HomeMy WebLinkAboutx11-28-2012 11.07-Appendix D - Control Authority Pretreatment Audit Checklist.pdf MEMBER AGENCY PRETREATMENT AUDIT CHECKLIST
AUDIT CHECKLIST CONTENTS
Cover Page
Section I Data Review
Section II IU File Evaluation
Section III Observations and Concerns
Attachment A Pretreatment Program Status Update
Attachment B Pretreatment Program Profile
Attachment C Legal Authority Review Checklist
Attachment Worksheets
Site Visit Data Sheet
WENDS Data Entry Worksheet
PCA Required CIS Data Elements Worksheet
RNC Worksheet
Attachment D Supporting Documentation
Member Agency(MA)name and address Date(s)of audit
AUDITOR(S)
Name Title/Affiliation Telephone Number Email Address
MA REPRESENTATIVE(S)
Name Title/Affiliation Telephone Number Email Address
SECTION I: DATA REVIEW
INSTRUCTIONS: Complete this section on the basis of MA activities to implement its pretreatment program.Answers to
these questions could be obtained from a combination of sources including discussions with MA personnel, review of
general and specific IU files, IU site visits, review of POTW treatment plants, among others.Attach documentation where
appropriate. Specific data might be required in some cases.
• Write ND (Not Determined)beside the questions or items that were not evaluated during the audit.
• Use N/A Not Applicable)where appropriate.
A. MA PRETREATMENT PROGRAM MODIFICATION [403.18]
1. a. Has the MA made any substantial changes to the pretreatment program that were not Yes No
reported to the SAWPA(e.g., legal authority, less stringent limits,
multijurisdictional situation)?
If yes, discuss.
b. Is the MA in the process of making any substantial modifications to any pretreatment Yes No
program component(including legal authority, less stringent local limits, and
required pretreatment provisions from the 2005 revisions to the General Pretreatment
Regulations, multijurisdictional situation, and others)?
If yes, describe.
c. Has the MA made any nonsubstantial changes to the pretreatment program (i.e., pH limit Yes No
modification, reallocation of the maximum allowable headworks loading, and such)?
If yes, describe.
1.b.When was the original submission of the MA's Pretreatment Program originally approved?
Who was the original approval authority? EPA, [ ] State [ ] Other[ ]
SECTION I: DATA REVIEW (CONTINUED)
A. MA PRETREATMENT PROGRAM MODIFICATION (continued)[403.18]
1. d. Has the MA amended its pretreatment program to include the following components required under the 2005
amendments to the General Pretreatment Regulations:
Yes No
• Slug control requirements in control mechanisms. [40 CFR 403.8(f)(1)(iii)(13)(6)]
• Notification requirements to include changes that might affect the potential for a slug
discharge. [40 CFR 403.8(f)(2)(vi)]
• Revised SNC definition. [40 CFR 403.8(f)(2)(viii)]
• Clarification that SIU reports must include any applicable BMP compliance information.
[40 CFR 40.12(b), (a),(h)]
• SIU control mechanisms must contain any BMPs required by a Pretreatment Standard,
local limits, state, or local law. [40 CFR 403.8(f)(1)(iii)(B)(3)]
• Record-keeping requirements for BMPs. [40 CFR 403.12(0)]
• Clarification that MAs that perform sampling for SIUs must perform any required repeat
sampling and analysis within 30 days of becoming aware of a violation. [40 CFR
403.12(g)(2)]
• Modifications to the sampling requirements. [40 CFR 403.12(g)]
• Requirement to report all monitoring results. [40 CFR 403.12(g)]
If not,when?
e. Has the MA adopted or does the MA plan to adopt any of the optional measures provided Yes No
by the 2005 amendments to the General Pretreatment Regulations?
If yes, check which ones.
Issuance of monitoring waivers for pollutants that are not present[40 CFR 403.8(f)(2)(v)and 403.12(e)(2)]
Issuance of general control mechanisms to regulate multiple industrial dischargers with similar wastes
[40 CFR 403.8(f)(1)(iii)(A)]
Using BMPs as an alternative to numeric local limits [40 CFR 403.3(e),403.5(c)(4), 403.8(f),403.12(b), (a),
and (h)]
Authority to implement alternative sampling, reporting, and inspection frequencies for NSCIUs
[40 CFR 403.3(v)(2),403.8(f)(2)(v)(B),403.8(f)(6), 403.12(e)(1), 403.12(g), (i), and (q)]
Authority to implement alternative sampling, reporting, and inspection frequencies for middle-tier CIUs
[40 CFR 403.8(f)(2)(v)(C),403.12(e)(3),and 403.12(i)]
Authority to implement equivalent concentration limits for flow-based standards [40 CFR 403.6(c)(6)]
Authority to implement equivalent mass limits for concentration-based standards [40 CFR 403.6(c)(5)]
SECTION I: DATA REVIEW(CONTINUED)
Yes No
1. a. Are there any contributing jurisdictions discharging wastewater to the MA SARI line
connections?
