HomeMy WebLinkAbout11-28-2012 Board Meeting Agenda - SAWPA Final ReportSAWPA PRETREATMENT PROGRAM
COMPLIANCE AUDIT REPORT
ORANGE COUNTY
SANITATION DISTRICT
CALIFORNIA
November 19, 2012
Santa Ana Watershed Project Authority
Pretreatment Program Compliance Audit Report
November 19, 2012
Prepared for:
Orange County Sanitary District
10844 Ellis Avenue
Fountain Valley, California 92708
Prepared by:
Environmental Engineering & Contracting, Inc.
501 Parkcenter Drive
Santa Ana, California 92705
EEC W2422.01T
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TABLE OF CONTENTS
ES EXECUTIVE SUMMARY ..................................................................................................................... 1 ES.1 Introduction ........................................................................................................................ 1 ES.2 Audit Scope ......................................................................................................................... 1 ES.3 Objective ............................................................................................................................. 2 ES.4 Methods .............................................................................................................................. 2 ES.5 Findings ............................................................................................................................... 2 ES.6 Recommendations .............................................................................................................. 4
1.0 INTRODUCTION ................................................................................................................................ 7
1.1 Background ......................................................................................................................... 7
1.2 Audit Team ......................................................................................................................... 8
2.0 OBJECTIVE, SCOPE, AND METHODS ................................................................................................. 9
2.1 OBJECTIVE ........................................................................................................................... 9
2.2 SCOPE .................................................................................................................................. 9
2.2.1 Santa Ana Watershed Project Authority ............................................................. 10
2.2.2 Member Agencies of the Santa Ana Watershed Project Authority ..................... 10
2.2.2.1 Inland Empire Utilities Agency ................................................................ 11
2.2.2.2 Eastern Municipal Water District ............................................................ 11
2.2.2.3 San Bernardino Valley Municipal Water District .................................... 12
2.2.2.4 Western Municipal Water District .......................................................... 12
2.2.2.5 Jurupa Community Services District ....................................................... 13
2.2.3 Industrial Users .................................................................................................... 13
2.3 METHODS .......................................................................................................................... 15
2.3.1 Orange County Sanitation District Wastewater Discharge Regulations, Ordinance
No. OCSD-39 ........................................................................................................ 16
2.3.2 U.S. Environmental Protection Agency Control Authority Pretreatment Audit
Checklist ............................................................................................................... 16
2.3.3 1991 Memorandum of Understanding ................................................................ 17
2.3.4 1996 Wastewater Treatment and Disposal Agreement ...................................... 17
3.0 FINDINGS AND RECOMMENDATIONS............................................................................................ 17
4.0 CONCLUSION .................................................................................................................................. 39
TABLES
Table 2-1 Industrial User Information and Inspection dates ........................................................... 14
Table 2-2 Summary of Liquid Waste Hauler Collection Stations ..................................................... 15
Table 3-1 Program Administration Findings and Recommendations ............................................... 19
Table 3-2 Permitting Findings and Recommendations .................................................................... 23
Table 3-3 Monitoring Finding and Recommendations .................................................................... 29
Table 3-4 Inspection Findings and Recommendations .................................................................... 32
Table 3- 5 Enforcement Findings and Recommendations ................................................................ 33
Table 3- 6 Data Management Findings and Recommendations ....................................................... 34
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Table 3- 7 Reporting Findings and Recommendations ..................................................................... 35
Table 3- 8 Program QA/QC Findings and Recommendations ........................................................... 36
Table 3- 9 Program Resources Findings and Recommendations ...................................................... 37
FIGURES
Figure 1 Santa Ana River Watershed Location Map
Figure 2 Santa Ana Watershed Authority Project Member Agencies
Figure 3 Inland Empire Brine Line and Connections
APPENDICES
Appendix A OCSD Wastewater Discharge Regulations Ordinance No. OCSD-39
Appendix B 1991 Memorandum of Understanding Summary
Appendix C 1996 Wastewater Treatment and Disposal Agreement Summary
Appendix D Control Authority Pretreatment Audit Checklist, February 2010
Appendix E Direct Industrial User Inspection Form
Appendix F Indirect Industrial User Inspection Form
Appendix G Industrial User Inspection Reports
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ES EXECUTIVE SUMMARY
ES.1 Introduction
The Orange County Sanitary District (OCSD) has retained Environmental Engineering & Contracting, Inc.
(EEC) to perform a comprehensive audit of the Santa Ana Watershed Project Authority’s (SAWPA’s)
compliance with all the requirements, responsibilities, and practices as specified in OCSD’s Wastewater
Discharge Regulations Ordinance No. OCSD-39 as well as in the agreements between OCSD and SAWPA;
namely, the 1991 Memorandum of Understanding (1991 MOU) and the 1996 Wastewater Treatment
and Disposal Agreement (1996 Agreement; Appendix A, OCSD Wastewater Discharge Regulations
Ordinance No. OCSD-39; Appendix B, 1991 Memorandum of Understanding Summary; Appendix C, 1996
Wastewater Treatment and Disposal Agreement Summary).
The audit also includes an investigation and description of SAWPA’s role. In addition to acting as an
oversight authority for the member agencies that administer local industrial pretreatment activities on
direct and indirect industrial dischargers to the Santa Ana River Interceptor (SARI) Line, also known as
the Inland Empire Brine Line (IEBL), SAWPA regulates local liquid waste hauling companies and the Chino
II desalter facility.
To assist in performing the audit, EEC retained Pretreatment Solutions Inc. (PSI) to create an audit team
with more than 30 years of auditing experience and more than 25 years of pretreatment expertise. EEC
conducted this audit in accordance with generally accepted government auditing standards and United
States Environmental Protection Agency (USEPA) guidelines.
ES.2 Audit Scope
The audit consisted of an evaluation of SAWPA’s compliance with all the pertinent requirements,
responsibilities, and practices and all other applicable regulations, including federal regulations (Title 40
of the Code of Federal Regulations [CFR], Section 403), OCSD ordinances, and contractual agreements
between OCSD and SAWPA. The audit included all of SAWPA’s delegated member agencies; namely, the
Inland Empire Utility Agency (IEUA), the Eastern Municipal Water District (EMWD), the San Bernardino
Valley Municipal Water District (SBVMWD) and the Western Municipal Water District (WMWD).
The evaluation of SAWPA’s and its member agencies’ pretreatment program included all elements of
the program:
Administration: policies, procedures, and workflows both internally and with SAWPA as the
oversight authority.
Permitting: permitting process and review of a sample of existing permits.
Monitoring: monitoring program, including self-monitoring and monitoring by SAWPA.
Inspection: inspection program and example documents, including a field audit of 16 of
SAWPA’s and its member agencies’ permitted facilities.
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Enforcement: enforcement response plan and its implementation with a review of the latest
cases of significant noncompliance. In particular, the case of serious noncompliance involving
the Corona Resource Recovery facility was reviewed.
Data Management: review of all types of compliance reports as required by the pretreatment
program.
Reporting: quarterly and annual reporting of permitting and compliance status to OCSD.
Quality Assurance / Quality Control (QA/QC): review of implemented QA/QC measures
throughout the program.
Resources: assessment of the adequacy of qualifications and resources to implement an
effective pretreatment program that ensures compliance with all applicable requirements.
ES.3 Objective
The primary objective of this comprehensive compliance audit of SAWPA’s Pretreatment Program is to
identify and address any deficiencies or omissions in the administration, implementation, and
enforcement of any of the applicable requirements and regulations.
In order to address the identified omissions, EEC made recommendations to improve the overall
pretreatment program. The recommendations, if properly and consistently implemented, will ensure
consistent and long-term compliance and ultimately protect OCSD’s treatment plant and its receiving
waters while maintaining a viable solution for the nonreclaimable wastewater (brine) generated in the
Santa Ana Watershed. Whenever encountered, best management practices (BMPs) were also described
and presented in the findings.
ES.4 Methods
The methodology followed by the audit team in performing the audit is similar to the methodology
followed by the USEPA and the RWQCB and as generally outlined in the USEPA’s Control Authority
Pretreatment Audit Checklist and Instructions document, dated February 2010 (Appendix D, Control
Authority Pretreatment Audit Checklist, February 2010).
Interviews were conducted with the 4 member agencies first and then with SAWPA. Following the
interviews, the audit team inspected 12 industrial user sites and all 4 liquid waste-hauler (LWH)
collection stations.
The documents used by the audit team during the interviews and inspections comprised the USEPA’s
checklist and instructions, OCSD’s Wastewater Discharge Regulations ordinance, the 1991 MOU, and the
1996 Agreement.
ES.5 Findings
During the pre-audit meeting with SAWPA and in all subsequent meetings, SAWPA’s staff cooperated
with the audit team and expressed willingness to address the audit findings for the purpose of
improving its overall pretreatment program. Similarly, all member agencies cooperated with the audit
team and expressed the same desire to use the audit findings to improve their pretreatment programs.
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The audit team was granted full and unrestricted access to all 16 industrial user facilities selected by the
audit team and OCSD. In regard to the Corona Resource Recovery, the audit team’s investigative efforts
were met with a limited flow of information.
In general, the audit revealed that SAWPA and/or its member agencies did not always follow important
program requirements. Some of the deficiencies were reportedly corrected after identification by the
audit team during the interviewing process. The verification of corrected deficiencies was not in the
scope of this audit and should be addressed in the corrective action plan follow-up and in future audits.
Specific findings include the following:
1. In assessing SAWPA’s administration of its pretreatment program, the audit team noted that the
multijurisdictional pretreatment agreements among SAWPA and its 4 member agencies, that is,
the IEUA, the EMWD, the SBVMWD, and the WMWD, are not all valid and don’t necessarily give
the power to SAWPA and/or the member agencies to carry out enforcement actions in areas
under the jurisdiction of SAWPA’s member agencies.
2. The audit also revealed that SAWPA allowed a major discharger into the IEBL, the Corona
Resource Recovery (CRR), to discharge mining waste into the IEBL. The waste originated from
outside the SAWPA service area and consisted of mining waste that was inaccurately referred to
as “brine” waste. The origin and nature of the waste warranted a higher level of due diligence
than that demonstrated by SAWPA and WMWD in the permitting process. At a minimum,
SAWPA should have requested a complete waste stream characterization based on a detailed
description of the process generating the waste. In addition, because of the large quantity of
waste under consideration, SAWPA and/or WMWD should have performed an on-site
assessment of all waste generating processes at the Molycorp’s Mountain Pass facility to
confirm the information provided by CRR. In order to categorically determine all the facts
surrounding the CRR issue including any correlation between the excursions in arsenic level in
OCSD’s biosolids and the discharge of the Molycorp’s waste, access to all records maintained by
SAWPA, WMWD and Molycorp pertaining to the CRR issue should be granted.
3. On the program administration level, SAWPA has retained G&G Environmental Compliance, Inc.
to develop and implement SAWPA’s pretreatment program. Two of the member agencies,
SBVMWD and WMWD, have also retained G&G Environmental Compliance, Inc. to develop and
implement their pretreatment programs as they relate to the IEBL. Furthermore, the same
individuals from G&G Environmental Compliance, Inc. who were working for SAWPA were also
working, at the same time, for SBVMWD and WMWD. With such arrangement, it is virtually
impossible for SAWPA to maintain jurisdiction and control over all of its member agencies,
including SBVMWD and WMWD.
4. In many instances, permits were not properly prepared and were sometimes based on
inaccurate and erroneous information. Some permit errors constitute serious deficiencies, such
as misidentification of the applicable categorical pretreatment standards, referencing the
incorrect ordinance, and elimination of monitoring requirements.
5. Monitoring deficiencies were encountered at all levels of the program for SAWPA, WMWD, and
SBVMWD. Deficiencies included lack of monitoring of field equipment, such as pH and flow
meters as well as insufficient monitoring of wastewater discharges.
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6. Inspections that are currently performed by the member agencies are scheduled in advance and
do not always reveal changes and modifications to a process or a facility.
7. Enforcement plans currently in place may lack the legal authority, under the current
multijurisdictional agreements, for SAWPA to carry out enforcement actions, including collecting
fines.
8. Data management has been lacking and has negatively affected the collaboration between
SAWPA and OCSD. In addition, the lack of traceability makes quality checking very difficult and
ineffective at identifying errors.
