Headquarters tracking of audits in FY 86. We solicit your comments
of the final draft audit procedures by September 16, 1985.
In FY 85, EPA Regions conducted 59 audits of POTWs with
approved pretreatment programs and States performed additional
audits. The local pretreatment program audit is a detailed
on-site review of an approved program to determine its adequacy.
The audit report identifies needed modifications to the approved
local program and/or the POTW's NPDES permit to address any
problems. The audit includes a review of the substantive require-
ments of the program, including local limits, to ensure protection
against pass through and interference with the treatment works
and the methods of sludge disposal. The auditor reviews the
procedures used by the POTW to ensure effective implementation
and reviews the quality of local permits and determinations
(such as implementation of the combined wastestream formula). In
addition, the audit includes all the elements of a pretreatment
compliance inspection (PCI).
The draft PCI was distributed to the Regions by Bill Jordan
of the Enforcement Division, OWEP, for review and comment on
August 5. Regions and States will need a capability to conduct
both audits and inspections. We recommend that audits be per-
formed first at (1) POTWs which have been approved for one year
or longer and have not previously been audited, and at (2) POTWs
which are within one year of permit reissuance. As a minimum,
roughly 20% of all POTW pretreatment programs must be audited
in each fiscal year to assure adequate oversight of local
programs during each five year permit term. All Regions have
A-3
-------
- 2 -
informally committed to FY 86 SPMS outputs for audits consistent
with this approach. (All POTWs that are not audited in a given
year should have a PCI as part of the routine NPDES inspection
at that facility.)
The POTW audit checklist contains 10 s.ections (I thru X) as
shown in the checklist table of contents (Appendix A). The'pci
generally consists of six of these sections (I, II, III, VI, VII
and X). Although an audit includes all the elements of a PCI,
the activity should not be counted as both an audit and a PCI.
If the on-site POTW review does not include all the aspects of
an audit (checklist Sections I thru X), it may still be counted
as a PCI (assuming all elements of a PCI are addressed), but it
may not be counted as an audit.
Our current plan (subject to OW and OMSE agreement) is that
for purposes of reporting, audits will be tracked at Headquarters
based on retrievals from the Permit Compliance System (PCS) on
a "lag" basis similar to that traditionally used for NPDES
compliance monitoring inspections. Further instructions on
entry codes, audits with industrial user inspections, and other
procedures will be provided early in FY 86. The audit will not
be counted as completed and entered into PCS until the audit
checklist has been completed, the auditor's reviewer or supervisor
has signed the completed 3560-3 form and the audit has been
officially sent to the POTW. Tracking from PCS in FY 86 will be
conducted according to the following schedule:
AUDITS RETRIEVAL DATE
July
Oct.
Oct.
Oct.
July
1,
1,
1,
1,
1,
1985
1985
1985
1985
1986
through
through
through
through
through
September
December
March 31,
June 30,
September
30,
31,
198
1986
30,
1
6
198
985
198
5
6
NO REPORT
April 2, 1986
July 2, 1986
October 1, 1986
To be credited
first quarter
in FY 87
report
An OWEP strategy for conducting local pretreatment program
audits and inspections is being prepared. The strategy will
describe FY 86-87 implementation activities, plans for additional
guidance, training, workshops and assistance, and clarification
of EPA and State roles and responsibilities. Rebecca Hanmer
will discuss this strategy at the September Water Management
Division Directors meeting.
Please let me know if you have any comments on the attached
audit checklist or our reporting requirements or if you have any
suggestions on how to make it work more effectively. You may
contact me at 755-2545 or ask your staff to submit comments to
Jin Gallup (755-0750) by September 6, 1935.
Attachment
cc: Rebecca Hanmer
Jim Elder
Bill Jordan
Regional and State Pretreatment
Coordinators
A-4
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
DEC IS Q85
OFFICE OF
WATER
MEMORANDUM
SUBJECT Pretreatment Audit Reporting Requirements
FROM: Martha G. Prothro, Director P\N _. \\\ >^
Permits Division (EN-336) V^^^x. \
TO: Water Management Division Directors
Regions I-X
My August 30, 1985 memorandum to you provided final draft
procedures for conducting a POTW pretreatment audit and described
Headquarters tracking of audits in FY 1986 (see attachment).
The purpose of this memorandum is to provide further instructions
on audit tracking and Region/State PCS data entry requirements.
A final pretreatment audit/inspection procedures guidance document
should be issued by Rebecca Hanmer in the very near future.