If yes, explain how the legal authority addresses the contributing jurisdictions.
b. List the contributing jurisdictions.
c. Does the MA have an agreement in place that addresses pretreatment program Yes No
responsibilities?
d. Is the MA or the contributing jurisdiction responsible for the following:
Contributing Jurisdiction
MA Responsibility Responsibility
Updating the IWS
Notifying IUs of requirements
Issuance of control mechanisms
Receiving and reviewing IU reports
Conducting inspections
Conducting compliance monitoring
Enforcement of Pretreatment Standards and Requirements
SECTION I: DATA REVIEW(CONTINUED)
B. LEGAL AUTHORITY(continued) [403.0(f)(1)] (continued)
e. Has the MA had any problems with implementation of its pretreatment program within Yes No
the contributing jurisdictions?
If yes, explain.
Yes No
2. a. Has the MA updated its legal authority to reflect the 2005 General Pretreatment
Regulation changes?
b. Did all contributing jurisdictions update their SUOs to be as stringent as the SAWPA
SUOI?
c. Did the MA update its procedures and ERP to implement the changes in its SUO?
Explain
3. Does the MA experience difficulty in implementing its legal authority[i.e., SUO, Yes No
interjurisdictional agreement(e.g., permit challenged,entry refused, penalty appealed)]?
If yes, explain.
SECTION I: DATA REVIEW(CONTINUED)
C. IU CHARACTERIZATION [403.8(f)(2)(i)&(ii)]
1. a. How does the MA define SIU?(Is it the same in contributing jurisdictions? Is it different from the federal definition at
40 CFR 403.3(v)?)
b. If the MA has implemented the middle-tier CIU provisions, how does the MA define middle-tier CIU?
c. If the MA has implemented the NSCIU provisions, how does the MA define NSCIU?
2. How are SIUs identified and categorized (including those in contributing jurisdictions)?
Discuss any problems.
3. a. How and when does the MA update its IWS to identify new IUs(including those in contributing jurisdictions)?
b. How and when does the MA identify changes in wastewater discharges at existing Us (including those in
contributing jurisdictions)?
SECTION I: DATA REVIEW(CONTINUED)
C. IU CHARACTERIZATION [403.8(f)(2)(i)&(ii)] (continued)
4. How many SARI dischargers are currently identified by the MA in each of the following groups?
a. SIUs (as defined by the MA) [WENDB-SIUS]
CIUS, excluding middle-tier CIUS and NSCIUs[WENDB-CIUS]
Middle-tier CIUS"(specify below)
Noncategodcal SIUS
b. Other regulated nonsignificant Us(specify)
Noncategodcal nonsignificant Us
NSCIUs", excluding zero-discharging CIUS [as defined by 40 CFR 403.3(v)(2)]
(specify below)
Zero-discharging CIUS"(specify below)
C. TOTAL
" The following section is to be completed only if the POTW has adopted middle-tier permitting [40 CFR 403.3(v),
403.8(f)(2)(v)(C),403.12(e)(3)], general control mechanisms [40 CFR 403.8(f)(1)(iii)(A)], or NSCIUs [40 CFR
403.3(v)(2),403.8(f)(2)(v)]. In addition the POTW's program must be revised and approved for these
classifications before they can be used.
List of NSCIUs and zero-discharging CIUS:
List of Middle-Tier CIUS:
If middle-tier CIU classification is used, what is 0.01% of the POTW's dry-weather capacity?
List of SIUS with general control mechanisms:
SECTION I: DATA REVIEW (CONTINUED)
D. CONTROL MECHANISM EVALUATION [403.111
1. a. How many and what percent of the total SIUs are not covered by an
existing unexpired permit, or other individual control mechanism?
b. Has the MA implemented any general control mechanisms?
c. If yes, how many SIUs (as defined by the MA)are covered by a general control mechanism?
List the types of SIUs covered under a general control mechanism:
d. How many control mechanisms were not issued within 180 days of the expiration date of the
previous control mechanism or extended beyond 5 years?[RNC—II]
If any, explain.
2. a. Do any UST), CERCLA, RCRA corrective action sites and/or other contaminated
groundwater sites discharge wastewater to the MA?
b. How are control mechanisms(specifically limits)developed for these facilities?