9. Required reviews of compliance data were not performed in a timely fashion and enforcement
and resampling requirements were not performed or were performed very late.
10. Reporting by SAWPA to OCSD on a monthly basis only resumed at the outset of this audit. The
1991 MOU clearly states that SAWPA must provide monthly reports detailing the number and
identification of new and existing permittees, inspections, enforcement actions, and monitoring
data.
11. QA/QC measures were lacking throughout the program, especially within SAWPA’s program and
the IEBL pretreatment programs for WMWD and SBVMWD.
12. Human resources and expertise necessary to implement an adequate pretreatment program are
lacking in SAWPA’s organization as well as in the WMWD’s and SBVMWD’s organizations.
ES.6 Recommendations
Overall, major improvements should be implemented at all levels of the pretreatment program to
ensure compliance with all applicable requirements and provide the highest level of protection for the
IEBL and OCSD’s treatment facility. Such improvements, if properly and continuously implemented,
would minimize the risk of a repeated instance of serious violations, as was the case with Corona
Resource Recovery.
On the program administration level, SAWPA must develop and implement the necessary improvements
to its pretreatment program. EEC also recommends that SAWPA manage all aspects of the pretreatment
program rather than delegating permitting, monitoring, and enforcement responsibilities to its member
agencies. This centralized management approach would give SAWPA the necessary control, but the
legality of multijurisdictional agreements allowing enforcement actions and the levying of fines must be
addressed.
Alternatively, SAWPA could continue to manage its program through multijurisdictional agreements
with some or all of its member agencies, but this option is not recommended because it yields a lower
level of compliance and protection. Such arrangement relieves SAWPA from the responsibility of issuing
permits and monitoring compliance, but would require SAWPA to closely monitor the performance of its
member agencies and to conduct announced and unannounced inspections at industrial user facilities.
In either arrangement, it is highly recommended for SAWPA to either acquire adequately qualified staff
dedicated to SAWPA’s pretreatment program and/or to retain a qualified consultant who is not retained
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by any of its member agencies. At all times, SAWPA must ensure that any conflict of interest is
eliminated and that it fulfills its role in providing additional control and program supervision.
Permits are control instruments that must be properly prepared and based on accurate and
comprehensive information concerning the industrial user. SAWPA should adopt a uniform permit fact
sheet and permit format that addresses all applicable requirements in the federal and state regulations, in
OCSD’s ordinance, in the 1991 MOU, and in the 1996 Agreement requirements. It is also recommended
that the practice of an agency issuing permits to itself for the control and monitoring of its LWH collection
station or its own industrial facility cease throughout SAWPA’s service area. Typically, and as observed in
this audit, such a practice leads to many instances of noncompliance due to the inherent lack of control
and monitoring.
Monitoring at all levels of the pretreatment program must be improved. The level of monitoring by IEUA
and EMWD is adequate, but it is lacking among SAWPA, SBVMWD, and WMWD. SAWPA must develop
and implement procedures for the regular calibration and maintenance of equipment, for the sampling
and testing of wastewater, for gathering information and issuing permits, and for all other activities that
can ensure compliance and a higher level of protection to the IEBL and OCSD’s treatment and receiving
waters. SAWPA must regularly monitor the proper implementation of all adopted procedures.
Inspections should consist of a critical examination of the industrial user facility and manufacturing
processes. The announced inspections currently performed by the member agencies do not always
reveal all changes and modifications. A minimum number of inspections must be unannounced in order
to capture facts and information that are more representative of normal operating conditions at the
industrial user facilities. The actual number of inspections should be determined in light of the nature of
the inspections and the potential risk present.
Enforcement plans that are currently in place for SAWPA and its member agencies must undergo a legal
review to assess the effectiveness of the plans under the current multijurisdictional agreements.
Enforcement plans must also contain a clear procedure to determine if a violation is considered an
instance of significant noncompliance, to identify and undertake a timely and appropriate response and
to document resolution of noncompliance. Enforcement response planning is a critical portion of every
ordinance and is ultimately SAWPA’s responsibility to implement.
Data management must be improved to increase the level of collaboration and work transferability
between SAWPA and OCSD. Traceability also must be improved to facilitate quality checking.
Reporting by SAWPA to OCSD must resume and continue on a monthly basis. As required in the 1991
MOU, SAWPA must provide monthly reports detailing the number and identification of new and existing
permittees, inspections, enforcement actions, and monitoring data. SAWPA and OCSD must agree on a
report format for smooth and effective transfer of information.
QA/QC measures specific to the IEBL must be implemented by SAWPA throughout its pretreatment
program. SAWPA’s primary mission should be to effectively oversee and carry out a robust quality
system and quality management plan, including QA/QC activities at the industrial user level. SAWPA
should also regularly review its implemented QA/QC measures.
Resources to develop and implement an adequate pretreatment program for SAWPA are critically
needed. SAWPA must acquire qualified staff and/or retain a qualified consultant with expertise in both,
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pretreatment as well as program management. If SAWPA chooses to retain a qualified consultant,
SAWPA will still need to elevate the pretreatment expertise of its staff members responsible for
managing the consultant.
EEC has estimated that, if SAWPA chooses to manage the entire IEBL pretreatment program with the
current number of permittees, it would need a total of three full-time equivalent (FTE) employees (staff
and/or consultants) the first year in order to develop and implement its pretreatment program without
passing on any responsibility to member agencies. The 3 FTEs would be comprised of a clerical position
mainly for invoicing, data management, and reporting; a junior staff position focusing primarily on
permitting and inspections; and a program manager to develop and oversee the program, review
permits, and liaise with OCSD and member agencies. It is expected that, after the first year, SAWPA
would need fewer employees to manage the same number or permittees.
The audit findings have been verbally shared with SAWPA and the member agencies throughout the
audit, and SAWPA is currently in the process of addressing many of the audit findings. Starting with the
recommended corrective actions presented in the report, SAWPA could begin to develop its own
corrective action plan and schedule specific to the audit findings. Alternatively, OCSD could, as specified
in the 1991 MOU Section 6.D, develop and issue SAWPA a remedial plan with a time schedule for
attaining compliance since SAWPA has failed or has refused to fulfill key pretreatment requirements. In
either case, follow-up audits by OCSD should be scheduled to determine whether the corrective actions
are being implemented adequately and on schedule.
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1.0 INTRODUCTION
SAWPA was formed in 1968 as a planning agency and was reformed in 1972 with a mission to plan and
build facilities to protect the water quality of the Santa Ana River Watershed. SAWPA is a Joint Powers
Authority, classified as a Special District (government agency) in which it carries out functions useful to
its member agencies. The agreements formalizing the current agency were signed in 1974 and went into
effect in 1975.
SAWPA’s program in water quality management is integrated with those of other local, state, and
federal agencies. SAWPA’s integrated program includes the Western Riverside County Regional
Wastewater Reclamation Plant, the Stringfellow Site Treatment Plant, and the IEBL. This report
addresses SAWPA’s management of the IEBL program only and does not discuss any of SAWPA’s other
programs.
The IEBL (also known as the Santa Ana Regional Interceptor, or SARI) is intended to provide a cost-
effective, sustainable means of disposal of nonreclaimable waste water for utilities and industry within
the Santa Ana Watershed (Figure 1, Santa Ana River Watershed Location Map).
The highest and best use of the IEBL is the removal of salts from the watershed to keep the salts from
degrading water quality within the watershed, thereby allowing better use of groundwater resources
and expanding the ability to reclaim water. The long-term goal of achieving salt balance within the
region depends on the ability to remove salts from the watershed via groundwater desalters and the
IEBL. Further use of desalters depends on an economical means of salt disposal and will ultimately
depend on an economically viable regional IEBL.
Wastewater is discharged into the IEBL either directly or indirectly. Direct-discharge industrial users are
located close enough to the IEBL to construct a direct-connection and produce enough high total
dissolved solids waste to economically justify the connection cost. Indirect-discharge industrial users are
not located close enough to the IEBL to make a direct connection. Indirect users dispose of their liquid
waste at one of the four IEBL LWH collection stations using a permitted commercial waste hauler. The
volume of wastewater generated by indirect dischargers can vary from one or two truckloads per week
to 100,000 gallons per day. Every discharger within the SAWPA service area is located less than 20 miles
from an LWH collection station (Figure 2, Inland Empire Brine Line and Connections).
The nonreclaimable waste water from utilities and industry within the Santa Ana Watershed is
transported via the IEBL to treatment plants operated by the OCSD. After treatment by OCSD, the
effluent is discharged to the Pacific Ocean.
Pretreatment enforcement and reporting responsibilities between SAWPA and OCSD are delineated in
OCSD’s Wastewater Discharge Regulations Ordinance, the 1991 Memorandum of Understanding (1991
MOU) and the 1996 Wastewater Treatment and Disposal Agreement (1996 Agreement; Appendices A, B,
and C).
1.1 Background
Major infractions by SAWPA of the provisions of the 1996 Agreement and 1991 MOU between OCSD
and SAWPA have been noted recently. Over a period of four months, WMWD, with SAWPA’s approval,
allowed Corona Resource Recovery to discharge mining wastes received from outside the SAWPA
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service area without written approval from OCSD as required in the 1996 Agreement and without
issuing a permit with the correct categorical discharge limits. The discharge to OCSD totaled more than 9
million gallons. Neither SAWPA nor WMWD initially collected samples to confirm the content of the
wastewater nor was an inspection of the mining operation conducted. As a result, OCSD issued a cease-
and-desist order to SAWPA. Aside from SAWPA’s improper administration of its duties as an oversight
authority over member agencies, coincidental to this time frame, OCSD experienced excursions in
arsenic level in its biosolids, which may impact biosolids reuse options.
While addressing the arsenic situation, OCSD determined that SAWPA failed to comply with provisions in
the Code of Federal Regulations for pretreatment of point sources. OCSD also determined that SAWPA
violated the contractual agreements between the two agencies (1991 MOU and 1996 Agreement) and
OCSD’s local ordinances.
In accordance with the 1991 MOU, OCSD exercised its right to review SAWPA’s pretreatment program.
The purpose of the review is for OCSD to ensure that SAWPA and/or any other agency having discharge
rights to the IEBL system pursuant to the contract with SAWPA is adequately administering and
diligently enforcing its pretreatment program in conformance with federal pretreatment regulations (40
CFR 403) and OCSD requirements.
In order to review SAWPA’s pretreatment program, OCSD retained EEC to perform a comprehensive
audit of SAWPA’s compliance with all the requirements, responsibilities, and practices specified in the
OCSD ordinance, the 1991 MOU, and the 1996 Agreement; the audit examined SAWPA’s role as the
oversight authority and the pretreatment programs of SAWPA and its member agencies.
EEC, located in Santa Ana, California, specializes in providing wastewater, including pretreatment,
consulting services to municipalities and industries. For the purpose of conducting the audit, EEC
retained Pretreatment Solutions, Inc. to form a team with a high level of expertise in both pretreatment
and auditing.
1.2 Audit Team
The audit team is composed of specialists with complementary skills to ensure a thorough review of a
complex pretreatment program. The team included Mr. John Shaffer and Mr. Najib Saadeh of EEC and
Dr. John Parnell of Pretreatment Solutions, Inc.
Mr. Shaffer, President of EEC, served as the project manager for this project. He has managed many of
EEC’s past pretreatment consulting projects, including those for which EEC has teamed with
Pretreatment Solutions, Inc. Mr. Shaffer has been a Southern California wastewater consultant for more
than 20 years and is very familiar with the relationship between OCSD and SAWPA and with the IEBL
project. Mr. Shaffer and Dr. Parnell recently collaborated to evaluate and upgrade the pretreatment
program of Salt Lake City, Utah, and the pretreatment ordinance and enforcement response plan for the
City of Ventura, California.
Dr. Parnell of Pretreatment Solutions, Inc. served as the project technical lead due to his extensive
experience in all areas related to pretreatment: program administration, ordinance and local limits
development, permitting, inspections, monitoring, enforcement, reporting, and training. Before
becoming a consultant, Dr. Parnell expanded the pretreatment program for the City of St. Petersburg,
Florida, and he was the industrial pretreatment coordinator there for 17 years.
