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