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HomeMy WebLinkAbout95.PPP PretreatmentPresentation 06-11-2014An Overview of OCSD’s Pretreatment Program Environmental Compliance Division Roya Sohanaki, PE Environmental Compliance Division Orange County Sanitation District Phone: (714) 593-7437 Fax: (714) 962-6957 rsohanaki@OCSD.com Orange County Sanitation District Code of Federal Regulations California Code of Regulations OCSD Pretreatment Program OCSD Industrial Source Control OCSD Wastewater Discharge Regulations Ordinance Orange County Sanitation District Code of Federal Regulations California Code of Regulations OCSD Wastewater Discharge Regulations Ordinance OCSD Pretreatment Program OCSD Industrial Source ControlOCSD Industrial Source Control Orange County Sanitation District Source Control Managing sources of pollutants throughout OC before they enter the sewage collection system Household Users Commercial Users Industrial Users Cities Utilities Community Programs OCSD Non-Industrial Source Control OCSD Industrial Source Control Orange County Sanitation District Effectiveness of Source Control Orange County Sanitation District As defined by OCSD’s Ordinance and the EPA Federal Code of Regulations (CFR) •Any facility that discharges a large volume of industrial wastewater. •Any facility subject to a Federal Category listed in the CFR. •Any industrial facility that has a potential to violate local, state, or federal pretreatment standards. Orange County Sanitation District Requirements of an Industrial User •Wastewater discharge must meet certain pollutant concentration criteria determined by OCSD inspection and sampling •Facility required to submit periodic reports on about its operation and discharge •Required to obtain an OCSD Permit Orange County Sanitation District Measuring Compliance •Source Inspection Division inspects facility and collects samples on a quarterly basis •Inspection group also conducts strategic sampling (‘fishing’) in the sewer system •Engineer reviews these results along with self- monitoring samples provided by the industry •When a permittee commits a violation, knowingly or unknowingly, OCSD pursues Enforcement How does OCSD ensure discharge limits are being met? Orange County Sanitation District Measuring Compliance •Source Inspection Division inspects facility and collects samples on a quarterly basis •Inspection group also conducts strategic sampling (‘fishing’) in the sewer system •Engineer reviews these results along with self- monitoring samples provided by the industry •When a permittee commits a violation, knowingly or unknowingly, OCSD pursues Enforcement How does OCSD ensure discharge limits are being met? Orange County Sanitation District Pursuing Enforcement •Enforcement is defined and authorized by Article 6 of OCSD’s Ordinance. •OCSD follows a specific Enforcement Response Plan (ERP) required to be in place by the EPA •The ERP designates the tools at OCSD’s disposal such as additional industry requirements, fines, and legal actions. •After a violation, an industry is subject to enforcement, the level of which is determined by the severity of the offense and user’s compliance history. •Occasionally, with a problematic permittee, when an illegal or unreported discharge is suspected, a downstream investigation is initiated How does OCSD compel a permittee to follow federal, state, and local regulations? ERP ERP Circumstance & Intent Type & Nature of the Violation Impact of the Violation to OCSD & Member Agencies Judicial Remedy (Criminal Penalty) Physical Termination of Service Permit Revocation Judicial Referral (OC District Attorney) Permit Suspension Administrative Complaint & Civil Penalties Fine Significant Noncompliance Publication & Cost Recovery Regulatory Compliance Schedule Agreement (RCSA) Enforcement Compliance Schedule Agreement (ECSA) Probation Orders Compliance Meetings Compliance Inspections Notices of Violation & Cost Recovery Fines Notices (Late Reports, Missing Attachments, etc.) Number of Actions in the Last 3 Years 170 57 119 405 202000OCSD Board of Directors Pretreatment Program Involvement Adopting the Ordinance Informed about noteworthy cases, usually after investigation Approval of Civil Penalties that are over $50,000 in value Serve as appeal body for high level enforcement 1) 2) 3) 4) Pretreatment Program Awards EPA National Pretreatment Program Excellence Award 1997 1st Place EPA National Pretreatment Program Excellence Award 1994 2nd Place 2000 2nd Place EPA National Pollution Prevention Achievement Award 1992 1st Place (First Recipient) National Association of Clean Water Agencies 2008 Public Information and Educational Award “OCSD’s Industrial Pretreatment Program has been the pioneer of leadership for over 40 years, under the Clean Water Act, Pacific Southwest Region U.S. EPA.” (2012) Keith Silva, Former U.S. EPA Pretreatment Program Coordinator, Region 9 An Overview of OCSD’s Pretreatment Program Environmental Compliance Division Questions? Roya Sohanaki, PE Environmental Compliance Division Orange County Sanitation District Phone: (714) 593-7437 Fax: (714) 962-6957 rsohanaki@OCSD.com