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Mr. Saadeh, senior regulatory specialist at EEC, served as the project audit lead due to his extensive
experience in audits of industrial facilities and evaluation of compliance programs for major
multinational corporations and public utilities. Mr. Saadeh has more than 20 years of experience in
compliance and management systems auditing.
2.0 OBJECTIVE, SCOPE, AND METHODS
The audit objective, scope, and methods were established in agreement between the audit team and
OCSD and communicated to SAWPA and its member agencies prior to and during the opening interviews.
The audit was initiated on August 7, 2012, with a pre-audit meeting with SAWPA. The opening interview
with SAWPA was scheduled after the interviews with the member agencies. This allowed the audit team
to gain a better understanding of the way the program was being implemented prior to assessing
SAWPA’s role in overseeing the complete program.
2.1 Objective
The objective of this audit is to assess the measures and controls that SAWPA and its member agencies
are currently applying to ensure compliance with all applicable regulations and contractual agreements.
The recommendations made by EEC do not only address deficiencies and omissions, but also include
best management practices (BMP). Sharing BMPs among the agencies leads to an overall program
improvement and is therefore encouraged.
If properly followed, the recommendations would ensure consistent and long-term compliance that
would ultimately protect the IEBL and OCSD’s treatment system and receiving waters while maintaining
a viable solution for the brine generated in the Santa Ana Watershed.
2.2 Scope
The audit examined all elements of SAWPA’s and its member agencies’ pretreatment programs:
Administration: assessment of policies, procedures, and workflows both internally and with SAWPA as
the oversight authority; data management; pollution prevention/BMP programs; public participation;
previous USEPA audits or findings; maps and geographic information system data of SAWPA’s and its
member agencies’ service areas, plants, and LWH collection stations; any recent pretreatment program
modifications; summary of which 2005 General Pretreatment Regulation options were adopted;
description of programs and projects SAWPA is undertaking to improve the watershed; and any other
pertinent documents relating to SAWPA’s authority as the oversight agency.
Permitting: review of permitting process, industrial user inventory identification and verification,
category determination, examination of slug control plan, determination whether the existing permits
comply with all applicable requirements, and example documents.
Monitoring: verification of monitoring program, including permittee self-monitoring and monitoring by
SAWPA; monitoring parameters included sampling frequency, constituents monitored, proper sampling
and preservation techniques, using appropriate analytical methods, chain-of-custody procedure, and
example documents.
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Inspection: review of inspection program and example documents, including a field audit of 16 of
SAWPA’s and its member agencies’ permitted facilities.
Enforcement: evaluation of enforcement and implementation of response plan, latest Significant
Noncompliance publication, periodic technical review of compliance, and example documents.
Data management: review of all types of compliance reports as required by the pretreatment program.
QA/QC: QA/QC of all programs and example documents.
Resources: assessment of the adequacy of qualifications and resources to implement an effective
pretreatment program that complies with all applicable laws and regulations, including obtaining an
organizational chart and list of qualifications of staff involved.
2.2.1 Santa Ana Watershed Project Authority
The audit team evaluated whether SAWPA, as an oversight agency, developed and implemented
sufficient measures to ensure that each of its member agencies and all others that discharge to the IEBL
are complying with the terms and conditions of all applicable agreements and regulations, including
OCSD ordinances and federal pretreatment regulations (40 CFR 403).
EEC also identified and itemized all requirements, responsibilities, and practices related to ensuring that
SAWPA is taking the appropriate measures to ensure that the wastewater quality is in compliance with
the OCSD ordinance, the 1991 MOU, and the 1996 Agreement.
EEC also evaluated SAWPA’s developed and implemented measures to ensure that discharges through
the LWH collection stations are complying with the terms and conditions of all applicable agreements
and regulations.
The opening audit interview with SAWPA was held on August 29, 2012. The following representatives
from SAWPA and from G&G Environmental Compliance, Inc. (SAWPA’s consultant) were present:
Mr. Rich Haller, SAWPA, Executive Manager of Engineering and Operations
Mr. Gary Ethridge, G&G Environmental Compliance, Inc., President
Mr. Gary W. DeFrese, G&G Environmental Compliance, Inc., Vice President
Mr. Benjamin Burgett, G&G Environmental Compliance, Inc., Environmental Compliance Inspector
The following individuals from the audit team were present:
Mr. John Shaffer, EEC, President
Mr. Najib Saadeh, EEC, Senior Regulatory Specialist
Dr. John Parnell, Pretreatment Solutions, Inc., Principal
2.2.2 Member Agencies of the Santa Ana Watershed Project Authority
SAWPA has entered into multijurisdictional pretreatment agreements with its four member agencies;
namely, the IEUA, the EMWD, the SBVMWD, and the WMWD (Figure 3, SAWPA Member Agencies).
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IEUA was originally named the Chino Basin Municipal Water District, which was formed in 1950 to
supply supplemental water to the Chino Basin. On July 1, 1998, the Chino Basin Municipal Water District
officially became the Inland Empire Utilities Agency. IEUA permits 9 direct industrial users and 10
indirect industrial users. LWHs permitted by SAWPA transport wastewater from the indirect industrial
users to the SAWPA-approved collection station at 16400 El Prado Road in Chino in IEUA’s service area.
2.2.2.1 Inland Empire Utilities Agency
The opening interview with the IEUA was held on August 23, 2012. The following representatives from
IEUA and SAWPA were present:
Mr. Craig Procter, IEUA, Pre-Treatment and Source Control Supervisor
Ms. Pari Dezham, IEUA, Pre-Treatment and Source Control Manager
Mr. Kenneth Tam, IEUA, Assistant Engineer
Mr. Martyn Draper, IEUA, Senior Pre-Treatment and Source Control Inspector
Mr. Michael Barber, IEUA, Pre-Treatment and Source Control Inspector
Mr. Rich Haller, SAWPA, Executive Manager of Engineering and Operations
The following representatives from the audit team were present:
Mr. Najib Saadeh, EEC, Senior Regulatory Specialist
Dr. John Parnell, Pretreatment Solutions, Inc., Principal
2.2.2.2 Eastern Municipal Water District
EMWD was formed in 1950. EMWD permits seven direct industrial users and three industrial users.
LWHs transport wastewater from the indirect industrial users to SAWPA’s approved collection station
located at 29541 Murrieta Road in Sun City in EMWD’s service area.
The opening interview with EMWD was held on August 21, 2012. The following representatives from the
EMWD and SAWPA were present:
Mr. Gregg Murray, EMWD, Source Control Manager
Ms. Judy Lankey, EMWD, Senior Source Control Inspector
Ms. Scarlett Draper, EMWD, Assistant
Mr. Dennis Martz, EMWD, Source Control Inspector
Mr. Victor Capata, EMWD, Environmental Compliance Analyst
Mr. David Trujillo, EMWD, Source Control Inspector II
Mr. Rich Haller, SAWPA, Executive Manager of Engineering and Operations
The following representatives from the audit team were present:
Mr. Najib Saadeh, EEC, Senior Regulatory Specialist
Dr. John Parnell, Pretreatment Solutions, Inc., Principal
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2.2.2.3 San Bernardino Valley Municipal Water District
The SBVMWD was formed in 1954 as a regional agency to plan a long-range water supply for the San
Bernardino Valley. SBVMWD permits 5 direct industrial users (4 active users and 1 emergency user).
SBVMWD has delegated the management of indirect dischargers to the City of San Bernardino Municipal
Water Department (CSBMWD). The CSBMWD permits the 18 indirect industrial users to transport
wastewater to SAWPA’s approved collection station within the CSBMWD’s water reclamation plant
located at 399 Chandler Place in San Bernardino. SBVMWD issues the permits for direct users. The
permits for the indirect users are issued by CSBMWD but they are co-signed by SBVMWD.
The opening interview with SBVMWD was held on August 22, 2012. The following representatives from
SBVMWD, SAWPA, CSBMWD, and G&G Environmental Compliance, Inc. (SBVMWD’s consultant) were
present:
Mr. Robert Tincher, SBVMWD, Manager of Engineering and Planning
Mr. Andy Coady, CSBMWD, Environmental Control Officer
Mr. Michael Placentia, CSBMWD, Environmental Control Technician
Mr. Gary W. DeFrese, G&G Environmental Compliance, Inc., Vice President
Mr. Benjamin Burgett, G&G Environmental Compliance, Inc., Environmental Compliance
Inspector
Mr. Rich Haller, SAWPA, Executive Manager of Engineering and Operations
The following representatives from the audit team were present:
Mr. Najib Saadeh, EEC, Senior Regulatory Specialist
Dr. John Parnell, Pretreatment Solutions, Inc., Principal
2.2.2.4 Western Municipal Water District
The WMWD was formed in 1954 and serves customers and wholesale agencies from Corona to
Temecula. WMWD permits 22 direct industrial users and 18 indirect industrial users. LWHs transport
wastewater from the indirect industrial users to SAWPA’s approved collection station located at the City
of Corona Water Reclamation Plan No. 1 at 2480 Railroad Street, in Corona.
The opening interview with WMWD was held on August 28, 2012. The following representatives from
WMWD, SAWPA, and G&G Environmental Compliance, Inc. (WMWD’s consultant) were present:
Mr. Joe Bernosky, WMWD, Director of Engineering
Mr. Gary W. DeFrese, G&G Environmental Compliance, Inc., Vice President
Mr. Benjamin Burgett, G&G Environmental Compliance, Inc., Environmental Compliance Inspector
Mr. Rich Haller, SAWPA, Executive Manager of Engineering and Operations
The following representatives from the audit team were present:
Mr. John Shaffer, EEC, President
Mr. Najib Saadeh, Environmental Engineering & Contracting, Inc., Sr. Regulatory Specialist
Dr. John Parnell, Pretreatment Solutions, Inc., Principal
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2.2.2.5 Jurupa Community Services District
The Jurupa Community Services District (JCSD) was founded in 1956. The JCSD is a public agency known
as a Special District. JCSD permits seven direct industrial users that discharge into its sewer system prior
to discharging into the IEBL.
The JCSD sewer system connects industrial users in the JCSD area to the IEBL. The JCSD operates within
WMWD’s service area. WMWD granted JCSD the right to issue permits and conduct monitoring. JCSD’s
pretreatment program, as it relates to the IEBL, was not assessed directly but through interviews with
the WMWD and a review of the permits issued by JCSD. The audit team further evaluated JCSD’s
pretreatment program through an inspection of one of JCSD’s permitted facilities, Metal Container Corp.
in Mira Loma, California. JCSD staff was not directly audited or interviewed.
2.2.3 Industrial Users
The audit team inspected 16 of the 106 Industrial users that were permitted at the time of the audit.
The inspections included 8 direct dischargers, 4 indirect dischargers, and all 4 LWH collection stations
(each permitted and operated by a separate member agency). Inspection forms were developed based
on guidance from the USEPA and used during the site visits (Appendix E, Direct Industrial User Inspection
Form, and Appendix F, Indirect Industrial User Inspection Form).
Inspection of industrial users is key to evaluate adequately an agency’s compliance with applicable
federal and local regulations and requirements. The number of inspections is consistent with the typical
USEPA pretreatment compliance inspection level of effort (the Control Authority Pretreatment Audit
Checklist and Instructions document also suggests that two inspections per agency is typically sufficient).
Initially, 11 facilities were selected by OCSD for inspections, but 5 additional facilities were subsequently
selected and added to the scope after OCSD’s review and approval. The 5 facilities consisted of two LWH
collection stations and three power generation plants. Overall, the inspections focused on the facilities
that present a potentially higher risk to the IEBL such as significant industrial users and LWH collection
stations.
The comprehensive site inspections also included a detailed file review prior to each site visit and
followed applicable elements of the USEPA’s Control Authority Pretreatment Audit Checklist and
Instructions. All collection stations were inspected in order to evaluate measures implemented for
ensuring that discharges through these stations comply with the terms and conditions of all applicable
agreements and regulations.
Although LWH information was evaluated as part of LWH collection station inspections, investigations
and audits of individual LWHs were not included in the scope of the audit.