Discuss
Yes No
3. a. Does the MA accept any waste by truck, rail, or dedicated pipe (including septage)?
b. Is any of the waste hazardous as defined by RCRA?
d. Describe the MA's program to control hauled wastes including a designated discharge point(e.g., number of points,
control/security procedures). [403.5(b)(8)]
SECTION I: DATA REVIEW (CONTINUED)
E.APPLICATION OF PRETREATMENT STANDARDS AND REQUIREMENTS
1.What limits(categorical, local, other)does the MA apply to wastes that are hauled to the SARI Truck collection Station?
[403.1(b)(1)]
2. How does the MA keep abreast of current regulations to ensure proper implementation of standards?[403.8(f)(2)(iii)]
3. Local limits evaluation: [403.8(f)(4); 122.21Q)(2)(ii)]
Yes No
Has the MA identified any pollutants of concern beyond those in its local limits?
If yes, how has this been addressed?
SECTION I: DATA REVIEW(CONTINUED)
F.COMPLIANCE MONITORING
1. a. How does the MA determine adequate IU monitoring(sampling, inspecting, and reporting)frequencies?
b. Is the frequency established above more, less, or the same as required?
Explain any difference.
c. Does the MA perform IU monitoring in lieu of requiring IUs to conduct self-monitoring? If yes, list IUs.
2. In the past 12 months, how many,and what percentage of, SARI dischargers were: [403.8(0(2)(v)]
(Define the 12-month period to .)
a. Not sampled or not inspected at least once
b. Not sampled at least once
c. Not inspected at lead once(all parameters)?
If any, explain. Indicate how the percentage was determined (e.g., actual, estimated).
SECTION I: DATA REVIEW (CONTINUED)
F.COMPLIANCE MONITORING (continued)
3. a. Indicate the number and percent of SARI dischargers that were identified as being in SNC`with the following
requirements as listed in the MIA's last pretreatment program performance report.
SNC Evaluation Period
• Applicable Pretreatment Standards and reporting
requirements `SNC defined by:
• Self-monitoring requirements
• Pretreatment compliance schedule(s)
b.Are any of the SIUs that were listed as being in SNC in the most recent pretreatment report still in SNC status? If
yes, list SIUs.
c. Indicate the number of SIUs and permitted IUs that have been in 100% compliance with all Pretreatment Standards
and Requirements.
Evaluation Period:
Number of IUs:
Number of SIUs:
Names of IUs and SIUs:
4.What does the MIA's basic inspection include? (process areas, pretreatment facilities, chemical and hazardous waste
storage areas, chemical spill prevention areas, hazardous-waste handling procedures, sampling procedures, laboratory
procedures, and monitoring records)[403.8(f)(2)(v)&(vii)]
Request a copy of the MA's inspection form, if applicable.
How many times is each IU inspected per year?
How many times is each SIU inspected each year?
How many times is each CIU inspected each year?
5.Who performs the MA's compliance monitoring analysis?
Performed by: MA/Contract Laboratory Name
• Metals
• Cyanide
• Organics
• Other(specify)
6.What QA/QC techniques does the MA use for sampling and analysis(e.g., splits, blanks, spikes), including
verification of contract laboratory procedures and appropriate analytical methods? [403.8(f)(2)(vii)]
Check all that are applicable.
CA/QC for Sampling QAIQC for Analysis
Gloves Sample Splits
Chain-of-custody forms Sample Blanks
New Sampling Tubes Sample Spikes
Field Blanks Other:
Other:
7. Discuss any problems encountered in identification of sample location, collection, and analysis.
8. a. Did any SARI dischargers notify the MA of a hazardous waste discharge? Yes No
[403.120)&(p)]
If yes, summarize.
b. How does the MA notify its users of the hazardous-waste reporting requirement?When was the last time the MA
notified its IUs?
9. a. How and when does the MA evaluate/reevaluate SARI dischargers for the need for a slug discharge control plan?
[403.8(f)(2)(vi)]
Yes No
b. For all existing SIUs identified as significant before November 14, 2005, or within a year
of becoming an SIU (whichever is later), has the MA performed the evaluation to
determine whether each SIU needs a plan or action to control slug discharges?
If not,which SIUs have not been evaluated?
SECTION I: DATA REVIEW(CONTINUED)
G.ENFORCEMENT
1.What is the MA's definition of SNC?[403.8(f)(2)(viii)]
2. ERP implementation: [403.8(f)(5)]
a. Has the ERP been adopted by the MA
b. Has the ERP been approved by SAW PA?
c. Does the ERP describe how the MA will investigate instances of noncompliance?
d. Does the ERP describe types of escalating enforcement responses and the time frames for each response?
e. Does the ERP identify the title of official(s)responsible for implementing each type of enforcement response?
f. Does the ERP reflect the MA's responsibility to enforce all applicable Pretreatment Standards and Requirements?
g. Is the ERP effective, and does it lead to timely compliance?Provide examples if any are available.
