Wednesday August 3, 2011
Pretreatment Audits 101
Typical Audit Format, Violations and
Deficiencies
“Ask the Auditor”????
Rebecca Villalba, TCEQ
rvillalb@tceq.state.tx.us
Pretreatment Program Audit and
Municipal Pollution Prevention Assessment
Background
►
EPA developed the audit process, including the
audit report and checklist for evaluating
implementation of the approved pretreatment
programs
►
The early audits withstood the test of enforcement
proceedings and judicial actions
Pretreatment Program Audit and
Municipal Pollution Prevention Assessment
Background
The audit includes municipal pollution prevention
(P2) aspects to raise the awareness of the
relationship of P2 activities to the pretreatment
program
► Audits have been historically performed
approximately once every five years
►
Audit Process
 Approval Authority (AA) announces audit (two
weeks prior)
 AA conducts field portion (2-5 days duration)
 Initial Interview
 File Review
 Site Visits
 Exit Meeting
 AA prepares audit report
 Final audit report is mailed to Control
Authority (CA) and copy sent to EPA
 CA submits audit response to AA
Audit Process
Audit Preparation
►
The process begins several weeks ahead with
review of:
 Approved pretreatment program components
 Wastewater treatment plant (WWTP) effluent
monitoring data, including toxicity reduction
evaluations
 Conditions in the watershed
Audit Process
Audit Preparation
►
The process begins several weeks ahead
with review of:
Previous inspections and audits
 Annual reports
 Enforcement actions
 NPDES permit requirements, including
sludge disposal
 Manufacturers Directory

Information Provided to City
Before Initial Audit “Interview”
 List of Hazardous Waste Generators
 List of Manufacturers
Audit Process
Components of the Audit Process
►
Once in the field, the main evaluation
tools are:
Interview checklist
 IU file review checklist
 IU site visit checklist and facility tour
 Examples of permits, forms, letters, reports,
graphs of data tracking

Audit Process
Components of the Audit Process
►
During the field portion of the audit, the
auditors are looking for:
Knowledge of the approved pretreatment program
and the regulations
 Adequate control over IU discharges through
permits or similar means
 Timely and appropriate enforcement activities
 Inventory of IUs discharging to the WWTP

Audit Process
Components of the Audit Process
►
During the field portion of the audit, the
auditors are looking for:
Adequate data management and quality
assurance/quality control (QA/QC)
 Correct categorical industrial user (CIU)
determinations
 Multijurisdictional partner responsibilities

Audit Process
Components of the Audit Process
►
During the field portion of the audit, the
auditors are looking for:
Adequate qualified personnel to implement
the approved pretreatment program
 Communication and familiarity with the IUs
 Any aspects of the pretreatment program
where the CA is voluntarily going “above
and beyond” to improve the program
 Enthusiasm!!

EPA Region 6
Audit Checklist
 Section I:
General Information
 Section II:
Pretreatment Program Analysis
 Section III: Industrial User File Evaluation
PLUS: Industrial User “Site Visits”
SECTION I: GENERAL INFORMATION
A. GENERAL INFORMATION
Control Authority Name:
NPDES #:________________________
Mailing address: _________________________________________________________
Permit Signatory:
Telephone:
Pretreatment Contact:
Title:____________________________
Fax:___________ e-address:_____________________
Title:________________________
Pretreatment program approval date:___________________
Dates of approval of any substantial modifications:_________________
Month Annual Pretreatment Report Due:___________________
Pretreatment Year Dates:
Date(s) of Audit:______________
(P2 Assessment)
Inspector(s):
NAME
TITLE/AFFILIATION
PHONE NUMBER
_______________________________________________________________________________
_______________________________________________________________________________
SECTION I: GENERAL INFORMATION (cont.)
Control Authority representative(s):
NAME
TITLE
PHONE NUMBER
*________________________________________________________
________________________________________________________
*Identifies Program Contact
Dates of Previous PCIs/Audits:
TYPE
DATE
DEFICIENCIES NOTED
__________________________ __ ____________________________
_________________________________________________________
___________________________ _____________________________
SECTION I: GENERAL INFORMATION (cont.)
YES NO_
___ ___ Is the Control Authority currently operating under any
pretreatment related consent decree, Administrative Order,
compliance or enforcement action?
____ __ _ Is the Control Authority currently in SNC or RNC?
B. TREATMENT PLANT INFORMATION
1. THIS PRETREATMENT PROGRAM COVERS THE FOLLOWING NPDES
PERMITS/TREATMENT PLANTS:
NPDES
Effective Expiration
Permit No.
Name of Treatment Plant
Date
Date__
*_________
_______
__________________ _____ _____
__________________ _____ _____
* Indicates the permit number/treatment plant under which the
Pretreatment Program is tracked.
SECTION I: GENERAL INFORMATION
(cont.)