As stated in the aforementioned memorandum, for purposes of
reporting, audits will be tracked at Headquarters based upon
retrievals from PCS on a one quarter "lag" basis. The schedule
in the August 30 memorandum for audit and PCS retrieval dates is
still valid. Audits are not counted as complete and should not
be entered into PCS until the audit has addressed all th* subiects
contained in the checklist, form 3560-3 has been completed and
signed, and a letter containing the audit findings and recommendations
has been officially sent to the POTW. Once the audit is complete,
the Region/State should enter the appropriate information from
.form 3560-3 into PCS. Particular attention must be paid to data
-entered from two fields: Inspection Type (Column 18) and Inspection
Date (Columns 12-17). We have established the code "G" to describe
pretreatment audits. This code should be entered in Column 18.
Enter the date the POTW site visit was conducted in Columns T2-17.
See Example I,form 3560-3 (attached).Section D should be completed
by either providing a short summary of the audit results or attaching
the letter transmitting the checklist and audit findings and recom-
mendations to the POTW.
The Office of Water Accountability System will track
industrial user (iu) pretreatment inspections in FY 1986. For
those IU inspections performed as part of a POTW pretreatment
audit, data entry requirements are basically the same as those for
IU inspections performed in conjunction with POTW pretreatment
inspections.
A-5
-------
-2-
Those requirements are discussed in the August 6, 1985 memorandum
from Bill Jordan to the Regions (copy attached). Because multiple
entries for a single facility on a single day are not permitted
in PCS, a separate entry should be made with the Inspection Type
code "U" in Column 18 (rather than "I" used for IU inspections
performed in conjunction with pretreatment inspections), the
receiving POTWs permit number in Columns 3-11, and the date
following the pretreatment audit site visit date in Columns
12-17. Regions/States should also indicate the number of IU's
inspected in conjunction with an audit using Columns 21-23 of
the comments section of form 3560-3. This number should be
"right justified" in these columns (e.g., "003" for three IU's
inspected). See Example 2, form 3560-3 (attached). Guidance on
industrial user inspections will be provided by the Enforcement
Division in OWEP.
Please contact me or have your staff call Jim Gallup of my
staff (FTS: 755-0750) if you have any questions or comments on
these reporting requirements.
Attachments
cc: Rebecca Hanmer
Bill Jordan
Ed Bender
Larry Reed
Dela Ng
Regional and State Pretreatment Coordinators
A-6
-------
txampie i
^t"/\ NPDES Compliance Inspection Report
Transaction Coda NPOES
111 'MINI
21
Reserved Facility Evaluation Rating
All American WWTP
1 USA Drive
Everywhere, New York 99999
John Smith
Same as above
Remarks
1 1 1
OMB No. 2040-0003
Ctor Fac Type
2CL/J
1 1
Bl QA •• Reserved ^
7lJFI 72)^1 73l | 1 74 7S| I 1 MfiO
Section B: Facility Data
Entry Time fXj ... [_] _M Permit Effective Date
8:00 6/1/83
Exit Time/Date Permit Expiration Date
5:00/ 10/24/85 5/31/88
Tulels) Phone Nols)
WWTP Superintendent (999) 999-9999
Title
Phone No. Contacted
El Yes C_J No
Section C: Areas Evaluated During Inspection
(S = Satisfactory. M = Marginal. U = Unsatisfactory. N = Not Evaluated)
Permit Flow M
Records/Reports Laborat
| Facility Site Review Effluent
easurement 5 Pretreatment
or'y Compliance Schedules
/Receiving Waters Self-Monitoring Program
Operations & Maintenance
Sludge Disposal
Other:
Section D: Summary of Findings/Comments (Attach additional sheets it necessary/
See attached copy of checklist and POIW transmittal letter containing findings and
recommendations .
Name(s) and Signature(s) of.lnspector(s)
John Jones fah^tfT^i-
" (7
Signature of Reviewer .
Action Taken
Agency/Office/Tele.phone
U.S. EPA Region 99
Water Management Division (999)999-9999
Agency/Office
U.S. EPA Region 99
Water Management Division
Regulatory Office Usa Only
Data
Date
11/25/85
Date
11/27/85
Compliance Status
l_l Noncompliance
| > Comolianea
EPA Form 3660-3 (Rev. 3-85) Previous editions ara obsolete.