Yes No
3. a. Does the MA use compliance schedules? [403.8(f)(1)(iv)(A)]
b. If yes, are they appropriate? Provide a list of SIUs on compliance schedules.
SECTION I: DATA REVIEW (CONTINUED)
G. ENFORCEMENT(continued)
Yes No
4. Did the MA publish all SARI dischargers in SNC in a daily newspaper of general circulation
that
provides meaningful public notice within the jurisdiction served by the POTW in the previous
year? [403.8(f)(2)(viii)]
If yes, attach a copy.
If no, explain.
5. a. How many SARI dischargers are in SNC with self-monitoring requirements and were not inspected
(in the four most recent full quarters)?
b. How many SIUs are in SNC with self-monitoring requirements and were not sampled
(in the four most recent full quarters)?
6. a. Has the MA experienced any problems since the last inspection (interference, collection system problems, overnows,
illicit dumping of hauled wastes or worker health and safety problems)caused by industrial discharges?
b. If yes, describe and explain the MA's enforcement action against IUscausing or contributing to problems.
H. DATA MANAGEMENT/PUBLIC PARTICIPATION
1. How is confidential information handled by the MA?[403.14]
2. How are requests by the public to review files handled?
SECTION I: DATA REVIEW(CONTINUED)
H. DATA MANAGEMENT/PUBLIC PARTICIPATION (continued)
3. Does the MA accept electronic reporting? If no, does it plan to do so?
4. Describe whether the MA's data management system is effective in supporting pretreatment implementation and
enforcement activities.
5. How long are records maintained? [403.12(0)]
I. RESOURCES [403.8(f)(3)]
1. Estimate the number of personnel (in FTEs)available for implementing the program.
Activity FTEs Activity FTEs
Legal Assistance Sample Analysis
Permitting Data Analysis: Review and Response
Inspections Enforcement
Sample Collection Administration
Total Number of FTEs
Yes No
2. Does the MA have adequate access to monitoring equipment?(Consider:sampling,flow
measurement, safety,transportation, and analytical equipment.)
If not, explain.
3. a. Estimate the annual operating budget for the MA's program. $
b. Is funding expected to stay the same, increase, decrease(note time frame; e.g., following year, next 3 years)?
Discuss any changes in funding.
4. Discuss any problems in program implementation that appear to be related to inadequate resources.
SECTION I: DATA REVIEW(CONTINUED)
I. RESOURCES (continued) [403.8(f)(3)] (continued)
5. a. How does the MA ensure that personnel are qualified and up-to-date with current program requirements?
Yes No
b. Does the MA have adequate reference material to implement its program?
Yes No
5. a. Has the MA implemented any kind of public education program?
b. Are there any plans to initiate such a program to educate users about pollution
prevention?
Explain.
6.What efforts have been taken to incorporate pollution prevention into the MA's pretreatment program (e.g.,waste
minimization at IUs, household hazardous waste programs)?
7. Does the MA have any documentation concerning successful pollution-prevention Yes No
programs being implemented by IUs(e.g., case studies, sampling data demonstrating
pollutant reductions)?
Explain.
SECTION I: DATA REVIEW(CONTINUED)
K.ADDITIONAL EVALUATIONS/INFORMATION
K.I. Does your pretreatment program issue permits to any other IUs,or SIUs that DO NOT discharge to the SARI line?
If yes explain
If no:
K.2. Is ther a POTW in your area which accepts domestic, commercial and industrial wastewater from all users that do not
use the SARI line?
If yes explain; (Size of POTW, IP program?, discharge effluent to?)
If no
K.3.Where does these discharges go? Explain.
SECTION I COMPLETED DATE:
BY:
TITLE: TELEPHONE:
SECTION II: IU FILE EVALUATION
INSTRUCTIONS: Select a representative number of SARI discharger files to review. Provide relevant details on each file
reviewed. Comment on all problems identified and any other areas of interest.Where possible, all CIUs (and SIUs)added
since the last PCI or PCA should be evaluated. Make copies of this section to review additional files as necessary.