2. Individual Treatment Plant Information
a. Name of Treatment Plant:
Location Address:
Expiration Date of NPDES Permit:
Treatment Plant Wastewater Flow:
Design-_____MGD; Actual (Avg)-_____MGD
Sewer System:_100_% Sanitary; ___0__% Combined
# of SSOs due to grease blockages ____
Industrial Contribution to this Treatment Plant
# of SIUs:____ # of CIUs:_____
Industrial Flow (mgd):
Industrial Flow:
%
SECTION I: GENERAL INFORMATION
2. Individual Treatment Plant Information (cont.)
Level of Treatment:
Type of Process(es):
Primary
_____
_______________________
Secondary _____
_______________________
Tertiary
_____
_______________________
Method of Disinfection: _________________
Dechlorination YES
NO
Effluent Discharge
Receiving Stream Name: Stone Dam Creek
Receiving Stream Classification: Segment 3F of the AR River
Receiving Stream Use: Extraordinary Resource; Primary &
Secondary Contact Recreation; Domestic Water Supply
If effluent is disposed of to any location other than the
receiving stream, please note: __golf course__________
SECTION I: GENERAL INFORMATION
2. Individual Treatment Plant Information (cont.)
Method of Sludge Disposal:
Quantity of Sludge:
Land Application
_______dry tons/yr.
Incineration
_______dry tons/yr.
Monofill
_______dry tons/yr.
Mun. Solid Waste Landfill
_______dry tons/yr.
Public Distribution
_______dry tons/yr.
Lagoon Storage
_______dry tons/yr.
Other (specify)
_______dry tons/yr.
List of toxic pollutant limits in NPDES permit:
Conventionals, TRC, NH3-N, T. Phos.
SECTION I: GENERAL INFORMATION
2. Individual Treatment Plant Information (cont.)
YES NO
Does the Control Authority hold a
sludge permit or has the NPDES
permit been modified to include
sludge use and disposal
____ ____ requirements? If yes, specify the following:
Issuing Authority:______________
Issuance Date:________________
Expiration Date:_______________
List pollutants that are specified in current sludge permit:
The list of 40 CFR 503 parameters, pathogen & vector
attraction reduction requirements
SECTION I: GENERAL INFORMATION
2. Individual Treatment Plant Information (cont.)
YES NO N/A
____ ___ ___
____ ____ ____
Has the Control Authority submitted
results of whole effluent biological
toxicity testing (WET)?
Has there been a pattern of toxicity
demonstrated by effluent toxicity testing?
If yes, explain what has been or
is being done about it. (eg. Is there an
ongoing TRE?)
SECTION I: GENERAL INFORMATION
2. Individual Treatment Plant Information (cont.)
How many times were the following monitored during the
past pretreatment year?
Influent Effluent
Sludge
Ambient
Metals *
Priority **
Biomonitoring
TCLP
Other:________
______
______
______
______
______
_______
_______
_______
_______
_______
______
______
______
______
______
* As identified at 40 CFR 122, Appendix D, Table III
** As identified at 40 CFR 122, Appendix D, Table II
________
________
________
________
________
SECTION I: GENERAL INFORMATION
2. Individual Treatment Plant Information (cont.)
Summarize any trends over the last five years regarding pollutant
(influent, effluent and sludge) loadings. Have they increased, decreased,
or stayed the same? Evaluate for each parameter measured.
_____________________________________________________________
YES NO N/A
____ ___ ____ Has the POTW begun tracking the trends in the
above samples?
____ ___ ____ Has the POTW violated it's NPDES Permit either for effluent
limits or sludge over the last 12 months?
____ ___ ____ If yes, List the NPDES effluent and sludge limits violated
and the suspected cause(s)
Parameters Violated
Cause(s)___________
__________________________________________________________
____ ____ Has the treatment plant sludge violated the TCLP Test?
SECTION II: PROGRAM ANALYSIS AND PROFILE
C. Control Authority Pretreatment Program
Modification [403.18]
YES NO
Has public comment been solicited during
revisions to the Sewer use ordinance and/or local
limits since the last program modification?
___ ___ [403.5(c)(3)] [Editor’s note: per CFR 403.8(f)(4),
“Local limits. The POTW shall develop
local limits as required in §403.5(c)(1), or
demonstrate that they are not necessary.”]
Have any substantial modifications been made or
requested to any pretreatment program components
___ ___ since the last audit?
If yes, identify below:
C. Control Authority Pretreatment Program
Modifications [403.18] (cont.)
1. Modifications:
Date
Date incorporated in
Approved
Ordinance Citation/
NPDES Permit
by [State]
Nature of Modification
_________ _________________________
__________
_________ _________________________
__________
2. Modifications in Progress:
Date Requested
Nature of Modification
____________
_________________________
____________
_________________________
____________
_________________________
C. Control Authority Pretreatment Program
Modifications [403.18] (cont.)
YES NO
Have any changes been made to any pretreatment
program components (excluding any listed
___ ___ above)? If yes:
Has the Control Authority notified the Approval
___ ___ Authority of all program changes? (e.g., Modified
forms, procedures, legal authorities). If no,
please copy and attach the modified form, etc.
SECTION II: PROGRAM ANALYSIS AND PROFILE
D. Legal Authority [403.8(f)(1)]
Date of original Pretreatment Program approval:
[WENDB-PTIM] ___________
Date of most recent Ordinance approved by the
Control authority:___________
Date of most recent Pretreatment Program
modification approval:___________
D. Legal Authority (cont.)
Does the Control Authority's legal authority enable it to:
[403.8(f)(1)(i-vii)]
YES NO
__✓ ____ Deny or condition pollutant discharges
__✓ ____ Require compliance with standards
__✓ ____ Control discharges through permit or similar
means
__✓ ____ Require compliance schedules and IU reports
__✓ ____ Carry out inspection and monitoring activities
__✓ ____ Obtain remedies for noncompliance
__✓ ____ Comply with confidentiality requirements
____ NO Establish Pollution Prevention (P2)
____ NO Has the city developed and adopted a P2
policy?
