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