IU IDENTIFICATION
FILE Industry name and address Type of industry
SIC Code:
NAICS Code:
[ ] CIU 40 CFR Average total flow(gpd) Average process flow
Category(ies)
[ ] Other SIU [ ] Non-SIU [ ] NSCIU Industry visited during audit Yes [ ] No [ ]
Comments
FILE Industry name and address Type of industry
SIC Code:
NAICS Code:
[ ] CIU 40 CFR Average total flow(gpd) Average process flow
Category(ies)
[ ] Other SIU [ ] Non-SIU [ ] NSCIU Industry visited during audit Yes [ ] No [ ]
Comments
i i
SECTION II: IU FILE EVALUATION (CONTINUED)
IU IDENTIFICATION (continued)
FILE Industry name and address Type of industry
SIC Code:
NAICS Code:
[ ] CIU 40 CFR Average total flow(gpd) Average process flow
Category(ies)
[ ] Other SIU [ ] Non-SIU [ ] NSCIU Industry visited during audit Yes [ ] No [ ]
Comments
FILE Industry name and address Type of industry
SIC Code:
NAICS Code:
[ ] CIU 40 CFR Average total flow(gpd) Average process flow
Category(ies)
[ ] Other SIU [ ] Non-SIU [ ] NSCIU Industry visited during audit Yes [ ] No [ ]
Comments
SECTION II: IU FILE EVALUATION (CONTINUED)
IU IDENTIFICATION (wntinued)
FILE Industry name and address Type of industry
SIC Code:
NAICS Code:
[ ] CIU 40 CFR Average total flow(gpd) Average process flow
Category(ies)
[ ] Other SIU [ ] Non-SIU [ ] NSCIU Industry visited during audit Yes [ ] No [ ]
Comments
General Comments
SECTION II: IU EVALUATION (CONTINUED)
Industry Name
INSTRUCTIONS: Evaluate the contents of selected IU files; place an emphasis on SIU files.
Use N/A(Not Applicable)where necessary. Use ND(Not Determined)where there is
insufficient information to evaluate/determine implementation status. Provide comments in
the comment area at the bottom of the page for all violations,deficiencies, and/or other
problems as well as for any areas of concern or interest noted. Enter a comment number in
box and in the comment area at the bottom of the page, followed by the comment.
Comments should delineate the extent of the violation, deficiency, and/or problem.Attach
relevant copies of IU file information for documentation.Where no comment is needed, or if
the item was found to be satisfactory, enter✓ (check)to indicate area was reviewed.The
evaluation should emphasize any areas where improvements in quality and effectiveness
can be made.
File File File File File Reg.
IU FILE REVIEW cite
A. ISSUANCE OF IU CONTROL MECHANISM
1. Control mechanism application form
2. Fad sheet
3. Issuance or reissuance of control mechanism 403.8(f)(1)(iii)
a. Individual control mechanism
b. General control mechanism 403.8(f)(1)(iii)(A)
4. Control mechanism contents 403.8(f)(1)(111)(B)
a. Statement of duration (< 5 years) 403.8(f)(1)(iii)(B)(1)
b. Statement of nontransferability w/o prior 403.8(f)(1)(111)(B)(2)
notification/approval
c. Applicable effluent limits (local limits, categorical standards, 403.8(f)(1)(111)(B)(3)
BMPs
Comments
SECTION II: IU EVALUATION (CONTINUED)
File File File File File Reg.
IU FILE REVIEW Cite
A. ISSUANCE OF IU CONTROL MECHANISM (continued)
d. Self-monitoring requirements 403.8(f)(1)(iii)(13)(4)
• Identification of pollutants to be monitored
• Process for seeking a waiver for pollutant not present or
expected to be present(CIUs only)
• Is the monitoring waiver certification language included in 403.12(e)(2)(v)
the control mechanism?(YIN)
• Are conditions for reinstating monitoring requirements if 403.12(e)(2)(vi)
pollutants not present are detected in the future included in
the permit?(YIN)
• Sampling frequency
Has the POTW reduced the IU's monitoring
requirements for pollutants not present or expected to
not to be present? (Y/N)
• Sampling locations/discharge points
• Sample types (grab or composite)
• Reporting requirements(including all monitoring results)
• Record-keeping requirements
Comments
SECTION II: IU EVALUATION (CONTINUED)
File File File File File Reg.
IU FILE REVIEW Cite
A. ISSUANCE OF IU CONTROL MECHANISM (continued)
e. Statement of applicable civil and criminal penalties 403.8(f)(1)(iii)(B)(5)
f. Compliance schedules/progress reports (if applicable) 403.8(f)(1)(iv)
g. Notice of slug loadings 403.12(f)
h. Notification of spills, bypasses, upsets, etc. 403.16, 403.17
i. Notification of significant change in discharge 403.12(j)
j. Notification of change affecting the potential for a slug 403.8(f)(2)(vi)
discharge
k. 24-hour notification of violation/resample requirement 403.12(g)(2)
I. Slug discharge control plan conditions, if determined by 403.8(f)(1)(iii)(B)(6),
the POTW to be necessary 403.8(f)(2)(vi)
Comments
SECTION It: IU EVALUATION (CONTINUED)
File File File File File Reg.