D. Legal Authority (cont.)
YES NO
✓ ___ Has the Control Authority experienced
difficulty in implementing the sewer use
ordinance? If yes, identify reason:
No oversight authority
No inspection authority
No remedies for noncompliance
No "equivalent" standard
✓ No clear delineation of responsibility for
program implementation
Interjurisdictional agreements not entered
into
✓ Other, Specify: POLITICS!!!!!
D. Legal Authority (cont.)
YES NO
____ ___ Are all industrial users located within the
jurisdictional boundaries of the Control
Authority? If no:
__?_ ___ Has the Control Authority negotiated all
legal agreements necessary to ensure that
pretreatment standards will be enforced in
contributing jurisdictions?
____ NO Have provisions been made for the
incorporation of Pollution Prevention (P2)
policies by contributing jurisdictions?
D. Legal Authority (cont.)
List the name of contributing jurisdictions, if any, the
number of CIUs, SIUs and type of multijurisdictional
agreements in those jurisdictions:
Number Number of
Name of Jurisdiction of CIUs Other SIUs
__________________ _______ ___________
__________________ _______ ___________
__________________ _______ ___________
Type of
Agreement
___________
___________
___________
D. Legal Authority (cont.)
If relying on activities of contributing jurisdictions,
indicate which activities are performed by jurisdictions
and describe any problems in their implementation.
Problems
Updating industrial waste survey
________
Notification of IUs
yes___
Permit issuance
________
Receipt and review of IU reports
________
Inspection and sampling of IUs
________
Assessment of IUs for P2 activity
yes___
Analysis of samples
________
Enforcement
yes___
Other: POLITICS!!!
yes___
D. Legal Authority (cont.)
Identify any IUs that have caused problems of
interference, upset, pass through, sludge
contamination, problems in the collection system, or
worker health and safety in the past 12 months:
NPDES Permit
Violation
IU Name
Problem
Yes No
__N/A and almost impossible to determine a single
(or multiple) culprit if pass-through or interference
occurs. Although SSOs due to grease blockages are,
or should be easier to track down.
E. Industrial User Characterization
[403.8(f)(2)(i)]
YES NO
____ __✓ Has the Control Authority updated its
Industrial Waste Survey (IWS) to identify
new Industrial Users (IUs) or changes in
wastewater discharges at existing IUs?
____ __✓ If yes, while conducting the IWS, was each
potential IU evaluated by the CA for the
possibility of incorporating P2 activities?
____ __✓ Does the Control Authority have written
procedures to update its Industrial Waste
Survey (IWS) to identify new Industrial Users
(IUs) or changes in wastewater discharges at
existing IUs?
E. Industrial User Characterization (cont.)
YES NO
____ __✓ If yes, do the written procedures include
provisions for the assessment of potential
new IUs to incorporate P2 activity and the
distribution of P2 reference materials to the
IUs which qualify?
What methods are used to update the IWS:
Review of newspaper/phone book
NO Review of plumbing/building permits
Review of water billing records
__ Permit reapplication requirements
Onsite inspections
Citizen involvement
Other (specify)
E. Industrial User Characterization (cont.)
How often is the survey to be updated? “ongoing”
Are there any problems that the Control Authority
has in identifying and categorizing SIUs: some cities
have problems correctly identifying production
based categorical IU’s “subparts”
YES NO
____ __✓ Have any new SIUs been identified within
the last 12 months? If yes:
Name of IU
__________
__________
Type of Industry
______________
______________
Is the IU
Permitted?
__________
__________
E. Industrial User Characterization (cont.)
How many IUs are currently identified by the Control
Authority in each of the following groups:
a.
SIUs (As defined by the Control Authority)
[WENDB-SIUS]
b.
Categorical Industrial Users [WENDB-CIUS]
c. ___ Noncategorical SIUs
d.
Other regulated nonsignificant IUs
(Describe) porta potties & landfill
leachate
TOTAL of a. + d.
E. Industrial User Characterization (cont.)
YES NO
____ __✓ Has the POTW identified any IUs with
Pollution Prevention opportunities?
__✓ ____ Is the Control Authority's definition of
"significant industrial user" the same as
EPA's? [403.3(v)(1-3)]
If not, the Control Authority has defined "significant
industrial user" to mean: Most cities have adopted
the CFR 403 “Streamlining” revised definition or are
in the process of drafting final ordinance changes.
F. Control Mechanism (Permits)
Evaluation [403.8(f)(1)(iii)]
YES NO
____ __✓ Has the Control Authority asked for Best
Management Practices (BMPs) or P2
assessments as part of the permit
application?
Describe the Control Authority's approved control
mechanism (e.g., permit, etc.): permits
What is the maximum term of the control
mechanism? 5 years
F. Control Mechanism (Permits)
Evaluation (cont.)
______ How many SIUs are not covered by an
existing, unexpired permit or other control
mechanism? [WENDBs-NOCM]
If there are any SIUs without current (unexpired)
permits, please complete the information below:
PERMIT EXPIRATION
IU NAME
DATE_____
___________________________________________
___________________________________________
F. Control Mechanism (Permits)
Evaluation (cont.)
YES NO
__✓ ____ Does the Control Authority accept trucked
__✓
____
__✓
____
septage wastes?