A-7
-------
t { ^^* P*" ^^| J* Washington. 0 C 20460
*'CrA NPDES Compliance Inspection Report
Form Aporavea
OMB No. 2040-0003
Approval Eioires 7-31 .05
Transaction Code NPC
I0I0I3I ! 1 1
£S _ yr/mo/day Inspection Type Inspector Fae Type
Remarks
I! 1 I 1 !
21
Reserved Facility Evaluation Rating 81 QA Reserved
67) | | |69 7d | ' 7l| | 72| | 73| 1 1 74 7^
Section B: Facility Data
Name and Location ot Facility -inspected Entry Time 1 — 1 I — 1
I I AM 1 ' PM
Nameis) ct On-Sue Represeniativeis)
IS
Permit
Records/Reports
Facility Site Review
Section D:
£»it Time. Oaie
Titleisl
Title
Phone .No.
Section C; Areas Evaluated During Inspection
= Satisfactory. M = Marginal. U = Unsatisfactory. N = Not Evaluated)
Flow Measurement Pretreatmeni
Laboratory Compliance Schedules
Effluent/ Receiving Waters | Self-Monitoring Program
Summary of Findings/Comments (Attach additional sheets it necessary!
II Mill'
DC
1 80
Permit Effective Date
Permii Expiration Oaie
Phone Nois)
Contacted
C] Yes d No
Operations & Maintenance
1 Sludge Disposal
1 Other
Guidance on industrial user inspections will be provided by the Enforcement Division.
Name(s) and Signatureisl ot Inspector(s)
Signature of Reviewer
Agency/Office/ Telephone
Agency/ Office
Date
Date
Date
Compliance Status
1 _ 1 Noncompliance
A-8
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APPENDIX B
SAMPLE FOLLOW-UP LETTER
TO THE CONTROL AUTHORITY
-------
(Name of Control Authority Manaqer)
(Address of Control Authority)
Dear
As you are aware, a (Pretreatment Compliance Inspection/Pretreatment Program
Audit) was conducted at your facility (NPDES #) on (date of event). This
(inspection/audit) indicated that your facility exhibited the following deficiencies
in its pretreatinent program when compared to applicable pretreatment regulations,
your facility's NPDES permit, and/or your facility's approved pretreatment program
submission:
0 (List such deficiencies)
In addition, we suggest that your facility remedy the following deficiencies
to improve the effective implementation of your facility's pretreatment progranr:
0 (List such deficiencies)
We request that within 15 days of receipt of this letter you inform us by
written response of the proposed corrective actions which will be undertaken at
your facility to address the deficiencies listed here.
Attached is a summary describing in general terms the results of the
(Pretreatment Compliance Inspection/audit) at your facility. Note that the
absence on the summary report of any of the deficiencies listed in this letter
does not excuse you from the above request to perform coorective actions to remedy
deficiencies.
If you have any questions regarding this matter, please contact (name of
Approval Authority representative) at (telephone number of Approval Authority
representative) as soon as possible.
Yours truly,
(Name and signature of
Approval Authority representative)
Attachment
B-l
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APPENDIX C
POIW PRETREATMENT PROGRAM PACT SHEET
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POIW PRETREATMENT PROGRAM FACT SHEET
SECTION II: POTW PRETREATMENT PROGRAM FACT SHEET
INSTRUCTIONS: Conplete entire Fact Sheet prior to on-site audit. Parts B
thru F should be completed based on the approved program
documents identified in Part A.
A. Inventory of Documents Comprising the Approved Pretreatment Program
1) Original Pretreatment Program Submission Approval Date:
2) Does NPDES permit contain pretreatment requirements or conditions?
Yes No
If yes, attach a copy of NPDES pretreatment conditions (e.g.,
reporting requirements, implementation requirements, etc.).
3) List in chronological order all program modification requests. Indicate
whether request was contained in a letter, annual report, or other,
and whether request was approved, denied, or not yet acted upon.
Date of Where Brief Description of Approval Authority
Request Contained Nature of Request Response and Date
4) Is the POTW currently operating under any consent decree, administrative
order or other document which contains pretreatment program requirements?
Yes No
If yes, attach copy.
B. Legal Authority and Control Mechanism
1) POTW authority to implement and enforce pretreatment standards and
requirements is contained in (cite legal authority):
Date Enacted/Adopted
2) Are all Industrial Users (lUs) located within the jurisdictional boundaries
of the POTW? Yes No
If no, what type of legal agreement provides the authority to enforce
pretreatment standards in outlying jurisdictions?
interjurisdictional agreement
contracts with lUs
other (describe):
C -1
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SECTION II: POTW PRETREATMENT FACT SHEET (Continued)
3) If a multijurisdictional situation exists, do the approved program
documents specify who should have lead responsibility for carrying out
each aspect of the pretreatment program in the outlying jurisdiction?