A detailed report was produced following each inspection (Appendix G, Industrial User Inspection
Reports). Except where prohibited, photographs were taken at all sites visited by the audit team. The
audit findings have been verbally shared with SAWPA and the member agencies throughout the audit,
and SAWPA is currently in the process of addressing many of the findings presented in this report.
Starting with the recommended corrective actions presented in the report, SAWPA could begin to
develop its own corrective action plan and schedule specific to the audit findings. Alternatively, OCSD
could, as specified in the 1991 MOU section 6.D., develop and issue SAWPA a remedial plan with a time
schedule for attaining compliance since SAWPA has failed or has refused to fulfill key pretreatment
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requirements. In either case, follow-up audits by OCSD should be scheduled to determine whether the
corrective actions are being implemented adequately and on schedule.
Information on the industrial users and the date of the inspections are presented in Table 2-1, Industrial
User Information and Inspection Dates.
Table 2-1, Industrial User Information and Inspection Dates
Inspected Facility Control Agency Inspection Date (2012) Discharge Type
SBVMWD LWH Collection station CSBMWD August 22 Collection station
IEUA LWH Collection station IEUA August 23 Collection station
RP No. 5 Solids Handling IEUA August 23 Direct
Angelica Textile Services SBVMWD August 27 Indirect
Metal Container Corp JCSD August 27 Direct
Corona Energy Partners Ltd. WMWD August 28 Direct
Dairy Farmers of America (former
Corona Resources Recovery) WMWD August 28 Direct
Frontier Aluminum WMWD August 28 Indirect
Sierra Aluminum Company WMWD August 29 Indirect
Chino II Desalter SAWPA August 29 Direct
International Rectifier EMWD August 30 Indirect
EWMD LWH Collection station EMWD August 30 Collection station
Inland Empire Energy Center EMWD September 6 Direct
Mountainview Generating Station WMWD September 10 Direct
WMWD LWH Collection station WMWD September 10 Collection station
OLS Energy - Chino IEUA September 13 Direct
Key:
CSBMWD = City of San Bernardino Municipal Water District
EMWD = Eastern Municipal Water District
IEUA = Inland Empire Utilities Agency
JCSD = Jurupa Community Services District
LWH = liquid waste hauler
SAWPA = Santa Ana Watershed Project Authority
SBVMWD = San Bernardino Valley Municipal Water District
WMWD = Western Municipal Water District
In addition, for the LWH collection stations, the specific features of each station and the manner in
which it is managed by the member agencies are presented in Table 2-2, Liquid Waste Hauler Collection
Station. Some collection stations are completely automated while others are staffed. Also, the level of
security for access and the frequency of monitoring for wastewater vary among stations.
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Table 2-2, Summary of Liquid Waste Hauler Collection Station
Feature
EWMD
LWH Collection
Station
IEUA
LWH Collection
Station
SBVMWD
LWH Collection
Station
WMWD
LWH Collection
Station
Permit No. 552 No. SSP027 No. 4E-04-S56 No. 4B-06-S60
Staffed No; monitored by
video camera
No; monitored by a
CCTV system
Yes. Plant operator
checks haulers
against a list of
approved dischargers
No; monitored by
plant personnel
Security Gated and security
code
Gated, carded, and
coded multiple times Gated and carded Gated and coded
pH
Monitoring
manual pH meter (1
quart samples) at the
industrial facility (not
done onsite)
pH and sulfide levels
checked (if exceeds
limits, station shuts
down and code
invalidated)
pH (some
wastewater is
allowed to discharge
and the pH is read)
pH (if exceeds limits,
load is rejected).
Waste Load
Rejection
Notice
Rejected loads not
noticed to other
stations (only
International
Rectifier discharges)
Notice faxed to other
stations
Notice faxed to other
stations
Notice faxed to other
stations
Processing of
Manifests
No manifests
deposited at station
Manifests dropped
off into box and
processed by IEUA
Manifests processed
by plant operator
Manifests dropped
off into box and
submitted to G&G
Environmental for
review
Sampling
Sampling done on-
site twice a month;
permittee not
required to self-
monitor
All discharges are
sampled, and
samples are
selectively analyzed
Sampling at
originating facility
only
Sampling at
originating facility
only
Flow Meter
Calibration Not clear Annually Annually Annually per permit
requirement
pH Meter
Calibration
pH meter calibrated
(at the industrial
facility, not the
station)
Weekly Annually Annually per permit
requirement
Self-
permitted Yes Yes Yes Yes
Key:
CCTV = closed-circuit television
EMWD = Eastern Municipal Water District
IEUA = Inland Empire Utilities Agency
LWH = liquid-waste hauler
SBVMWD = San Bernardino Valley Municipal Water District
WMWD = Western Municipal Water District
2.3 METHODS
In accordance with the audit objectives and the USEPA’s standards and guidelines, the audit was
conducted in three phases: 1) planning, 2) implementation, and 3) reporting.
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During the planning phase, the audit team reviewed documents provided by SAWPA and the member
agencies to understand the regulatory framework and processes relevant to the audit scope. The
purpose of the planning phase was to develop a risk-based audit program as a basis for the orderly,
efficient, and cost-effective performance of the audit and to develop criteria for assessment.
During the implementation phase, the audit team interviewed representatives from SAWPA and its
member agencies. SAWPA’s representative was present at all interviews with the member agencies.
During this phase, the audit team also inspected industrial user sites and LWH collection stations.
The reporting phase consisted of closing interviews, first with SAWPA and then with SAWPA’s member
agencies. At the time of this report, the closing interviews were all concluded with SAWPA and WMWD
on October 16, 2012, and with SBVMWD, IEUA and EMWD on October 22, 2012.
In all phases of the audit, the audit team considered all regulatory requirements and contractual
obligations applicable to SAWPA and SAWPA’s member agencies. The regulatory requirements included
the OCSD Wastewater Discharge Regulations (Ordinance No. OCSD-39), USEPA Pretreatment
Regulations, the 1991 Memorandum of Understanding, and the 1996 Wastewater Treatment and
Disposal Agreement.
2.3.1 Orange County Sanitation District Wastewater Discharge Regulations Ordinance
No. OCSD-39
The OCSD ordinance sets uniform requirements for users of OCSD facilities and enables OCSD to comply
with all applicable State and federal laws, including the Clean Water Act (33 United States Code [U.S.C.]
Section 1251 et seq.) and the General Pretreatment Regulations (40 CFR 403; Appendix A).
2.3.2 United States Environmental Protection Agency Checklist
The audit team conducted audit activities in accordance with the USEPA’s recommended pretreatment
audit checklist, which is divided into three sections (Appendix D): Section I, Data Review; Section II, IU
File Review; and Section III, Observations and Concerns.
Section I, Data Review, consisted of an interview. The interview was intended to evaluate the portions of
program implementation that could not be evaluated adequately by looking at the industrial user files.
The audit team first conducted interviews to gather background information on the program that would
be verified through review of industrial user records. The interview also complemented the information
gained during the file review and site visits.
Section II, IU File Review, consisted of the review of industrial user records to verify information
collected during the interview. The audit team reviewed the industrial user records maintained by
SAWPA and its member agencies to gather objective evidence of whether the program was effectively
implemented or not implemented.
Section III, Observations and Concerns, consists of a summary of observations and concerns based on
information gathered from site visits, interviews, and file reviews. Section III is organized to correspond
to the subsections in Sections I and II of the USEPA checklist; the areas of concern to consider are listed
with corresponding regulatory and checklist question citations. This section identifies problems and
deficiencies for which required actions and applicable recommendations have been identified; these
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findings and recommendations are summarized in Section 3.0, Findings and Recommendations, and
Section 4.0, Conclusion, of this report.
2.3.3 1991 Memorandum of Understanding
The 1991 MOU between OCSD and SAWPA allows SAWPA to continue to exercise jurisdiction and control
over all discharges located within SAWPA’s territorial boundaries in the Upper Basin that are tributary and
discharge to OCSD’s facilities. For example, SAWPA is responsible for the following activities:
Issuing permits and enforcing violations
Monitoring wastewater flows and performing inspections at SAWPA’s expense
Collecting noncompliance fines, fees, user charges, taxes, and other lawful charges as levied by SAWPA
Preparing and submitting appropriate quarterly and annual reports
A summary table of all of SAWPA’s responsibilities under the 1991 MOU is presented in Appendix B.
2.3.4 1996 Wastewater Treatment and Disposal Agreement
The 1996 Agreement between OCSD and SAWPA became effective on July 24, 1996. The summary table
includes all 32 parts of the 1996 Agreement; however, the following sections are most relevant to the
audit:
Treatment and disposal rights
Capital payments
Quality criteria
Quality violations
Protection of OCSD facilities
Limitation of discharge to the wastewater originating from SAWPA service area only
A summary table of SAWPA’s responsibilities under the 1996 Agreement is presented in Appendix C.
3.0 FINDINGS AND RECOMMENDATIONS
The seriousness of audit findings regarding deficiencies varies significantly. Positive findings that are
considered BMPs were also captured. In order to provide consistency in reporting the audit findings, the
significance of each finding was rated in one of the following categories:
V: Violations
N: Noncompliance
D: Deficiencies
E: Effectiveness issues
B: Best management practices
Violations (V) refer to findings that are generally rated as violations of the federal pretreatment
regulations. Occurrence of these problems on an ongoing basis raises concerns regarding SAWPA and/or
the member agency’s internal control environment over its pretreatment program.
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Noncompliance (N) refers to instances of nonfulfillment of SAWPA’s contractual agreements with OCSD
(1991 MOU and 1996 Agreement) and/or the terms of the permit. Instances of noncompliance raise the
same concerns as violations.
Deficiencies (D) refer to findings where their continuing occurrence can result in an overall high
likelihood for a violation or for an instance of noncompliance and should be reported as such.
Effectiveness issues (E) refer to less serious matters that affect or can affect the pretreatment program
negatively.
Best management practices (B) are methods, techniques, or monitoring measures found to be the most
effective and practical in achieving compliance while making the optimum use of an agency's resources.
The audit team clearly distinguished between findings of violations, noncompliance, deficiencies,
program effectiveness issues, and best management practices. Reportedly, some of these issues were
being addressed by SAWPA and/or the member agencies. The status and description of the conveyed
corrective actions were not included in this report because the required verification of such reports
should be part of the scope and objective of verification and follow up audits of the corrective action
plan.
Findings and recommendations are presented in Tables 3.1 and 3.2 for each program element. Each
finding is assigned a letter for each program element, a second letter to designate the agency associated
with the finding, and a numeral to indicate the finding number. For example, for finding A.S.1, “A” refers
to the administration element of the pre-treatment program, “S” refers to SAWPA, and “1” indicates the
first listed finding and so on. Because SAWPA and SBVMWD start with the same letter, the letter “S” was
assigned to SAWPA and the letter “B” to SBVMWD.
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Table 3-1, Program Administration Findings and Recommendations
Agency Finding
Number Finding Rating Recommendations
SAWPA A.S.1
Noncompliance with 1991 MOU.
SAWPA’s effort in ensuring that all SARI dischargers are permitted
is not sufficient. SAWPA only audits EMWD and IEUA. There was
an instance of an illegal discharge from the Los Serrano’s facility.
This is a requirement under Section 2.C. of the 1991 MOU.
N
SAWPA should develop an audit program and perform
audits of all of its member agencies to verify that all
industrial users are properly permitted. SAWPA should
also perform regular monitoring of the SARI to ensure
that there are no illegal connections.
SAWPA A.S.2
Noncompliance with 1991 MOU.
SAWPA has not been fulfilling its obligation to forward, within 15
days, copies of signed permits to OCSD. This is a requirement
under Section 2.E. of the 1991 MOU.
N
SAWPA should develop and implement a procedure
to ensure that signed permits are forwarded or
made available to OCSD within 15 days. Reportedly,
permits are now uploaded to the SharePoint site
and OCSD is notified by email.
SAWPA A.S.3
Noncompliance with 1996 Agreement.
SAWPA does not have a procedure in place to ensure that it does
not grant capacity for facilities that were previously denied service
in OCSD’s jurisdiction. This is a requirement under Section C.5.(b).ii
of the 1996 Agreement.
N
SAWPA should develop and implement a procedure
to identify facilities that were previously denied
service in OCSD’s jurisdiction. SAWPA is considering
addressing this in a question on the permit
application form.