____ Does the Control Authority accept other
trucked wastes?
__✓ Does the Control Authority have a control
mechanism for regulating trucked
wastes? If yes, answer the following:
____ Does Control Mechanism designate a
discharge point? [403.5(b)(8)]
__✓ Are all applicable categorical standards
and local limits applied to trucked wastes ?
F. Control Mechanism (Permits)
Evaluation (cont.)
List all pollutants and applicable limits, other than
local limits and categorical standards, that are
applied to waste haulers:
Pollutant
Limit
Usually just the general and specific
prohibitions in CFR 403.5(a) & (b)
Describe the discharge point(s) (including security
procedures): “at headworks witnessed by W.W. plant
personnel testing for pH and periodically taking
samples.”
F. Control Mechanism (Permits)
Evaluation (cont.)
YES NO
Does the Control Authority accept
Underground Storage Tank (UST) cleanup
wastes?
___N/A____ Does the Control Authority have a control
mechanism for regulating wastes from
UST sites?
List all pollutants and applicable limits, other than
local limits and categorical standards, that are
applied to UST cleanup sites:
Pollutant
Limit
____________________
____ __✓
G. Application of Pretreatment Standards
and Requirements
YES NO
__✓* ____ Has
the POTW notified the IUs of their
potential requirement to report hazardous
wastes to EPA, the State, and the POTW?
[*Twenty years ago? STRONGLY RECOMMEND IT
BE SENT AGAIN!!]
Date Notified 5/91? Method of Notification letter*
[*Of course documentation is LONG gone!]
How does the Control Authority keep abreast of current
regulations to ensure proper implementation of
standards?
Federal Register
_✓ Journals, Newsletters
_✓ Meetings, Training
_✓ Other Internet
_✓ Government Agency _✓ Other Listserves
G. Application of Pretreatment Standards and
Requirements (cont.)
YES NO
Is the Control Authority in the process of
making any changes to its local limits or
have limits changed since the last PCI,
Audit, or Annual Report?
If yes, complete the information below:
Pollutant
Old
New
Reason
Changed
Limit
Limit
for Change
_____________________________________________
____ __✓
G. Application of Pretreatment Standards and
Requirements (cont.)
[TBLLs / MAHLs]
YES NO
__✓ ____ Has
the Control Authority technically
evaluated the need for local limits for all
required
pollutants listed below? [WENDB-EVLL] [403.5(c)(1);
403.8(f)(4)]
|
|
|
|
V
G. Application of Pretreatment Standards and
Requirements (TBLLs / MAHLs, cont.)
Headworks
Analysis
Completed?
Yes No
Arsenic (As)
__✓
Cadmium (Cd)
__✓
Chromium-Total __✓
Copper (Cu)
__✓
Cyanide (CN)
__✓
Lead (Pb)
__✓
Mercury (Hg)
__✓
Molybdenum (Mo) * ✓
Nickel (Ni)
__✓
Selenium (Se) *
__✓
Silver (Ag)
__✓
Zinc (Zn)
__✓
Local
Local
Limits
Limits
Needed? Adopted?
Yes No Yes No
____
____ __✓
____
____ __✓
____ __✓
____
____
____ __✓
____
__✓ ____
__✓ ____
____
____ __✓
____ __✓
____
____
__✓
____
_✓
____
____
____
__✓
____ __✓
____
____
__✓
____ __✓
____
__✓
____
__✓ ____
____
____
__✓
____ __✓
____
____
__✓
__✓
____ __✓
____ __✓
__✓ ____
____ __✓
*If necessary for biosolids land application option if chosen
Numerical
Limit / MAHL
Adopted
(mg/l)
_______
_______
_______
_______
_______
_______
_______
_______
_______
_______
_______
_______
G. Application of Pretreatment Standards and
Requirements (cont.)
YES NO
__✓ ____ Where
it has been determined that certain
pollutants need to have limits, has the POTW identified
the sources of the pollutants? [Except for Hg – it’s
sources are not wholly identified]
What method of allocation was used for local limits for
each pollutant that has a local limit in-place?
TYPE OF ALLOCATION (for all parameters mentioned
previously)
If there is more than one treatment plant, were the local
limits established specifically for each plant or were
local limits applied uniformly to all plants? The most
stringent TBLLs / MAHLs are applied to all the Control
Authorities’ POTWs
H. COMPLIANCE MONITORING
Compliance Monitoring and Inspection Requirements:
Approved Federal
Explain
Program Aspect
Program Requirement Difference
 Inspections:
CIUs
1-2/yr 1/year
1/year
TO KEEP
Other SIUs 1-2/yr 1/year
1/year
 Sampling:
CIUs
1-12/yr 1/year
1/year THEIR INDUSTRIES
Other SIUs 1-52/yr 1/year
1/year
 Reporting:
CIUs
2-12/yr 2/year
2/year
ON THEIR
Other SIUs 2-12/yr 2/year
2/year
 Self-Monitoring:
CIUs
2-12/yr 2/year
2/year
TOES!!!!!!
Other SIUs 2-52/yr 2/year
2/year
H. COMPLIANCE MONITORING
#
% How many and what percentage of SIUs
were (during the last “pretreatment year):
___ ___ Not sampled at least once in the past reporting
year?
Not inspected at least once in the past
Pretreatment reporting year?