Yes No N/A
If yes, identify who undertakes the following (POTW or outlying jurisdiction):
establishing local limits
issuing IU control documents _
receiving reports (BMRs, etc.)
sampling and analysis
inspections of lUs
compliance tracking
enforcement
pretreatment program administration
4) What IU control mechanisms are intended to be used by the POTW?
permits
- contracts
orders
sewer use ordinance (SUO) only
other (describe):
5) According to the approved program documents, approximately how many
IU permits or other control documents are intended to be issued the
POTW?
6) How often are the control documents intended to be reissued?
C. Industrial User Characterization
1) How many lUs were identified in each of the following groups:
categorical lUs
significant* noncategorical IUs
other regulated** noncategorical IUs
other nondomestic users
TOTAL
*The POTW has defined "significant" IU to mean:
** By "other regulated" IUs is meant IUs that the POTW surcharges,
inspects, controls through a permit, or otherwise regulates, but
which are not considered significant for purposes of the pretreat-
ment program.
The POTW's "other regulated" IUs include:
2) Does the POTW intend to update its industrial waste survey
(IWS)? Yes No How often?
C-2
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SECTION II: POTW PRETREA.TMENT PROGRAM FACT SHEET (Continued)
D. local Limits
1) Does the program submission indicate historical problems caused by
IU discharges?
inhibition/upset (describe)
pass through (describe) __.
sludge (describe)
Bother (describe) .^____
2) Attach a copy of the local limits contained in the program
submission attached
no local limits exist
3) How were the local limits derived?
technical basis (describe)
preexisting in ordinance, basis unknown
other (describe)
4) Does the POTW's NPDES permit(s) contain limits or monitoring require-
ments for any toxic/priority pollutants? Yes No
If yes, list pollutants:
If yes, how many analyses per year for:
Influent Effluent Sludge
metals
organics
biomonitoring
EP toxicity
E. Standards and Requirements for Industrial Users
1) Do the approved program documents indicate that the POTW has lUs
subject to any of the following requirements (indicate approximate
number, if known):
Yes No Approximate
Number
a. combined wastestream formula
b. production-based categorical
standards
c. total toxic organic (TTO)
limits
d. solvent management plans
2) Does the POTW have approval to grant removal credits to categorical
IUs? Yes No If yes, list parameters:
3) Does the POTW have a spill prevention and control plan to address
toxic discharges from lUs? Yes No
4) Does the program include procedures for accepting hazardous wastes by
truck, rail, or dedicated pipeline? Yes No N/A
C-3
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SECTION II: POTW PRETREATMENT PROGRAM
5) Does the program include procedures for notifying lUs of Resource
Conservation and Recovery Act (RCRA) obligations? Yes No
F. Compliance Monitoring
1) Does the program submission establish a proposed frequency for
conducting:
Minimum Frequency (times/yr/IU)
Categorical Significant Noncategorical
onsite IU inspections
POTW monitoring of lUs
self-monitoring by lUs .
reporting by lUs
G. Enforcement
1) Check those compliance/enforcement options that are available to
the POTW in the event of IU noncompliance:
notice or letter of violation
establishment of IU compliance schedule
revocation of permit
"injunctive relief
_ fines; maximum amount: $ /day/violation
criminal penalties
termination of service
2) Does the program submission highlight any particular lUs as being
problem dischargers?
IU Name Reason
H. POTW Resources
1) How many full-time equivalents (FTEs) will be committed to the
POTW's pretreatment program? FTEs
(An FTE is sometimes referred to as a man-year. For example, two
persons working half-time all year are equivalent to one FTE.)
2) Which of the following equipment is to be available for
pretreatment program implementation? Indicate the number of units
where possible.
Number
vehicle(s)
automatic sampler(s)
flow meter (s) ^^^^^
portable pH meter(s)
gas detector (s)
self contained breathing
unit(s)
other safety equipment
(describe)
C-4
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SECTION II: POTW PRETREA.TMEOT PROGRAM FACT SHEET (Continued)
3) How does the POTW intend to fund the pretreatment program?
Percent of Total Funding
POTW general operating fund
~IU permit fees
monitoring dharges
industry surcharges
"other (describe)
"Total 100%
4) What is the total estimated level of annual funding required to
implement the POTW pretreatment program?