SAWPA A.S.4
Noncompliance with 1996 Agreement.
The steps that SAWPA are taking to minimize reclaimable
wastewater discharges to the SARI are not apparent. This is a
requirement under Section C.7 of the 1996 Agreement.
N
SAWPA should develop and implement a procedure
to ensure that reclaimable wastewater is not
discharged into the SARI. This verification can be
performed during the inspection of industrial user
facilities.
SAWPA A.S.5
Noncompliance with 1996 Agreement.
The steps that SAWPA are taking to ensure that stormwater is not
discharged to the SARI are not apparent. This is a requirement
under Section C.28 of the 1996 Agreement.
N
SAWPA should develop and implement a procedure
to ensure that stormwater is not discharged into the
SARI. This verification can be performed during the
inspection of industrial user facilities.
SAWPA A.S.6
Noncompliance with 1991 MOU.
SAWPA did not fulfill OSCD’s request for a current list of
permits. This is a requirement under Section 2.E. of the 1991
MOU.
N OCSD should be granted access to the list of
permittees that is maintained by SAWPA.
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Table 3-1, Program Administration Findings and Recommendations (Continued)
W2422.01T Orange County Sanitation District 20 EEC
Agency Finding
Number Finding Rating Recommendations
SAWPA A.S.7
No defined jurisdiction.
The multijurisdictional agreement or arrangement between
WMWD and JCSD is not clear. WMWD permits the sewer
connection points to JCSD. JCSD permits its own facilities and,
although SAWPA does not consider JCSD a member agency, JCSD
is acting in a control agency capacity, and OCSD is not aware of
such arrangements. Section 6.C. of the 1991 MOU.
N
A legal review of the multijurisdictional agreement
or arrangement between WMWD and JCSD must be
reviewed, and the JCSD’s power to issue permits
and carry out enforcement must be confirmed.
SAWPA A.S.8
Noncompliance with 1991 MOU.
SAWPA is not supplying all of the required data including self-
monitoring data in the quarterly reports. This is a requirement
under Section 5.D. of the 1991 MOU.
N
SAWPA must resume supplying all required data,
including self-monitoring data, in the quarterly
report to OCSD. SAWPA has reportedly resumed the
reporting.
SAWPA A.S.9
Noncompliance with 1991 MOU.
The permit fact sheets that SAWPA submits to OCSD for review are
missing key information and sample data. This is a requirement under
Section 2.A of the 1991 MOU.
N
SAWPA must ensure that the permit application
process is well documented and followed and that
data and information verification is performed prior
to submitting the application to OCSD.
SAWPA A.S.10
Noncompliance with 1996 Agreement.
SAWPA has interpreted the “out-of-area” definition differently
than the definition in the 1996 Agreement. This is a requirement
under Section 24 of the 1996 Agreement.
N
As clearly stated in the 1996 Agreement, SAWPA
should obtain OCSD’s written approval for all
wastewater originating from outside SAWPA’s SARI
Service Area for any direct or indirect discharger.
SAWPA A.S.11
Noncompliance with 1991 MOU.
SAWPA has not communicated to OCSD the monitoring schedule,
including self-monitoring requirements, for all permittees. This is a
requirement under Section 3.C. of the 1991 MOU.
N
SAWPA must communicate to OCSD the monitoring
schedule, including self-monitoring requirements,
for all permittees. SAWPA must agree with OCSD on
the best method to regularly communicate the
information.
SAWPA A.S.12
No defined jurisdiction.
Since SAWPA adopted a new ordinance (Ordinance No. 6), not all
industrial user permits were reissued to reference the new
ordinance.
V
SAWPA should reissue all permits with the
reference to Ordinance No. 6 or any revision
thereafter. SAWPA should develop a reasonable
schedule for reissuing all the permits with reference
to the correct Ordinance. SAWPA should seek legal
advice for referencing “or successor ordinances” or
similar language in the permits and hence avoid
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Table 3-1, Program Administration Findings and Recommendations (Continued)
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Agency Finding
Number Finding Rating Recommendations
having to reissue all permits every time the
Ordinance is updated.
SAWPA A.S.13
Delayed initiation of permit renewals.
Some member agencies require that the initiation of the permit
renewal process is the responsibility of the permittee rather than
that of the responsible member agency. However, if the permittee
does not initiate the permit renewal process, the member
agencies do not identify which permittees failed to make the
notifications or that the permits have expired. In some cases, the
permit renewal process only started after OCSD’s inquiries into
whether the permits were renewed.
D
SAWPA must develop and implement a process for
initiating the permit renewal 90 days prior to permit
expiration date and allowing enough time for
OCSD’s review.
SAWPA A.S.14
Inaccurate portrayal.
In permits and documents referring to the collection stations, the
terms collection station or discharge station are typically used.
However, at least in one instance, the term truck dump station
was also used. The term dump does not relay the importance of
compliance in order to ultimately protect both the IEBL and the
OCSD wastewater treatment facility.
E
The wording “liquid waste hauler collection station”
should be used in all documents and permits and at
all boards and signs posted at the collection
stations. This term is defined and used in SAWPA’s
current Ordinance.
SAWPA A.S.15
Conflict of interest.
The WMWD collection station’s most recent direct-user discharge
permit was issued to WMWD by WMWD. In general, self-
permitting does not provide the desired control level to ensure
compliance with regulatory controls. All member agencies permit
their own LWH collection stations. In EMWD’s case, the LWH
collection station and the desalters are permitted by WMWD.
E
SAWPA must find an alternative to the current
permitting of an agency’s LWH collection station,
desalters, and emergency bypasses by the same
agency.
EMWD A.E.1
Outdated ordinance.
EMWD recognizes that they have to upgrade their sewer use
ordinance to include the USEPA pretreatment streamlining
provisions and be consistent with SAWPA’s Ordinance No. 6. The
EMWD intends to perform this upgrade, including the Enforcement
Response Plan, as soon as SAWPA’s Ordinance is updated.
D
EMWD recognizes that it must upgrade its sewer
use ordinance to include the USEPA pretreatment
streamlining provisions and to make the ordinance
consistent with SAWPA’s Ordinance No. 6 or any
revision thereafter.
SAWPA Pretreatment Program Compliance Audit Report November 19, 2012
Table 3-1, Program Administration Findings and Recommendations (Continued)
W2422.01T Orange County Sanitation District 22 EEC
Agency Finding
Number Finding Rating Recommendations
SBVMW
D A.B.1
Lack of jurisdiction.
SBVMWD appears to completely delegate most or all of the
administrative responsibilities to G&G and CSBMWD. SBVMWD
would like to adopt SAWPA’s ordinance by reference and
disregard its own IEBL ordinance. SBVMWD has already adopted
SAWPA’s ERP. The adoption of the ERP will be problematic when
delegation of enforcement responsibilities is involved.
N SBVMWD must develop its own ordinance and
enter into a jurisdictional agreement with CSBMWD.
SBVMW
D A.B.2
Lack of jurisdiction.
There is no written multijurisdictional agreement or arrangement
between SBVMWD and CSBMWD. All user permits are issued by
CSBMWD, but SBVMWD co-signs the LWH collection station and
the indirect users within the SBVMWD service area.
N Same as above.
WMWD A.W.1
Lack of jurisdiction.
WMWD adopted a new sewer use ordinance on June 20, 2012,
effective August 15, 2012. The ordinance contains reference to an
ERP (Article 6) and no reference to the IEBL users; WMWD
admitted at the interview that it may not have an IEBL ordinance
at the present time. Lack of an ordinance and ERP effectively
means that WMWD has no current legal authority to oversee the
IEBL indirect or direct users.
N WMWD must develop its own ordinance and ERP
that is inclusive of the IEBL.
WMWD A.W.2
Lacking data management tool.
WMWD oversees and administers all sampling and monitoring
activities for its users. WMWD appears to have adequate
equipment to perform this function but the audit team did not
inspect the equipment. Sampling data is entered into a customized
database that is reportedly old and possibly in need of updating.
E WMWD must develop an adequate data
management system.
Key: CSBMWD = City of San Bernardino Municipal Water District
EMWD = Eastern Municipal Water District
ERP = Enforcement Response Plan
IEUA = Inland Empire Utilities Agency
JCSD = Jurupa Community Services District
LWH = liquid-waste hauler
MOU = memorandum of understanding
SAWPA = Santa Ana Watershed Project Authority
SBVMWD = San Bernardino Valley Municipal Water District
WMWD = Western Municipal Water District
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Table 3-2, Permitting Findings and Recommendations
Agency Finding
Number Finding Rating Recommendation
SAWPA P.S.1
Omission in permit.
The present permit does not state that the facility is classified as
an SIU. (Chino II Desalter Facility)
D SAWPA must correct the permit to state that
the facility is classified as an SIU.
SAWPA P.S.2
Updating permits.
Many of the permits reviewed don’t reference SAWPA’s or the
regulating member agency’s current ordinance. Furthermore, the
requirements of the EPA Streamline Rule is not included in the
permits.
D
SAWPA should ensure that all permits
reference the updated SAWPA’s or member
agencies’ Ordinance, the requirements under
the EPA Streamline Rule including mass load
limits in lieu of concentration limits, and
OCSD’s local limits (instantaneous limits).
IEUA P.I.1
Monitoring point location.
The monitoring locations should be clearly defined as to their
purposes. (OLS Energy)
E IEUA is encouraged to adopt the same uniform
permit that SAWPA is currently developing.
IEUA P.I.2
Permit format.
The structure of the IEUA permit is much different from the
structure of the permits issued by the other three member
agencies and the permit format suggested by the USEPA Industrial
User Permitting Guidance Manual, dated September 1989. While
the main body of the permit contains the standard regulations, the
required monitoring activities are appended to the permit. The
sampling location is referred to in Section IIIB in the body of the
permit between other standard regulations, and a diagram of the
location of the sampling point is included in another appendix to
the permit. Since the direct discharge to the IEBL, and eventually
to OCSD’s wastewater treatment plant, originates from the
permittee’s industrial processes, the permit contains OCSD’s
applicable local limits that apply at the end of pipe discharge point.
(RP-5)
E
IEUA must state in the body of the permit that
the facility is permitted as an SIU and the
reason for this classification.
SAWPA Pretreatment Program Compliance Audit Report November 19, 2012
Table 3-2, Permitting Findings and Recommendations (Continued)
W2422.01T Orange County Sanitation District 24 EEC
Agency Finding
Number Finding Rating Recommendation
IEUA P.I.3
Categorical standards.
Facility is permitted as an SIU, but this is not explicitly stated in the
body of the permit. The reason for the SIU classification (e.g.
industrial flow exceeding 25,000 gallons per day) is not presented.
(RP 5)
E
IEUA must include in the permit a section
requiring the permittee to submit to the
control agency, at least 90 days before the
commencement date of any business activity,
all details of any new customer with which it
intends to do business. This will act as a
guarantee that no customer from inside or
outside of the municipal area is allowed to
transport waste to the RP-5 facility without the
full knowledge of the waste substances
involved and the origins of the waste by the
regulatory agencies.
IEUA P.I.4
Categorical standards.
In a situation where a facility, such as the RP-5 facility, accepts only
food waste and is exempt from the centralized waste treatment
regulations in 40 CFR 437, the permit must contain a section
requiring the permittee to submit to the control agency (IEUA for
RP-5), at least 90 days before the commencement date of any
activity, all details of any new customer with which it intends to do
business. This will guarantee that no customer from inside or
outside of the municipal area is allowed to transport waste to the
RP-5 facility without the full knowledge of the waste substances
involved and the origins of the waste by the regulatory agencies.
(RP-5)
E
Although IEUA Ordinance contains a section
that addresses changes to an industrial user’s
production (Section 3.4(A)(4)), the Ordinance
does not include a timeline for notification.
This requirement should be included in the
permit to prompt the permittee to notify IEUA
and allow sufficient time for an adequate
review of the proposed changes.
EMWD P.E.5
Best management practices.
The Inland Empire Energy Center facility is equipped with
permanent gauges to provide real-time flow rates and pH
measurements. Flow rates and pH measurements are also
monitored in real-time by EMWD. This very advanced monitoring
system provides maximum visibility for the control agency. It was
not encountered at any other facility inspected during the audit.