Not inspected or not sampled at least once in
the past reporting year? [WENDB-NOIN][403.8(f)(2)(v)]
* NOIN- this is a count of SIUs that are either not
inspected OR not sampled in the past 12 months. This is
NOT a count of SIUs that were both not sampled and not
inspected. Do not count repetitive SIU names more than
once.
H. COMPLIANCE MONITORING
Attach the names of SIUs that were not sampled
and/or not inspected within the last Pretreatment
reporting year. Include an explanation next to each
name as to why it was not sampled and/or not
inspected. Usually there has been no instances of
city reps not fulfilling these requirements.
Does the Control Authority routinely split samples
with industrial personnel:
YES NO
If requested?
To verify IU self-monitoring results?
__✓ ______
__✓ ______
H. COMPLIANCE MONITORING (cont.)
Provide the following information regarding pollutant
analyses done by the POTW:
Analytical Method *
Name of Laboratory
Metals ICP/MS (200.8)
_____________________
Cyanide _ Spectrophotometric _____________________
Organics _________________
_____________________
Other (WET) ______________
_____________________
Mercury Method 1631
_____________________
Were all wastewater samples analyzed by 40 CFR 136
methods? YES
*Enter the type of Analytical Method used for each group of
pollutants. (eg. AA-flame, AA-furnace, GC, GC/MS, ICP, etc.)
H. COMPLIANCE MONITORING (cont.)
YES NO
__✓ ___ Does the POTW use QA/QC for sampling and
analysis? If yes, describe:
Blanks, spikes and duplicates every 10% on their own.
They’ve even sent the same plus de-I water to contract lab.
In house, they follow EPA’s DMR-QA Study and ERA’s
(Environmental Resource Assoc.)_test procedures quarterly.
IU dedicated sample tubing is changed out frequently.
How much time normally elapses between sample collection
and obtaining analytical results for:
_____ Conventionals
Metals
Organics
H. COMPLIANCE MONITORING (cont.)
YES NO
____ __✓ Is there an established [written] protocol
clearly detailing sampling location and
procedures?
__✓ ____ Has the Control Authority had any problems
performing compliance monitoring?
If yes, explain: Vehicles parked over
sampling manhole, delay by IU rep in allowing City
rep access to sampling point, etc.
H. COMPLIANCE MONITORING (cont.)
Does the Control Authority use the following
methods for compliance monitoring?
YES NO
__✓ ____ Scheduled compliance monitoring
__✓ ____ Unscheduled compliance monitoring
__✓ ____ Demand monitoring for IU compliance
_✓& _✓ IU self-monitoring (some cities do the
compliance sampling for all their SIUs)
____ __✓ Has the Control Authority identified any
violation of the prohibited discharge
standards in the last reporting year? If
yes, describe below:
No instances of Pass Through or Interference
I. ENFORCEMENT
YES NO
_✓* ___ Is the Control Authority definition of SNC
consistent with EPA's? [403.8(f)(2)(viii)] *Or the
City is currently drafting revised Ordinance
__✓ ___ Does the Control Authority have a written
enforcement response plan? [403.8(f)(5)]. If yes,
does the plan:
__✓ ___ Describe how the Control Authority will
investigate instances of noncompliance
___ _ ✓ Describe the Control Authority's types of
escalating enforcement responses and the
periods for each response
__✓ ___ Identify by Title the Official(s) responsible for
implementing each type of enforcement
response reflect the Control Authority's
responsibility to enforce all applicable
pretreatment requirements and standards
I. ENFORCEMENT (cont.)
Check those compliance/enforcement options that are
available to the POTW in the event of IU noncompliance:
[403.8(f)(1)(vi)]
Notice or letter of violation
Administrative Order
Setting of compliance schedule
Revocation of permit
Injunctive relief
$1000 Fines (maximum amount):
civil
criminal
administrative
$
$
$
/day/violation
/day/violation
/day/violation
Imprisonment
Termination of Service
_✓ Other: Supplemental Environmental Projects; required P2
audits with subsequent corrective actions / upgrades
I. ENFORCEMENT (cont.)
Describe any problems the Control Authority
has experienced in implementing or enforcing
its pretreatment program: POLITICS and NO
communications with “downtown” city
council, other engineering groups or
economic development commission notifying
City coordinator a new SIU is connecting!
I. ENFORCEMENT (cont.)
YES NO
____ __✓ When violations occur, does the Control
Authority routinely notify SIUs and escalate
enforcement responses if violations
continue? [403.8(f)(5)] NO RECORD OF
COMMUNICATIONS STILL BEING FOUND
__✓ ____ Are SIUs required to notify the Control
Authority within 24 hours of becoming
aware of a violation and to conduct
additional monitoring within 30 days after
the violation is identified? [403.12(g)(2)].
Comment: Hard to “catch” these required 24 hr
reports during a file review, but some “missing”
ones forces an Audit deficiency.
__✓&✓ If no, does the Control Authority conduct all of the
monitoring?
I. ENFORCEMENT (cont.)
YES NO
_✓& _✓ Does the pattern of enforcement conform to
the Enforcement Response Plan? Too many
NOVs for same permit violation w/o
escalated enforcement
Complete the following table for SIUs identified as
SNC:
Date First
Return to
SIU Identified Enforcement Action Compliance?