IU FILE REVIEW cite
A. ISSUANCE OF IU CONTROL MECHANISM (continued)
5. Issuance of General Control Mechanisms 403.8(f)(1)(iii)(A)
a. Involve the same or similar operations
b. Discharge the same types of wastes
c. Require the same effluent limitations
d.Written request by the IU for coverage by a general control
mechanism including:
• Contact information
• Production processes
• Types of waste generated
• Location for monitoring all wastes covered by the general
permit
• Any requests for a monitoring waiver for a pollutant neither
present nor expected to be present
e. Documentation to support the POTW's determination
Comments
SECTION II: IU EVALUATION (CONTINUED)
File File File File File Reg.
IU FILE REVIEW Cite
B. MA APPLICATION OF IU PRETREATMENT STANDARDS
1. IU categorization 403.8(f)(1)(ii)
2. Calculation and application of categorical standards 403.8(f)(1)(ii)
a. Classification by category/subcategory
b. Classification as new/existing source
c.Application of limits for all regulated pollutants
d. Classification as an NSCIU 403.3(v)(2)
e. Documentation for the qualification to be classified as NSCIU
f. Documentation of reasons for supporting sampling wavier for 403.12(2)(iv)
pollutant not present
3.Application of local limits 403.5(c)&(d)&
403.8(f)(1)(ii)
4.Application of BMPs 403.8(f)(1)(iii)(B)(3)
5. Calculation and application of production-based standards 403.6(c)
Comments
SECTION It: IU EVALUATION (CONTINUED)
File File File File File Reg.
IU FILE REVIEW Cite
B. MA APPLICATION OF IU PRETREATMENT STANDARDS (continued)
6. Calculation of equivalent mass limits for concentration limits 403.6(c)(5)
a. IU has demonstrated or will demonstrate substantially reduced 403.6(c)(5)(1)(A)
water usage
b. IU uses control and technologies adequate to achieve 403.6(c)(5)(1)(13)
compliance
c. IU has provided information regarding actual average daily 403.6(c)(5)(1)(C)
flow
d. IU does not have variable flow rates, production levels, or 403.6(c)(5)(i)(D)
pollutant levels
e. IU has consistently complied with applicable categorical 403.6(c)(5)(1)(E)
requirements
f. Did the CA use appropriate flow rates when developing limits? 406.3(c)(5)(iii)(A)
(YIN)
g. Did the CA use the correct concentration-based limits for the 403.6(c)(5)(iii)(B)
applicable categorical standards? (Y/N)
h. Upon notification of revised production rate, did the CA
reassess the mass limits?(YIN)
7. Calculation of equivalent concentration limits for flow-based 403.6(c)(6)
standards
a. Is the IU subject to 40 CFR Part 414,419, or 455? (Y/N)
b. Documentation that dilution is not being used as treatment?
(YIN)
8. Calculation and application of CW F or FWA 403.6(d)&(e)
9. Application of most stringent limit 403.8(f)(1)(ii)
Comments
SECTION It: IU EVALUATION (CONTINUED)
File File File File File Reg.
IU FILE REVIEW Cite
C.CA COMPLIANCE MONITORING
1. Inspection (at least once a year, except as otherwise specified) 403.8(f)(2)(v)
a. If the CA has determined a discharger to be an NSCIU 403.8(f)(2)(v)(B)
• Evaluation of discharger with the definition of NSCIU once per
year
b. If the CA has reduced an IU's reporting requirements 403.8(f)(2)(v)(C)
• Inspect at lead once every 2 years
2. Inspection at frequency specified in approved program 403.8(c)
3. Documentation of inspection activities 403.8(f)(2)(v)
4. Evaluation of need for slug discharge control plan (reevaluation 403.8(f)(2)(vi)
of existing plan)
5. Sampling (at least once a year, except as otherwise specified) 403.8(f)(2)(v)
a. If the CA has waived monitoring for a CIU 403.8(f)(2)(v)(A)
• Sample waived pollutant(s)at least once during the term of
the control mechanism
b. If the CA has reduced an IU's reporting requirements 403.8(f)(2)(v)(C)
• Sample and analyze IU discharge at least once every 2
years
6. Sampling at the frequency specified in approved program 403.8(c)
7. Documentation of sampling activities(chain-of-custody; QAIQC) 403.8(f)(2)(vii)
8.Analysis for all regulated parameters 403.12(g)(1)
9. Appropriate analytical methods(40 CFR Part 136) 403.8(f)(2)(vii)
Comments
SECTION It: IU EVALUATION (CONTINUED)
File File File File File Reg.