(IEEC)
B Best management practices should be shared
with other agencies and with other industries.
SAWPA Pretreatment Program Compliance Audit Report November 19, 2012
Table 3-2, Permitting Findings and Recommendations (Continued)
W2422.01T Orange County Sanitation District 25 EEC
Agency Finding
Number Finding Rating Recommendation
EMWD P.E.6
Omissions.
The prohibited waste discharges are listed under Part 5.I. of the
permit. However, the permit does not list the wastewater streams
authorized to discharge from the IEEC facility. A list of the waste
streams authorized to discharge are an integral part of a permit
and should be listed. (IEEC)
E
EWMD must list the wastewater streams
authorized to discharge from the IEEC facility.
A list of the waste streams authorized to
discharge is an integral part of a permit and
should be included.
EMWD P.E.7
Omissions.
The EMWD permit simply refers to the permittee (International
Rectifier) as “performing processes subject to 40 CFR 469,” which
is inadequate. This is a complex facility and the permit should
describe the sources of regulated and unregulated waste streams
in more detail. However, no other significant issues were found
with this permit. Comparisons with the WMWD permit for this
same facility demonstrate serious errors in the WMWD permit.
(See P.W.10) (International Rectifier)
B
The permit should provide more detail about
the sources of regulated and unregulated
waste streams.
SBVMWD P.B.1
Omissions.
Industrial user is permitted as a nonsignificant industrial user, but
this is not explicitly stated in the body of the permit. The only
reference to this classification was the permit number SARI-IU-
021. (Angelica Textile Services)
D
Permit should explicitly state that an industrial
user is permitted as a Non-Significant
Industrial User.
SBVMWD P.B.2
Errors.
The permit contains the name of another unrelated industrial user
(first paragraph on page 2 of the permit refers to CSM Bakery
Products). (Angelica Textile Services)
E The permit must be corrected and a permit
review process implemented.
WMWD P.W.1
Errors.
1. Outdated contact information in permit (p. 10, Part 3.E). Calling
(714) 593-7410 is not appropriate (Mr. Paul Spassoff is an office
assistant, not the indicated Source Control Manager; the position
of Source Control Manager no longer exists).
D The permit must be corrected and a permit
review process implemented.
SAWPA Pretreatment Program Compliance Audit Report November 19, 2012
Table 3-2, Permitting Findings and Recommendations (Continued)
W2422.01T Orange County Sanitation District 26 EEC
Agency Finding
Number Finding Rating Recommendation
2. Repeated information in permit (p. 11, Part 3.E).
3. Incorrect references in the permit (LWH collection station
permit - facility where collection station is located is referred to as
the “City of Corona’s Water Treatment Plant No. 1” instead of the
“City of Corona Water Reclamation Facility No. 1”).
4. Incorrect designation of the entity required to immediately
notify WMWD of any concerns or issues (per Permit Special
Conditions Part 5.D.3, the Dart Container Corporation is required
to notify WMWD or any concerns or issues - Dart Container
Corporation is a permitted direct discharger located approximately
1.0 mile from the collection station). (LWH Collection Station in
Corona)
WMWD P.W.2
Omissions.
The permit states that sampling for biological oxygen demand and
total suspended solids is required. However, monthly sampling by
WMWD for surcharge purposes is not mentioned in the permit.
(Dairy Farmers of America)
V Monthly sampling by WMWD for surcharge
purposes should be added to the permit.
WMWD P.W.3
Errors.
Multiple designations for the same sampling location: Permit
refers to the sample location as Location 001. In Section 1G the
permit describes the same location as “Discharge Point A.” In
Section 2A, permit refers to a designated sample location that is
described and poorly illustrated in Section 2C as a “sample
location.” (Dairy Farmers of America)
D Sampling location must be well defined and
illustrated
WMWD P.W.4
Incorrect permitting procedure.
The termination of the permit for the DFA facility, the issuance of a
modified permit as a standby permit, and the permit for the CCR
operation did not follow the correct permitting procedure
required by SAWPA and OCSD. This is not allowed in SAWPA’s
(Section 407.0) or OCSD’s (Section 104.A) Ordinances.
N
WMWD should ensure that its permitting
procedures comply with the requirements in
SAWPA’s and OCSD’s Ordinances.
SAWPA Pretreatment Program Compliance Audit Report November 19, 2012
Table 3-2, Permitting Findings and Recommendations (Continued)
W2422.01T Orange County Sanitation District 27 EEC
Agency Finding
Number Finding Rating Recommendation
WMWD P.W.5
Categorical standards.
Incorrect categorical identification of manufacturing process.
Currently, it is incorrectly identified as a categorical industrial user
subject to 40 CFR 467, but all extrusion activities have ceased at
the site. (Frontier Aluminum)
V Permittee must be correctly categorized based
on the current manufacturing activities.
WMWD P.W.6
Categorical standards.
Incorrect categorical identification of manufacturing process.
Reference to Press Heat Treatment Contact Cooling Water is
incorrect in the spreadsheet and should be removed from the
calculation. The Heat Treatment Non-Contact Cooling Water is not
being monitored and treated as a dilution flow. A combined waste
stream formula is not developed to calculate the applicable limits
for the total combined flows from the two regulated sources. The
spreadsheet used in the calculations contains incorrect data and
the wrong combined waste stream formula. (Sierra Aluminum)
V
A combined waste stream formula must be
developed to calculate the applicable limits for
the total combined flows from the two
regulated sources. The spreadsheet used in
the calculations must be corrected.
WMWD P.W.7
Errors.
Permit does not distinguish between OCSD’s total toxic organics
(TTO) list and the federal TTO list described in 467.02(q). These
two TTO lists contain different pollutant parameters. Also the
Permit does not state that the oil & grease analysis may be used as
an alternate for the TTO analysis. (Sierra Aluminum)
V
Permit must distinguish between OCSD’s TTO
list and the federal TTO list described in
467.02(q). Permit must state that the oil &
grease analysis may be used as an alternate for
the TTO analysis.
WMWD P.W.8
Errors.
Permit states that a TTO certification is required (presumably in
lieu of sampling) but this requirement is not contained in the
federal regulations. (Sierra Aluminum)
V Permit must be corrected, and TTO sampling
must commence.
WMWD P.W.9
Omissions.
Permit does not contain the formula used in the calculation of the
combined waste stream formula or an explanation of the various
waste streams involved. (Sierra Aluminum)
D
Permit must contain the formula used in the
calculation of the combined waste stream, and
the various waste streams involved must be
listed.
SAWPA Pretreatment Program Compliance Audit Report November 19, 2012
Table 3-2, Permitting Findings and Recommendations (Continued)
W2422.01T Orange County Sanitation District 28 EEC
Agency Finding
Number Finding Rating Recommendation
WMWD P.W.10
Omissions.
Permit contains a diagram that is outdated. The diagram of the
wastewater treatment system shows an evaporator system that is no
longer there. (Sierra Aluminum)
E The facility diagram must be corrected to
remove the evaporator.
WMWD P.W.11
Categorical standards.
WMWD’s permit does not distinguish between the OCSD TTO local
limit and the 40 CFR 469.18 TTO limit and incorrectly compares the
two limits by using the most stringent limit for the single analysis.
The EMWD permit correctly identifies the difference between
OCSD’s TTO local limit (which requires only an USEPA 624 analysis)
and the federal pretreatment standard for TTO in 40 CFR 469.18
(which requires both a 624 and 625 analyses). (International
Rectifier)
V
The WMWD permit must be corrected and
must identify the difference between OCSD’s
TTO local limit (which requires analysis by
USEPA Method 624 only) and the federal
pretreatment standard for TTO in 40 CFR
469.18 (which requires analyses by both
USEPA Methods 624 and 625).
Key:
CSBMWD = City of San Bernardino Municipal Water District
EMWD = Eastern Municipal Water District
IEEC = Inland Empire Energy Center
IEUA = Inland Empire Utilities Agency
JCSD = Jurupa Community Services District
LWH = liquid-waste hauler
MOU = memorandum of understanding
SAWPA = Santa Ana Watershed Project Authority
SBVMWD = San Bernardino Valley Municipal Water District
SIU = significant industrial user
TTO = total toxic organics
WMWD = Western Municipal Water District
SAWPA Pretreatment Program Compliance Audit Report November 19, 2012
W2422.01T Orange County Sanitation District 29 EEC
Table 3-3, Monitoring Findings and Recommendations
Agency Finding
Number Finding Rating Recommendation
EMWD M.E.1
Best management practice.
The IEEC facility is equipped with permanent gauges to provide real-time
flow rates and pH measurements. Flow rates and pH measurements are also
monitored in real-time by EMWD. This very advanced monitoring system
provides maximum visibility for the control agency. It was not encountered
at any other facility inspected during the audit. (IEEC)
B
Best management practice should be
shared with other agencies and with
other industries.
IEUA M.I.1
Lacking monitoring equipment.
Permittee should maintain a written log of pH on an hourly basis (or install a
continuous pH recorder) at the discharge point or in the discharge pit on the
effluent side of the dissolved air flotation unit. (RP-5)
E
Permittee should maintain a written log
of pH on an hourly basis (or install a
continuous pH recorder) at the
discharge point or in the discharge pit
on the effluent side of the dissolved air
flotation unit.
IEUA M.I.2
Errors.
The exact location of the sample point was described during the inspection
by the permittee as the interior of the pipe leading to the final effluent
storage tank at the audit. The permit states that the sampling point is a
manhole on Flower Street. Further investigation of the exact location of all
samples to date by both IEUA and the permittee should be conducted to
ascertain if the correct sampling point indicated in the permit is always used,
or if a revision of the sampling point has been recorded after permit
issuance. Some reference to a future revision of a sampling point was
included in the January to March 2012 quarterly report from IEUA to SAWPA
but no further information could be found. (RP-5)
V
The exact location of the sample point
must be determined and accurately
described in the permit. Furthermore,
the sampling point should be clearly
marked in the field to avoid any
confusion in the future.
IEUA M.I.3
Error.
IEUA’s facility permit defines a grab sample as an individual sample collected
in less than 5 minutes. In the USEPA Model Ordinance (January 2007) a grab
sample is referred to as “a sample that is taken from a waste stream without
regard to the flow in the waste stream and over a period of time not to
exceed fifteen (15) minutes.” (RP-5)
E
The permit must include the correct
definition of a grab sample. Although
IEUA’s requirement is more stringent
that USEPA’s, nonetheless, the
deviation from a federal definition is not
warranted.
SAWPA Pretreatment Program Compliance Audit Report November 19, 2012
Table 3-3, Monitoring Findings and Recommendations (Continued)
W2422.01T Orange County Sanitation District 30 EEC
Agency Finding
Number Finding Rating Recommendation
SBVMWD M.B.1
Error.
Permit, in Part IIB, refers to a sample point located on the tanker truck
transporting the waste. This is incorrect, as the audit team was informed that
the spigot on the storage tank was the sample point. (Angelica Textile Services)
V
The permit should be corrected to
include the spigot on the storage tank
as the sample point. The sampling point
should be clearly marked in the field.
SBVMWD M.B.2
Omission.
Permit, in Part IIIA, sampling is required in January of each year but the
permit does not specifically state that the permittee shall perform the
sampling. (Angelica Textile Services)
D The permit must explicitly state the
party responsible for sampling.
SBVMWD M.B.3
Lack of contractual agreement.
Oversight of the monitoring program by SBVMWD is questionable, as there
are no written standard operating procedures or documented actions.
SBVMWD has delegated all of its sampling and monitoring responsibilities.
Indirect users conduct their own sampling in all instances and CSBMWD
performs the required control authority sampling. WMWD samples the
direct users for control authority requirements. It was not determined if
SBVMWD has a contract with WMWD or SBCMWD to perform the
monitoring.
V
Responsibilities for sampling and
monitoring activities must be well
defined. Formal agreements must be in
place if SBVMWD decides to continue to
delegate sampling and monitoring
responsibilities to WMWD and
SBCMWD.
WMWD M.W.1
Lack of monitoring.
Equipment is not monitored and supervision is lacking. At the time of the
inspection, the red alarm light was flashing but neither the WMWD
representative nor the water reclamation facility workers nearby had any
information on the cause of the triggered alarm or the time that the red
light started flashing. (LWH Collection Station)
V Adequate monitoring per the permit
requirements must be implemented.
WMWD M.W.2
Lack of equipment maintenance.
1. No valid documentation was provided verifying that the automatic valve
would close if the pH value is out of the compliance range of 6.0 to 12.0.
Part 1, H of the permit requires that WMWD submit a quarterly report to
SAWPA verifying the proper functioning of the valve.
2. No documentation was provided verifying the proper operation of
V
Equipment should be maintained and
calibrated as required in the permit.
Documentation must be produced and
maintained for at least three years. The
wastewater discharged must be
sampled and analyzed randomly.
SAWPA Pretreatment Program Compliance Audit Report November 19, 2012
Table 3-3, Monitoring Findings and Recommendations (Continued)
W2422.01T Orange County Sanitation District 31 EEC
Agency Finding
Number Finding Rating Recommendation
software at the collection station. Part 1, I of the permit requires that
WMWD submit a quarterly report to SAWPA verifying the proper
functioning of the software.
3. No valid records were provided on the meter calibration. Part 5, D.3 of the
permit requires that WMWD calibrate the meter annually; the permit does
not specify whether the meter to be calibrated is the pH meter or the flow
meter.
4. No samples of the wastewater discharged at the collection station are
being collected. (LWH Collection Station)
WMWD M.W.3
Misidentification of sample point.
The sample point on the concentrated wastewater tank described in the
permit is both end of pipe and end of process so that all of OCSD’s local
limits should apply here, as it is the point of discharge to the IEBL via the
hauler truck. All local limits should be sampled at least semiannually to meet
federal regulations. They are not required to be sampled at all in the present
permit. (Sierra Aluminum)
V
Sample should be collected from the
sample point on the concentrated
wastewater tank and analyzed for all
local limits at least semiannually to
meet the federal regulations.
Key:
CSBMWD: City of San Bernardino Municipal Water Department
IEEC = Inland Empire Energy Center
IEUA = Inland Empire Utilities Agency
LWH = liquid waste hauler
SAWPA = Santa Ana Watershed Project Authority
USEPA = United States Environmental Protection Agency
WMWD = Western Municipal Water District
SAWPA Pretreatment Program Compliance Audit Report November 19, 2012
W2422.01T Orange County Sanitation District 32 EEC
Table 3-4, Inspection Findings and Recommendations
Agency Finding
Number Finding Rating Recommendation
SAWPA I.S.1
Lacking inspections.
SAWPA retained G&G Environmental Compliance Inc. to perform
inspections of SAWPA’s permits. SAWPA displayed little or no oversight
in determining whether or not these inspections are adequately
performed.
E
SAWPA must ensure that
inspections are adequately
performed.
EMWD I.E.1
Best management practice.
EMWD inspects all of the IEBL direct and indirect users within its
jurisdiction as part of its approved industrial pretreatment program.
Inspection forms were found to be comprehensive.
B
Best management practice should
be shared with other agencies and
with other industries.
SBVMWD I.B.1
Lacking sampling.
G & G Environmental Compliance, Inc. apparently inspects each facility
once per year in January on behalf of SBVMWD, but no samples are
collected by SBVMWD or by G&G Environmental Compliance, Inc.
(Angelica Textile Services)
V
SBVMWD must include a sampling
program as part of its inspection
program.
SBVMWD I.B.2 Lacking inspections.
Oversight of the inspection program by SBVMWD is questionable, as
there are no written standard operating procedures or documented
actions. G&G Environmental Compliance, Inc. inspects the direct users
and makes all decisions since these occur without SOPs.
V
SBVWMD must oversee its
inspection program and ensure
that documentation is produced
and maintained for at least 3
years.
WMWD I.W.1
Lacking inspections.
WMWD contracts with G&G Environmental Compliance Inc. to perform
inspections for most of its industrial users, including those that directly
or indirectly discharge to the IEBL. Inspection forms were determined
to be comprehensive but did not include all of OCSD’s requirements.
E
WMWD must develop inspection
procedures and forms that
incorporate essential
requirements from the 1991 MOU,
the 1996 Agreement and
regulatory requirements.
Key: EMWD = Eastern Municipal Water District
IEBL = Inland Empire Brine Line
SAWPA = Santa Ana Watershed Project Authority
SBVMWD = San Bernardino Valley Municipal Water District
SAWPA Pretreatment Program Compliance Audit Report November 19, 2012
W2422.01T Orange County Sanitation District 33 EEC
Table 3-5, Enforcement Findings and Recommendations
Agency Finding
Number Finding Rating Recommendation
SAWPA E.S.1
Lacking reporting.
Enforcement actions by SAWPA are not always reported to OCSD. SAWPA
issued the IEUA a notice of violation letter for an unpermitted discharge to
the IEBL from the Los Serranos facility, but SAWPA did not inform OCSD of
this issue.
N
SAWPA must ensure that all
enforcement actions are always
reported to OCSD.
SBVMWD E.B.1
Lacking enforcement action.
SBVMWD takes minimal oversight of enforcement procedures and there
are no SOPs except that SBVMWD has adopted SAWPA’s Enforcement
Response Plan. G&G Environmental Compliance Inc. prepares drafts of all
enforcement procedures, and the biggest concern at present is with
EnerTech Environmental California LLC, which processes biosolids. It
appears that EnerTech company has had a large number of startup and
enforcement problems and has been in significant noncompliance, but
G&G Environmental Compliance Inc. could not remember when. SBVMWD
is ultimately responsible for this enforcement.
V
SBVMWD must oversee enforcement
activities and develop and implement
policies and procedures in the form of
an ERP for enforcement.
WMWD E.W.1
Lacking enforcement action.
WMWD contracts with G&G Environmental Compliance Inc. to draft any
enforcement documents for WMWD’s signature for all users that directly
or indirectly discharge to the IEBL. Apart from the enforcement performed
at Corona Resource Recovery, some enforcement at the California
Rehabilitation Center occurred in 2009–2010 but no other enforcement at
other IUs was described at the interview.
E
After implementing a new monitoring
program that includes unannounced
inspections, WMWD must ensure that
enforcement actions are conducted.
Key: IEUA = Inland Empire Utilities Agency
OCSD = Orange County Sanitation District
SAWPA = Santa Ana Watershed Project Authority
SBVMWD = San Bernardino Valley Municipal Water District
WMWD = Western Municipal Water District
SAWPA Pretreatment Program Compliance Audit Report November 19, 2012
W2422.01T Orange County Sanitation District 34 EEC
Table 3-6, Data Management Findings and Recommendations
Agency Finding
Number Finding Rating Recommendation
SAWPA D.S.1
No data management tool.
Data management is not systematic but SAWPA is planning on
implementing a system called OnBase to manage all data and
documents in the future. E
SAWPA must ensure that the data
management system (OnBase),
which is currently in the
implementation phase, aids in
fulfilling all regulatory
requirements and all of SAWPA’s
requirements under the 1991
MOU and 1996 Agreement.
EMWD D.E.1
Best management practice.
EMWD has all necessary equipment and trained staff and performs all
administrative requirements for both the direct and indirect IEBL users
as part of its approved industrial pretreatment program for local sewer
users. EMWD uses a database program (Oracle-based custom software)
that adequately tracks all of district’s industrial users in both the IEBL
system and the district’s approved program. Overall, the EMWD
administration appears to be more than adequate to safeguard the
integrity of the IEBL.
B
Best management practice should
be shared with other agencies and
industry.
SBVMWD D.B.1
SBVMWD has a contract with G&G to prepare permits.
SBVMWD receives the permit application for new or reissued permits
and directly forwards it to G&G Environmental Compliance Inc. to
prepare a draft permit. Review by SBVMWD is minimal, as there does
not appear to be a delegated reviewer. Pre-permit inspections do not
appear to be conducted. Drafts are then forwarded to SBVMWD and
SAWPA for review prior to permit delivery.
N
SBVMWD must ensure adequate
review of the permit application
for new or re-issued permits.
Key: EMWD = Eastern Municipal Water District
IEBL = Inland Empire Brine Line
LWH = liquid-waste hauler
SAWPA = Santa Ana Watershed Project Authority
SBVMWD = San Bernardino Valley Municipal Water District
SAWPA Pretreatment Program Compliance Audit Report November 19, 2012
W2422.01T Orange County Sanitation District 35 EEC
Table 3-7, Reporting Findings and Recommendations
Agency Finding
Number Finding Rating Recommendation
SAWPA R.S.1
Lack of reports.
SAWPA (except for IEUA) was not reporting as required up until the first
report was produced for June 2012, which was delivered on August 8,
2012. Previously, the OCSD was receiving reports from IEUA only. As of the
time this report was prepared, SAWPA has resumed its reporting.
N
At the time this report was prepared, SAWPA
had resumed reporting to OCSD. SAWPA
should include data and information from all
member agencies and make the required
changes to the semiannual and annual report
as requested by OCSD.
IEUA R.I.1
Missing information.
Quarterly reports to SAWPA contain details of permits, inspections, and all
analytical results of samples collected by IEUA for IEBL users during that
quarter. Copies of compliance reports received from IEBL individual users
are not included in the report.
N
IEUA must include copies of compliance
reports received from IEBL individual users
in the quarterly reports submitted to
SAWPA.
EMWD R.E.1
Missing information.
Quarterly reports to SAWPA contain all analytical results of samples taken
by EMWD on IEBL users during that quarter. Copies of compliance reports
received from IEBL individual users are not included in the report.
N
EMWD must include copies of compliance
reports received from IEBL individual users
in the quarterly reports submitted to
SAWPA.
SBVMWD R.B.1
Missing information.
Compliance reports from EnerTech appear to be delivered to SBVMWD on
time and these reports are referred to only in a spreadsheet forwarded to
SAWPA every month by SBVMWD. No detailed analytical results from
either the industrial users or the control authority (performed by WMWD
on SBVMWD’s behalf) are submitted to SAWPA.
N
SBVMWD must submit to SAWPA all
detailed analytical results from either the
industrial users or the control authority
(performed by WMWD on behalf of
SBVMWD).
WMWD R.W.1
Missing information.
Monthly reports from WMWD to SAWPA are comprised of tables
documenting inspections, pH violations, and enforcement activities for the
month. No record of any control authority analytical data or user
compliance reports is included.
N
In the monthly reports to SAWPA, WMWD
must include analytical data and user
compliance reports. SAWPA should discuss
with OCSD the level of detail in the
required reports.
Key: IEUA = Inland Empire Utilities Agency
OCSD = Orange County Sanitation District
SAWPA = Santa Ana Watershed Project Authority
SBVMWD = San Bernardino Valley Municipal Water District
WMWD = Western Municipal Water District
SAWPA Pretreatment Program Compliance Audit Report November 19, 2012
W2422.01T Orange County Sanitation District 36 EEC
Table 3-8, Program QA/AC Findings and Recommendations
Agency Finding
Number Finding Rating Recommendation
SAWPA Q.S.1
Training lacking.
Training of LWH truck drivers on safeguards, procedures, and
recordkeeping is a yearly requirement. Last documented training was
performed in 2009.
N
SAWPA must resume annual
training of LWH truck drivers
regarding safeguards, procedures,
and recordkeeping.
SAWPA Q.S.2
Checking lacking.
With SAWPA and two member agencies sharing the same consultant
(G&G Environmental Compliance Inc.), it is not clear when G&G
Environmental Compliance Inc. is acting in its capacity as SAWPA’s,
WMWD’s, or SBVMWD’s consultant. Also, it is not clear how quality
assurance and quality control is ensured in reviewing permit fact sheets
and final permits.
D
SAWPA must ensure that its staff
and/or consultant are providing an
adequate level of review of permit
fact sheets and final permits.
WMWD Q.W.1
Control lacking.
Manifests are not collected in a secure location and are not protected
from the elements. The manifests serve as a record of each shipment’s
chain of custody. When the waste shipment is delivered to the
permitted waste management facility, the receiving facility must sign
the manifest, retain a copy as a record, and return a signed copy to the
generator who originated the shipment. This process closes the
accountability circle and enables the generator to verify that the
shipment reached its final destination.
D
The manifests must be collected in
a secure location and must be
protected from the elements (LWH
Collection Station).