$ /year
Other Supporting Comments;
SECTION II Completed By: Date:
Title: Telephone;
C-5
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APPENDIX D
NPDES COMPLIANCE INSPECTION REPORT
POPM 3560-3
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A §•• IQ j» Washington, D. C. 20460
^tPA NPDES Compliance Inspection Report Z™« 'S^S, ...
Transaction Cod* NPDf
ll 1 2|5| 3| | | | 1 1
1 II III
Reserved Facility Evaluation Rating
67| | | |69 7CU
:B yr/mo/day Inspection Type Inspector Fac Type
' | | |n 14 | 1 1 11 Ii7 ial 1 id I 2d I
Remarks
I M 1 I 1 I 1 1 1
7l|J 72| | 73l 1 |74 Tfll 1 1 1 1 80
Section B: Facility Data
Name and Location of Facility Inspected Entry Time ^ AM Q p|y) Permit Effective Date
Exit Time/Date Permit Expiration Date
Namels) of On-Site Representative);)
Name. Address of Responsible Official
Title(s) Phone No(s)
Title
Phone No. - Contacted
D Yes D No
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INSTRUCTIONS
Section A: National Data System Coding (i.e., PCS)
Column 1: Transaction Code: Use N, C, or D for New. Change, or Delete. All inspections will be new
unless there is an error in the data entered.
Columns 3-11: NPDES Permit No. Enter the facility's NPDES permit number. (Use the Remarks
columns to record the State permit number, if necessary.)
Columns 12-17: Inspection Da'te. Insert the date entry was made into the facility. Use the
year/month/day format (e.g., 82/06/30 = June 30, 1982).
Column 18: Inspection Type. Use one of the codes listed below to describe the type of inspection:
A — Performance Audit E — Corps of Engrs Inspection S — Compliance Sampling
B — Biomonitoring L — Enforcement Case Support X — Toxic Sampling
C — Compliance Evaluation P — Pretreatment
0 — Diagnostic R — Reconnaissance Inspection
Column 19: Inspector Code. Use one of the codes listed below to describe the lead agency in the
inspection.
C — Contractor or Other Inspectors (Specify in N — NEIC Inspectors
Remarks columns) R — EPA Regional Inspector
E — Corps of Engineers S — State Inspector
J — Joint EPA/State Inspectors—EPA lead T—Joint State/EPA Inspectors—State lead
Column 20: Facility Type. Use one of the codes below to describe the facility.
1 — Municipal. Publicly Owned Treatment Works (POTWs) with 1972 Standard Industrial Code
(SIC) 4952.
2 — Industrial. Other than municipal, agricultural, and Federal facilities.
3 — Agricultural. Facilities classified with 1972 SIC 0111 to 0971.
4 — Federal. Facilities identified as Federal by the EPA Regional Office.
Columns 21 -66: Remarks. These columns are reserved for remarks at the discretion of the Region.
Column 70: Facility Evaluation Rating. Use information gathered during the inspection (regardless
of inspection type) to evaluate the quality of the facility self-monitoring program. Grade the program
using a scale of 1 to 5 with a score of 5 being used for very reliable self-monitoring programs, 3 being
satisfactory, and 1 being used for very unreliable programs.
Column 71: Biomonitoring Information. Enter D for static testing. Enter F for flow through testing.
Enter N for no biomonitoring.
Column 72: Quality Assurance Data Inspection. Enter Q if the inspection was conducted as
followup on quality assurance sample results. Enter N otherwise.
Columns 73-80: These columns are reserved for regionally defined information.
Section B: Facility Data
This section is self-explanatory.
Section C: Areas Evaluated During Inspection
Indicate findings (S, M, U, or N) in the appropriate box. Use Section D and additional sheets as
necessary. Support the findings, as necessary, in a brief narrative report. Use the headings given on
the report form (e.g., Permit, Records/Reports) when discussing the areas evaluated during the
inspection. The heading marked "Other" may include activities such as SPCC, BMP's, and multime-
dia concerns.
Section D: Summary of Findings/Comments
Briefly summarize the inspection findings. This summary should abstract thepertinent inspection
findings, not replace the narrative report. Reference a list of attachments, such as completed
checklists taken from the NPDES Compliance Inspection Manuals and pretreatment guidance
documents, including effluent data when sampling has been done. Use extra sheets as necessary,
EPA Form 3560-3 (Rev. 3-85) Ravers*
*U. S. GOVERNMENT PRINTING OFFICE 1986j 621-735/60521
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