Name in SNC
Type
Date
Yes (Date) No
_____________________________________________
_____________________________________________
_____________________________________________
I. ENFORCEMENT (cont.)
Indicate the number and percent of SIUs that were
identified as being in significant noncompliance during
the past Pretreatment reporting period:
#
%
___ ___ Pretreatment Standards [WENDB-PSNC] (Local
Limits/Categorical Standards/BMPs)
Self-monitoring requirements [WENDB-MSNC]
Reporting requirements [WENDB-PSNC]
Pretreatment compliance schedule [WENDBSSNC]
How many SIUs that are currently in SNC with
self-monitoring and were not inspected or
sampled? [WENDB-SNIN]
I. ENFORCEMENT (cont.)
YES NO
___ _ ✓ Does the ERP provide for any P2 activities as corrective actions? If so,
give some examples.
Has the Control Authority experienced any of the following:
EXPLAIN and ID Industrial User
_✓ ___ Interference [WENDB]
Can’t exactly ID the “culprit(s)”
_✓ ___ Pass through [WENDB]
Can’t exactly ID the “culprit(s)”
___ _ ✓ Fire or explosions?
No problems typically found
(incl. flash point viol.)
_✓ ___ Corrosive structural damage?
“Oh, it’s just our old sewer lines or
(Incl. pH <5.0).
naturally occurring hydrogen sulfide”
_✓ ___ Flow obstructions?
Finding more cases of “wet wipes”
and adult diapers
_✓ ___ Excessive flow of pollutant
concentrations?
Our poultry processors w/BOD & TSS
___ _ ✓ Heat problems?
No problems typically found
_✓ ___ Interference due to oil or grease? Restaurants, apartments and homes
_✓ ___ Toxic fumes?
Industrial Laundries cleaning solventladen rags
_✓ ___ Illicit dumping of hauled wastes? Can’t exactly ID the “culprit(s)”
I. ENFORCEMENT (cont.)
YES NO
_✓ ___ Does the Control Authority compare all
monitoring data to applicable Pretreatment
Standards and requirements contained in the
control mechanism? [403.8(f)(2)(iv)]
How many SIUs are currently on compliance
schedules?
__?__ Have any CIUs been allowed more than 3
years from the effective date of a categorical
standard to achieve compliance with those
standards? [403.6(b)] Those “old” reports
were recycled after 3 years
I. ENFORCEMENT (cont.)
Indicate the number of SIUs from which penalties
have been collected by the Control Authority during
the past Pretreatment reporting period:
Number
Amount
Civil ______
$________
Administrative ______
$________
Total ______
$________
[WENDB-IUPN]
J. DATA MANAGEMENT/PUBLIC
PARTICIPATION
YES NO
_✓& _✓ Are inspection & sampling records well
documented, organized and readily
retrievable? Are files/records:
YES NO
_✓ ___ computerized
_✓ ___ hard copy
_✓ ___ OTHER: memory?
Are the following files computerized:
_✓ ___ Control Mechanism Issuance
___ _ ✓ Inspection and Sampling schedule
_✓ ___ Monitoring Data
_✓& ✓ IU Compliance Status Tracking
_✓ ___ Other: Permit Applications,Tracking Inf / Eff trends
J. DATA MANAGEMENT/PUBLIC
PARTICIPATION (cont.)
YES NO
_✓ ___
___ _ ✓
_✓ ___
___ _ ✓
___ _ ✓
___ _ ✓
_✓ ___
?
Can IU monitoring data can be retrieved by:
Industry name
Pollutant type
Industrial category or type
SIC Code
IU discharge volume
Geographic location
Receiving treatment plant (i.e. if > one plant
is covered under the “Program”)
Other (specify)
J. DATA MANAGEMENT/PUBLIC
PARTICIPATION (cont.)
YES NO
_✓ ___ Does the POTW have provisions to address
claims of confidentiality? [403.8(f)(1)(vii)]
_✓ ___ Have IUs requested that data be held
confidential?
How is confidential information handled by
the Control Authority? Kept in a locked file
cabinet and will only be released if approval is
given by the IU
_✓ ___ Are there significant public or community
issues impacting the POTW's pretreatment
program?
If yes, please explain: Budgets, Nutrients, TDS
and increasingly more stringent WQ standards
_✓ ___ Are all records maintained for at least 3 years?
K. RESOURCES
What is the current level of resources dedicated to
the Pretreatment Program in FTEs and funding
amounts? [403.8(f)(3)] - FTE = Full Time Equivalent
Employee Finding fewer Pretreatment dedicated
FTEs during most Audits. A City can be written up
(and some HAVE) in violation if it appears the
Program is being poorly implemented.
YES NO
_✓& _✓ Have any problems in program
implementation been observed which appear to be
related to inadequate funding?
If yes, describe and show below the source(s) of
funding for the program:
K. RESOURCES (cont.)
Percent of Total Funding
_✓ POTW general operating fund __100__
_ IU permit fees
_______
_ monitoring charges
_______
_ industry surcharges
_______
other (describe) ________
_______
Total 100%
YES NO
_✓ ___ Is funding expected to continue near the
current level? If no, will it: Increase
or ___
Decrease?