Key: LWH = liquid--waste hauler
SAWPA = Santa Ana Watershed Project Authority
SBVMWD = San Bernardino Valley Municipal Water District
WMWD = Western Municipal Water District
SAWPA Pretreatment Program Compliance Audit Report November 19, 2012
W2422.01T Orange County Sanitation District 37 EEC
Table 3-9, Program Resources Findings and Recommendations
Agency Finding
Number Finding Rating Recommendation
SAWPA R.S.1
Expertise lacking.
G&G Environmental Compliance Inc. personnel on whom the agency relies demonstrated
a lack of skills in the performance of tasks related to the issuance of permits and the
performance of monitoring. Personnel have also demonstrated an inadequate level of
knowledge in the regulatory and technical aspects of pretreatment.
Agency personnel assigned the task of overseeing SAWPA’s pretreatment program have
also demonstrated an inadequate level of knowledge in the regulatory and technical
aspects of pretreatment.
Agency personnel assigned the task of overseeing SAWPA’s pretreatment program have
not dedicated sufficient time to oversee SAWPA’s overall pretreatment program.
D
SAWPA must acquire
personnel with the
necessary expertise to
develop and implement its
pretreatment program and
who are dedicated to the
program.
IEUA R.I.1
Best management practice.
Agency personnel have demonstrated skills in the performance of tasks related to the
issuance of permits and the performance of monitoring. Personnel have also
demonstrated an adequate level of knowledge in the regulatory and technical aspects of
pretreatment.
Agency personnel assigned the task of managing SAWPA’s pretreatment program have
fulfilled their responsibilities for managing SAWPA’s pretreatment program in their
district.
B
Best management practice
must be shared with other
agencies and with other
industries.
EMWD R.E.1
Best management practice.
Agency personnel have demonstrated skills in the performance of tasks related to the
issuance of permits and the performance of monitoring. Personnel have also
demonstrated an adequate level of knowledge in the regulatory and technical aspects of
pretreatment.
Agency personnel assigned the task of managing SAWPA’s pretreatment program have
fulfilled their responsibilities for managing SAWPA’s pretreatment program within their
district.
B
Best management practices
must be shared with other
agencies and industry.
SAWPA Pretreatment Program Compliance Audit Report November 19, 2012
Table 3-9, Program Resources Findings and Recommendations (Continued)
W2422.01T Orange County Sanitation District 38 EEC
Agency Finding
Number Finding Rating Recommendation
SBVMWD R.B.1
Expertise lacking.
G&G Environmental Compliance Inc. personnel on whom the agency relies demonstrated
a lack of skills in the performance of tasks related to the issuance of permits and the
performance of monitoring. Personnel have also demonstrated an inadequate level of
knowledge in the regulatory and technical aspects of pretreatment.
Agency personnel assigned the task of overseeing SAWPA’s pretreatment program have
also demonstrated an inadequate level of knowledge in the regulatory and technical
aspects of pretreatment.
Agency personnel assigned the task of overseeing SAWPA’s pretreatment program have
not dedicated sufficient time to oversee SAWPA’s pretreatment program within their
district.
D
SBVMWD must acquire
personnel with the
necessary expertise to
develop and implement its
pretreatment program and
who are dedicated to the
program.
WMWD R.W.1
Expertise lacking.
G&G Environmental Compliance Inc. personnel on whom the agency relies demonstrated
a lack of skills in the performance of tasks related to the issuance of permits and the
performance of monitoring. Personnel have also demonstrated an inadequate level of
knowledge in the regulatory and technical aspects of pretreatment.
Agency personnel assigned the task of overseeing SAWPA’s pretreatment program have
also demonstrated an inadequate level of knowledge in the regulatory and technical
aspects of pretreatment.
Agency personnel assigned the task of overseeing SAWPA’s pretreatment program have
not dedicated sufficient time to oversee SAWPA’s pretreatment program within their
district.
D
WMWD must acquire
personnel with the
necessary expertise to
develop and implement its
pretreatment program and
who are dedicated to the
program.
Key: IEUA: Inland Empire Utilities Agency
SAWPA = Santa Ana Watershed Project Authority
SBVMWD = San Bernardino Valley Municipal Water District
WMWD = Western Municipal Water District
SAWPA Pretreatment Program Compliance Audit Report November 19, 2012
W2422.01T Orange County Sanitation District 39 EEC
4.0 CONCLUSION
Overall, major improvements should be implemented at all levels of the pretreatment program to
ensure compliance with all applicable requirements and provide the highest level of protection for the
IEBL and OCSD’s treatment facility. Such improvements, if properly and continuously implemented,
would increase the level of protection and would minimize the risk of a repeated instance of serious
violations as was the case with Corona Resource Recovery (CRR). General recommendations are
outlined below, and specific recommendations to address each finding have been tabulated in Tables 5-
1 through 5-9.
Specific to the CRR issue, the audit revealed that SAWPA allowed a major discharger into the IEBL, CRR,
to discharge mining waste into the IEBL. The waste originated from outside the SAWPA service area and
consisted of mining waste that was inaccurately referred to as “brine” waste. The origin and nature of
the waste warranted a higher level of due diligence than that demonstrated by SAWPA and WMWD in
the permitting process. At a minimum, SAWPA should have requested a complete waste stream
characterization based on a detailed description of the process generating the waste. In addition,
because of the large quantity of waste under consideration, SAWPA and/or WMWD should have
performed an on-site assessment of all waste generating processes at the Molycorp’s Mountain Pass
facility to confirm the information provided by CRR. In order to categorically determine all the facts
surrounding the CRR issue including any correlation between the excursions in arsenic level in OCSD’s
biosolids and the discharge of the Molycorp’s waste, access to all records maintained by SAWPA,
WMWD and Molycorp pertaining to the CRR issue should be granted.
On the program administration level, SAWPA must develop and implement the necessary improvements
to its pretreatment program. EEC also recommends that SAWPA manage all aspects of the pretreatment
program rather than delegate permitting, monitoring, and enforcement to its member agencies. This
would give SAWPA the necessary control, but the legality of multijurisdictional agreements allowing
enforcement actions and the levying of fines must be addressed.
Alternatively, SAWPA could continue to manage its program through multijurisdictional agreements
with some or all of its member agencies, but this option is not recommended because it yields a lower
level of compliance and protection. Such arrangement relieves SAWPA from the responsibility of issuing
permits and monitoring compliance, but would require SAWPA to closely monitor the performance of its
member agencies and to conduct announced and unannounced inspections at industrial user facilities.
In either arrangement, it is highly recommended for SAWPA to either acquire adequately qualified staff
dedicated to SAWPA’s pretreatment program and/or to retain a qualified consultant who is not retained
by any of its member agencies. At all times, SAWPA must ensure that any conflict of interest is
eliminated and that it fulfills its role in providing additional control and program supervision.
Permits are control instruments that must be properly prepared and based on accurate and
comprehensive information concerning the industrial user. SAWPA should adopt a uniform permit fact
sheet and permit format that addresses all applicable requirements in the federal and state regulations,
in OCSD’s ordinance, in the 1991 MOU, and in the 1996 Agreement requirements. It is also
recommended that the practice of an agency issuing permits to itself for the control and monitoring of
its LWH Collection Station, its desalters or its emergency bypass permits cease throughout SAWPA’s
service area. Typically, and as observed in this audit, such a practice leads to many instances of
noncompliance due to the inherent lack of control and monitoring.
SAWPA Pretreatment Program Compliance Audit Report November 19, 2012
W2422.01T Orange County Sanitation District 40 EEC
Monitoring at all levels of the pretreatment program must be improved. The level of monitoring by
some member agencies is adequate but it is lacking among other member agencies. SAWPA must
develop and implement procedures for the regular calibration and maintenance of equipment, for the
sampling and testing of wastewater, for gathering information and issuing permits, and for all other
activities that can ensure compliance and a higher level of protection to the IEBL and OCSD’s treatment
and receiving waters. SAWPA must regularly monitor the proper implementation of all adopted
procedures.
Inspections should consist of a critical examination of the industrial user facility and manufacturing
processes. The announced inspections currently performed by the member agencies do not always
reveal all changes and modifications. A minimum number of inspections must be unannounced in order
to capture facts and information that are more representative of normal operating conditions at the
industrial user facilities. The actual number of inspections should be determined in light of the nature of
the inspections and the potential risk present.
Enforcement plans that are currently in place for SAWPA and its member agencies must undergo a legal
review to assess their effectiveness under the current multijurisdictional agreements. Enforcement
plans must also contain a clear procedure to determine if a violation is considered an instance of
significant noncompliance, to identify and undertake a timely and appropriate response, and to
document resolution of noncompliance. Enforcement response planning is a critical portion of every
ordinance and is ultimately SAWPA’s responsibility to implement.
Data management must be improved to increase the level of collaboration and work transferability
between SAWPA and OCSD. Traceability also must be improved to facilitate quality checking.
Reporting by SAWPA to OCSD must resume and continue on a monthly basis. As required in the 1991
MOU, SAWPA must provide monthly reports detailing the number and identification of new and existing
permittees, inspections, enforcement actions, and monitoring data. SAWPA and OCSD must agree on a
report format for smooth and effective transfer of information.
QA/QC measures specific to the IEBL must be implemented by SAWPA throughout its pretreatment
program. SAWPA’s primary mission should be to effectively oversee and carry out a robust quality
system and quality management plan, including QA/QC activities at the industrial user level. SAWPA
should also regularly review its implemented QA/QC measures.
Resources to develop and implement an adequate pretreatment program for SAWPA are critically
needed. SAWPA must acquire qualified staff and/or retain a qualified consultant with expertise in both
pretreatment and program management. Should it choose to retain a qualified consultant, SAWPA
would still need to elevate the pretreatment expertise of its staff members responsible for managing the
consultant. The audit team estimated that, should it choose to manage the entire IEBL pretreatment
program with the current number of permittees, SAWPA would need a total of three full-time
equivalent (FTE) employees (staff and/or consultants). The 3 FTE’s would be comprised of a clerical
position mainly for invoicing, data management, and reporting; a junior staff position focusing primarily
on permitting and inspections; and a program manager to develop and oversee the program, review
permits, and liaise with OCSD and member agencies. This estimate is for the first year and is for the
development and implementation of a pretreatment program without passing on any responsibility to
member agencies. It is also expected that, after the first year, SAWPA would need fewer employees to
manage the same number of permittees.
SAWPA Pretreatment Program Compliance Audit Report November 19, 2012
W2422.01T Orange County Sanitation District 41 EEC
The audit findings have been verbally shared with SAWPA and the member agencies throughout the
audit, and SAWPA is currently in the process of addressing many of the audit findings. Starting with the
recommended corrective actions presented in the report, SAWPA could begin to develop its own
corrective action plan and schedule specific to the audit findings. Alternatively, OCSD could, as specified
in the 1991 MOU section 6.D., develop and issue SAWPA a remedial plan with a time schedule for
attaining compliance since SAWPA has failed or has refused to fulfill key pretreatment requirements. In
either case, follow-up audits by OCSD should be scheduled to determine whether the corrective actions
are being implemented adequately and on schedule.
Project
Project Number File Number
Date
PE/RG PM DR
Figure
Santa Ana Watershed Authority Project
Pretreatment Program Compliance Audit
Santa Ana River Watershed Location Map
W2422-01T Santa Ana River Watershed
Location Map.ppt
October 22, 2012
NS NS NS 1
SOURCE:
Santa Ana Watershed
Project Authority
Project
Project Number File Number
Date
PE/RG PM DR
Figure
Santa Ana Watershed Authority Project
Pretreatment Program Compliance Audit
Inland Empire Brine Line and Connections
W-2422-01T Santa Ana Regional Interceptor Line and Connections.ppt
October 22, 2012
NS NS SAWPA 2
SOURCE:
Santa Ana Watershed
Project Authority
Project
Project Number File Number
Date
PE/RG PM DR
Figure
Santa Ana Watershed Authority Project
Pretreatment Program Compliance Audit
Santa Ana Watershed Project Authority
Member Agencies
W2422-01T sawpa member
agencies.ppt
October 22, 2012
NS NS SAWPA 3
SOURCE:
Santa Ana Watershed
Project Authority