IU FILE REVIEW Cite
D.CA ENFORCEMENT ACTIVITIES
1. Identification of violations 403.8(f)(2)(vii)
a. Discharge violations
• IU self-monitoring
• CA compliance monitoring
b. Monitoring/reporting violations
• IU self-monitoring
Reporting (e.g., frequency, content)
— Sampling (e.g.,frequency, pollutants)
Record-keeping
• Notification (e.g., slug, spill, changed discharge, 24-hour notice
of violation)
• Slug discharge control plan
• Compliance schedule/reports
c. Compliance schedule violations
• Start-up/final compliance
• Interim dates
Comments
SECTION It: IU EVALUATION (CONTINUED)
File File File File File Reg.
IU FILE REVIEW Cite
D. CA ENFORCEMENT ACTIVITIES (continued)
2. Determination of SNC(on the basis of rolling quarters) 403.8(f)(2)(viii)
a. Chronic
b. TRC(Technical Review Criteria)
c. Pass through/interference
d. Spill/slug reporting load
e. Reporting
f. Compliance schedule
g. Other violations(e.g., BMPs requirements)
3. Response to violation
4.Adherence to approved ERP 403.8(f)(5)
5. Return to compliance
a.Within 90 days
b.Within time specified
c. Through compliance schedule
6. Escalation of enforcement 403.8(f)(5)(ii)
7. Publication for SNC 403.8(f)(2)(viii)
Comments
SECTION II: IU EVALUATION (CONTINUED)
File File File File File Reg.
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E.IU COMPLIANCE STATUS
1. Self-monitoring and reporting
a. Sampling at frequency specified in control 403.12(e)&(h)
mechanism/regulation
b.Analysis of all required pollutants 403.12(g)(1)&(h)
c.Appropriate analytical methods (40 CFR Part 136)
d.Appropriate sample collection methods
e. Compliance with sample collection holding times
f. Submission of BMR/90-day report 403.12(b)&(d)
g. Periodic sett monitoring reports 403.12(e)&(h)
h. Reporting all required pollutants 403.12(g)(1)&(h)
I. Signatory/certification of reports 403.12(I)
j.Annual certification by NSCIUs 403.12(q)
k. Submission of compliance schedule reports by required 403.12(c)
dates
I. Notification within 24 hours of becoming aware of violations 403.12(g)(2)
• Discharge violation
• Slug load
• Accidental spill
m. Resampling/reporting within 30 days of knowledge of 403.12(g)(2)
violation
n. Notification of hazardous waste discharge 403.120)&(p)
o. Submission/implementation of slug discharge control plan 403.8(f)(2)(vii)
p. Notification of significant changes 403.120)
Comments
SECTION If: IU EVALUATION (CONTINUED)
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E. IU COMPLIANCE STATUS (continued)
2. Compliance with all general control mechanism requirements
3. If the CA has classified the discharger as a middle-tier CIU 403.12(e)(3)
• Categorical flow does not exceed 0.01%of the design dry-
weather hydraulic capacity or 5,000 gpd (whichever is
smaller)
• Categorical flow does not exceed 0.01%of the design dry
weather organic treatment capacity of the POTW
• Categorical flow does not exceed 0.01%of the maximum
allowable headworks loading for any regulated categorical
pollutant
4. If the CA has granted the discharger a monitoring waiver 403.12(e)(2)
• Certification statements with each compliance report
5. Compliance with BMR requirements, if applicable(Y/N)
6. If the CA has classified the discharger as an NSCIU 403.3(v)(2)
IU discharges less than 100 gpd of total categorical
wastewater
• Annual certification statements from the IU
Comments
SECTION II: IU EVALUATION (CONTINUED)
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IU FILE REVIEW Cite
E. IU COMPLIANCE STATUS(continued)
7. If the CA has established equivalent mass limits fora CIU 403.6(c)(5)(ii)
• IU is effectively operating treatment technologies to achieve
compliance
• IU is recording the facility's Flow rates
• IU is recording the facility's production rates
• IU has notifed the CA whenever production rates vary
• IU continues to employ water conservation
methods/technologies
Comments
SECTION II: IU EVALUATION (CONTINUED)
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F.OTHER
Comments
SECTION II COMPLETED BY: DATE:
TITLE: TELEPHONE:
SECTION III: OBSERVATIONS AND CONCERNS
INSTRUCTIONS: On the basis of the information and data evaluated, summarize the observations and concerns of the
audit for each program element shown below. Identify all problems or deficiencies from the evaluation of program
components. Clearly distinguish between deficiencies,violations, and effectiveness issues. This is to ensure that the final
report will clearly identify required actions versus recommended actions and program modifications.