If no, describe the nature of the changes: ________
K. RESOURCES (cont.)
Are an adequate number of personnel available for
the following program areas:
YES NO
If no, explain:
_✓ ___ Legal assistance
_____________________________
_✓ ___ Permitting
_____________________________
_✓ ___ IU inspections
_____________________________
_✓ ___ Sample collection
_____________________________
_✓ ___ Sample analyses
_____________________________
_✓ ___ Data analysis, review/response __________________________
_✓ ___ Enforcement
_____________________________
_✓ ___ Administration
(inc. record keeping/data management) ____________________
Does the Control Authority have access to adequate:
_✓ ___ Sampling equipment
_✓ ___ Safety equipment
_✓ ___ Vehicles
_✓ ___ Analytical equipment
L. POLLUTION PREVENTION
Describe any efforts that have been taken to incorporate
pollution prevention into the Pretreatment Program (e.g. waste
minimization at IUs, household hazardous waste programs,
etc.):
2. Has the source of any toxic pollutants been identified? If yes,
what was found?
3. Has the POTW implemented any kind of public education
program? If yes, describe:
4. Does the POTW have any pollution prevention success stories
for industrial users documented?
. If yes, please attach.
5. Are SIUs required to get a pollution prevention audit or
assessment as a part of their permit application or as a
requirement of their permit? _______NO_________
6. Has the POTW used any of the various "Guides to Pollution
Prevention" as examples to their industrial and commercial
users as ways to eliminate or reduce pollutants? ___NO___
If yes, which of the "Guides to Pollution Prevention" were
used?
1.
SECTION III:
INDUSTRIAL USER FILE REVIEW
FILE #: 1 Industry Name_____________________________
File/ID (permit) No.____________________
Industry Address____________________________________
Industry Description:________________________________
Industrial Category ___________________40 CFR________
SIC/NAICS Code(s):________/_________________________
Avg. Total Flow (gpd)___________
Avg. Process Flow (gpd)_________
Industry visited during audit: YES NO
Comments:____________________________________
A. IU Characterization
FILE 1
1. Is the IU considered "significant"
by the Control Authority?
__✓_
2. Is the user subject to categorical
pretreatment standards?
______
a. New source or existing
source (NS or ES)?
______
b. Is this IU one identified
as having P2 potential?
__??__
B. Control Mechanism (permit)
FILE 1
1. Does the file contain an application
for a control mechanism?
__✓_
If yes, what is the application date?
09/1/10_
Does it ask for Pollution Prevention information? _ NO_
2. Does the file contain a Permit?
__✓_
Permit Expiration Date?
__✓_
Is a fact sheet included?
_ NO_
B. Control Mechanism (permit cont.)
FILE 1
3. Has the SIU been issued a control mechanism
containing [per 403.8(f)(1)(iii)(B)(1-6)]:
a. Legal Authority Cite?
b. Expiration date?
c. Statement of nontransferability?
d. Appropriate discharge limitations?
e. Appropriate self-monitoring
requirements?
f. Sampling frequency?
g. Sampling locations?
__✓_
12/15
__✓_
__✓_
__✓_
__✓_
_ NO_
B. Control Mechanism (permit cont.)
FILE 1
h. Requirement for flow monitoring?
i. Types of samples (grab or composite)
for self-monitoring?
j. Applicable IU reporting requirements?
k. Standard conditions for:
Right of Entry?
Records retention?
Civil and Criminal Penalty
provisions?
Revocation of permit?
_?? _
_?? _
__✓_
__✓_
__✓_
__✓_
__✓_
B. Control Mechanism (permit cont.)
FILE 1
l. Compliance schedules/
progress reports
_?? _
m. General/Specific Prohibitions?
__✓_
n.
Where technologically and
economically achievable, are P2
aspects included?
_ NO_
C. Application of Standards
FILE 1
1. Has the IU been properly categorized?
2. Were both Categorical Standards and
Local Limits properly applied?
3. Was the IU notified of recent
revisions to applicable pretreatment
standards? [403.8(f)(2)(iii)]
4. For IUs subject to production-based
standards, have the standards been
properly applied? [403.8(f)(1)(iii)]
__✓_
__✓_
_N/A_
__✓_
C. Application of Standards (cont.)
FILE 1
5. For IUs with combined wastestreams is
the Combined Wastestream Formula
or the Flow Weighted Average Formula
correctly applied? [403.6(d)]
__✓_
6. For IUs receiving a "net/gross"
variance, are the alternate standards
properly applied?
_N/A__
7. Is the Control Authority applying a
bypass provision to this IU?
__✓_
D. Compliance Monitoring (Sampling)
FILE 1
1. Does the file contain Control Authority
sampling results for the industry?
__✓_
2. Did the Control Authority sample as
frequently as required by its approved
program or permit? [403.8(c)]
3. Does the sampling report(s) include:
[403.8(f)(2)(vii)]
a. Name of sampling personnel?
__✓_
b. Sample date and time?
__✓_
c. Sample type?
__✓_
D. Compliance Monitoring
(Sampling, cont.)
FILE 1
d. Wastewater flow at the time
of sampling?
_ NO_
e. Sample preservation procedures?
_ NO_
f. Chain-of-custody records?
_ NO_
g. Results for all parameters? SIUs &
CIUs [403.12(g)(1) - CIUs]
__✓_
D. Compliance Monitoring
(Sampling, cont.)
FILE 1
4. Has the Control Authority appropriately
implemented all applicable TTO
monitoring/management requirements?
5. Did the Control Authority adequately
assess the need for flow-proportion vs.
time-proportion vs. grab samples?
6. Were 40 CFR 136 analytical methods
used? [403.12(g)(3)]
_ NO_
_ NO_
__✓_
D. Compliance Monitoring (Inspections)
FILE 1
7.
Does the IU file contain
inspection reports?
8. a. Has the Control Authority
inspected the IU at least as
frequently as required by the
approved program or permit?
[403.8(2)(v)]
b. Date of last Inspection
__✓_
__✓_
8/3/11
D. Compliance Monitoring (Inspections cont.)
FILE 1
9. Does the inspection report(s) include:
[per 403.8(f)(2)(vii)]
a. Inspector Name(s)
b. Inspection date and time?
c. Name and title of IU official
contacted?
d. Verification of production rates?
e. Identification of sources, flow, and
types of discharge (regulated,
dilution flow, etc.)?
f. Evaluation of pretreatment facilities?
__✓_
__✓_
__✓_
_ NO_
_ NO_
_ NO_
D. Compliance Monitoring (Inspections cont.)
FILE 1
g. Evaluation of self-monitoring
equipment and techniques?
h. Evaluation of slug discharge
control plan & need to
develop? [403.8(f)(2)(vi)]
i. Manufacturing facilities?
j. Chemical handling and
storage procedures?
k. Chemical spill prevention areas?
_ NO_
_ NO_
_ NO_
_ NO_
__✓_
D. Compliance Monitoring (Inspections cont.)
FILE 1
l. Hazardous waste storage areas
and handling procedures?
m. Sampling procedures?
n. Laboratory procedures?
o. Monitoring records?
p. Evaluation of P2 opportunities?
q. Control Authority inspector
signature?
_ NO_
__✓_
N/A?
__✓_
_ NO_
_ NO_
D. Compliance Monitoring
IU Self-Monitoring and Reporting
FILE 1
10. Does the file contain selfmonitoring reports?
11. Does the file include:
a. BMR?
b. 90-Day Report?
c. All periodic reports?
d. Compliance schedule
reports?
__✓_
_NO_
_NO_
__✓_
_N/A_
D. Compliance Monitoring
IU Self-Monitoring and Reporting (cont.)
FILE 1
12. Did the IU report on all
required parameters?
13. Did the IU comply with the required
sampling frequency(s)?
14. Did the IU report flow?
15. Did the IU comply with the required
reporting frequency(s)?
16. For all SIUs, are self-monitoring
reports signed and certified?
__✓_
__✓_
__✓_
__✓_
_NO_
D. Compliance Monitoring
IU Self-Monitoring and Reporting (cont.)
FILE 1
17. Did the IU report all changes in its
discharge? [403.12(j)]
_NO_
18. Has the IU developed a Slug Control and
Prevention Plan?
??_
19. Has the industry been responsible for spills
or slug loads discharged to the POTW? _NO_
If yes, does the file contain
documentation regarding:
a. Did the spill cause Pass Through or
Interference?
??_
b. Did POTW respond to the spill?
____
E. Enforcement
FILE 1
1. Were all IU discharge violations
identified in [403.8(f)(2)(vii)]:
a. Control Authority monitoring
results?
b. IU self-monitoring results?
c. If NS CIU was it compliant
within 90 days from
commencement of discharge?
__✓_
__✓_
??_
E. Enforcement (cont.)
FILE 1
2. How many reports submitted during
the past reporting year indicated
discharge violations?
3. Did the IU notify the Control Authority
within 24 hours of becoming aware
of the violation(s)?
4. Was additional monitoring conducted
within 30 days after each discharge
violation occurred?
5. Were all non-discharge violations
identified in the file?
_10_
_NO_
_NO_
_NO_
E. Enforcement (cont.)
FILE 1
6. Was the IU notified of all violations?
7. Was follow-up enforcement action
taken by the Control Authority?
8. Did the Control Authority follow its
approved ERP?
9. Did the Control Authority's enforcement
action result in the IU achieving
compliance?
_NO_
__✓_
_NO_
??_
E. Enforcement (cont.)
FILE 1
10. Is there a compliance schedule?
If yes:
11. Were there any compliance schedule violations?
12. Was SNC calculated for the violations on a quarterly
basis? [403.8(f)(2)(viii)]
During evaluation for SNC, did the CA consider
each of the following criteria?
a. Chronic violations
b. TRC
c. Pass through/Interference
d. Spill/slug loads
e. Reporting
f. Compliance schedule
g. others (specify)
13. Was the SIU published for SNC?
Date of publication:
_N/A_
_N/A_
__✓_
__✓_
__✓_
__✓_
__✓_
__✓_
_?? _
__✓_
8/3/11
Industrial User Site Visits
1. Significant industrial user?
2. Classified correctly?
3. Pretreatment equipment or procedures?
4. Pretreatment equipment maintained and operational?
5. Hazardous waste generated or stored?
6. Proper solid waste disposal?
7. Solvent management/TTO control?
8. Suitable sampling location?
9. Appropriate self-monitoring procedures/equipment?
10. Adequate spill prevention and control?
11. Industry familiar with limits and requirements?
12. Pollution Prevention activity?
Audit Exit Meeting
1. List of audit findings with required actions to
come into compliance with the National
Pretreatment Regulations or provisions in the City’s
Pretreatment Program.
AND
2. List of recommended actions to improve
implementation of the City’s Pretreatment and
Pollution Prevention Programs.
AND
3. List of required modifications to bring the City’s
Pretreatment Program into compliance