COMPLIANCE SCHEDULE DESCRIPTION
A compliance schedule is a formal plan which lists the sequential tasks that must be completed
and the earliest dates by which the tasks must be completed by an industry in order to eliminate
the cause(s) of the discharge violations and achieve consistent compliance with all the
discharge limitations contained in its wastewater discharge permit. These steps usually lead to
upgrade of an existing pretreatment facility, construction of a new pretreatment facility or
perhaps, completion of in-plant modifications which the industry believes, and the Metro District
concurs, will allow the industry to consistently meet their wastewater discharge limitations.
A compliance schedule can be issued under the following circumstances:
1.
As a corrective action taken against an industry which has failed to demonstrate
consistent compliance with all the discharge limitations contained in its wastewater
discharge permit, provided the industry has not been found to be in significant
noncompliance a third time within three years or has completed a compliance schedule
which was intended to eliminate the cause of the discharge violations.
2.
If continued operation of the industrial facility will not cause a significant discharge
violation. The Metro District considers a discharge violation to be significant if the
concentration (or mass, in the case of production-based standards) of pollutant
discharged is more than 1.2 times the effluent limitation for metals and organics, 1.4
times the limitation for oil and grease or more than 1.0 standard pH unit above the upper
pH limit or below the lower pH limit. Other examples of significant violations are:
discharges that cause, alone or in combination with other discharges, interference or
pass through, or cause imminent endangerment to human health/welfare or to the
environment.
3.
As a part of a new wastewater discharge permit.
4.
As a modification to an existing wastewater discharge permit.
The basic rules for writing a compliance schedule are:
1.
The schedule shall contain increments of progress in the form of dates for the
commencement and completion of major events leading to compliance (e.g., hiring an
engineer, completing preliminary plans for pretreatment systems, completing final plans,
executing contracts for major components, commencing construction, completing the
construction and operation of pretreatment facilities or in-plant modifications).
2.
The increments of progress should be listed in sequential order on the basis of their
scheduled completion dates.
3.
No single increment of progress shall exceed nine (9) months.
4.
The final listed increment of progress will be “Deadline for compliance with permit
effluent standards”.
5.
The compliance schedule will state that the industry must submit a compliance schedule
progress report to the Metro District within fourteen (14) calendar days following the
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scheduled completion date for each increment of progress. The report must contain at a
minimum, information on whether or not the industry complied with the increment of
progress to be completed on such date and, if not, the date on which it expects to
comply with this increment of progress, the reason(s) for delay, and the steps being
taken by the industry to return to the schedule established. An example of a compliance
schedule progress report is contained in this appendix.
It is generally preferable to let the industry propose a compliance schedule within the guidelines
listed above. Any proposed compliance schedule is subject to final approval and issuance as
an Administrative Order, by the Metro District. An example of a compliance schedule is shown
in this appendix.
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EXAMPLE COMPLIANCE SCHEDULE
Increment
#
1.
2.
Description of Action Required
Develop remedial measures to improve housekeeping, training, maintenance
and calibration of pretreatment equipment and monitoring & record keeping of
the system operation. Submit measures to Metro District for review.
Develop and implement revised operations and maintenance (O & M)
pretreatment manual for existing pretreatment system. Use chemicals
selected for existing pretreatment system.
Completion
Date
Report
Date
04/21/95
05/05/95
05/19/95
06/02/95
06/30/95
07/14/95
07/28/95
08/11/95
09/01/95
09/15/95
11/17/95
12/01/95
Monitor effectiveness by conducting daily in-house process control tests on
grab samples by EPA approved methods for chromium, nickel and zinc,
record results. Submit O & M pretreatment manual and summary of test
findings to Metro District for review.
3.
4.
5.
6.
The O & M pretreatment manual must contain (at a minimum) the following
procedures:
A. Detailed procedures for operating all pretreatment system components,
including start-up and shut-down directions and disposal procedures for
tanks not discharging to the pretreatment system.
B. Schedules for the inspection, calibration and preventative maintenance of
equipment (pipes, pumps, mixers, tanks, meters, sensors, alarms, press,
etc.) used in the pretreatment system.
C. Detailed procedures for responding to pretreatment system alarms, upset
conditions, capacity limitations and other emergencies.
D. Process control testing. This should include a schedule of the locations,
the test methods and the frequency of the testing that will be performed
to monitor the performance of the pretreatment system.
Install the new zinc process line and pretreatment equipment, complete all
connections to the new system equipment. Submit a complete tank schedule
& flow diagram which includes the discharge route(s) and the size(s) of lines
entering and exiting the new zinc pretreatment system and all zinc process
lines.
Develop and implement supplemental O & M pretreatment manual section(s)
for the new zinc pretreatment system. Prepare according to the criteria
contained in increments 2.a-d above.
Monitor effectiveness by conducting daily in-house process control tests on
grab samples by EPA approved methods for chromium, nickel and zinc,
record results. Submit summary of test findings and supplemental O & M
section(s) to Metro District for review.
Perform study to identify additional process changes (ie., final polishing filter)
that may be implemented or installed to reduce pollutants in the final process
wastewater discharge. Submit proposal to Metro District for review.
Implement changes (if any) identified in increment #5 above. Demonstrate
consistent compliance with pretreatment standards by performing accelerated
compliance monitoring for chromium, nickel and zinc according to the
following guidelines:
Collect three (3) flow composite samples per week for four weeks from
Monitoring Point 001, provide Metro District with splits of all collected samples
and analyze industry portions of samples by EPA approved methods. Submit
results to Metro District for compliance determination.
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COMPLIANCE SCHEDULE PROGRESS REPORT
COMPANY NAME:_____________________________________________________________
ADDRESS:___________________________________________________________________
PROGRESS REPORT DUE DATE:___________________
INCREMENT NUMBER:____
1. Compliance schedule corrective action increment description:
2. Scheduled completion date for above increment:________________________________
3. Was the increment completed on schedule?
Yes
No
4. If not on schedule, indicate anticipated completion date:__________________________
5. State reason for delay, if applicable:
6. What action has been initiated to return project to original schedule, if applicable?
7. What is the probability of meeting the next scheduled increment of progress completion
date?
____________________________________________
SIGNATURE OF AUTHORIZED REPRESENTATIVE
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______________
DATE
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