Regulatory Checklist
Description Citation Question(s)
A. CA PRETREATMENT PROGRAM MODIFICATION
• Status of program modifications 403.18 I.A.1
• Modification to the program to accommodate the 2005 General 403.8(f)(1)(iii)(B)(6), I.A.1
Pretreatment Regulation changes 403.8(f)(2)(vi),
403.12(g)
B. LEGAL AUTHORITY
• Minimum legal authority requirements 403.8(f)(1) 1.B.283
• Adequate multijurisdictional agreements 403.8(f)(1) I.13.10
SECTION III: OBSERVATIONS AND CONCERNS (CONTINUED)
Regulatory Checklist
Description Citation Question(s)
C. IU CHARACTERIZATION
• Application of significant industrial user definition 403.3(v)(1) I.C.1;
Attach B.E.2
• Application of middle-tier C/U definition
• Application of NSCIU definition
• Identify and categorize IUs 403.8(0(2)(i)&(ii) I.C.20; II.B
D. CONTROL MECHANISM
• Issuance of individual or general control mechanisms to all SIUs 403.8(f)(1)(iii)
• Adequate control mechanisms 403.8(f)(1)(iii)(B) II.A.4
• Adequate control of trucked, railed, and dedicated pipe wastes 403.5(b)(8) I.D.20, E.1
SECTION III: OBSERVATIONS AND CONCERNS (CONTINUED)
Regulatory Checklist
Description Citation Question(s)
E.APPLICATION OF PRETREATMENT STANDARDS AND REQUIREMENTS
• Appropriately categorize, notify, and apply all applicable pretreatment 403.8(f)(1)(ii)&(iii) 11.13
standards 403.5
• Basis and adequacy of local limits 403.8(f)(4); I.E.3&4
122.21
F. COMPLIANCE MONITORING
• Adequate sampling and inspection frequency Approved I.F.1&2; II.0
program
403.8(f)(2)(ii)&(v)
• Adequate inspections 403.8(f)(2)(v)&(vi) I.F.2&4; II.C.1-3
• Adequate sampling protocols and analysis 403.8(f)(2)(vii) I.F. 5&6; II.C.5-9
SECTION III: OBSERVATIONS AND CONCERNS (CONTINUED)
Regulatory Checklist
Description Citation Question(s)
F.COMPLIANCE MONITORING (continued)
• Adequate IU self-monitoring 403.8(f)(2)(iv) I.F.6,G.5; ILE
• Notification of changed and hazardous waste discharges 403.120)&(p) I.F.8; II.D.1.b
• Evaluate the need for SIUs to develop slug discharge control plans 403.8(f)(2)(vi) I.F.9; II.C.4
• Monitor to demonstrate continued compliance and resampling after 403.12(g)(1)&(2) I I.A.4.j & II.C.5
violation(s) 403.8(f)(2)(vi)
G. ENFORCEMENT
• Appropriate application of significant noncompliance definition 403.8(f)(2)(viii) I.G.1; II.D.2;
Attach B.1.1
• Develop and implement an ERP 403.8(f)(5) I.G.2; II.D.3
• Annually publish a list of Us in SNC 403.8(f)(2)(viii) I.G.4; II.D.7
SECTION III: OBSERVATIONS AND CONCERNS (CONTINUED)
Regulatory Checklist
Description Citation Question(s)
G. ENFORCEMENT(continued)
• Effective enforcement 403.8(f)(5) I.G.2.c, 5&6;
II.D.1.c,4&5
H. DATA MANAGEMENTIPUBLIC PARTICIPATION
• Effective data management/public participation 403.5(c)(3); I.H
403.12(o);403.14
(. RESOURCES
• Adequate resources 403.8(f)(3) I.I
SECTION III: OBSERVATIONS AND CONCERNS (CONTINUED)
Regulatory Checklist
Description Citation Question(s)
J. ENVIRONMENTAL EFFECTIVENESS/POLLUTION PREVENTION
• Understanding of pollutants from all sources I.J.1&3
• Documentation of environmental improvements/effectiveness I,J2
• Integration of pollution prevention
K. ADDITIONAL EVALUATIONSIINFORMATION
SECTION II COMPLETED BY: DATE:
TITLE: TELEPHONE: