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HomeMy WebLinkAboutSteering Agenda Item 3 SAWPA REPORT Appendix G Industrial User Inspection Report Santa Ana Watershed Project Authority Audit Industrial User: Angelica Textile Services Industrial User Address: 925 South 8th Street, Colton, CA 92324 Industrial User Permit Number: SARI-IU-021 Industrial User Representatives: Mr. Joe Gomez, Plant Operations Director Indirect/Direct User: Indirect User Agency Area: San Bernardino Valley Municipal Water District Agency Representatives: Mr. Andy Coady, City of San Bernardino Municipal Water Department Environmental Control Officer Mr. Michael Plasencia, City of San Bernardino Municipal Water Department Environmental Control Technician Inspection Date: August 8, 2012, Scheduled Inspection EEC/PSI Inspectors: Dr. John R. Parnell, Pretreatment Solutions, Inc. Mr. Najib Saadeh, Environmental Engineering & Contracting, Inc. Report Date: November 1, 2012 1.0 SCOPE AND PURPOSE On behalf of the Orange County Sanitary District (OCSD), Environmental Engineering & Contracting (EEC) performed an inspection of selected industrial users discharging into the Inland Empire Brine Line (IEBL; formerly known as the Santa Ana Regional Interceptor, SARI). This inspection is part of an audit of the pretreatment programs of the Santa Ana Watershed Project Authority (SAWPA) and its member agencies. Industrial users were selectively inspected based on volume of wastewater discharged and/or industry type in order to evaluate the performance of the pretreatment programs. The current evaluation is one of a series of inspections of direct and indirect dischargers into the IEBL. Direct dischargers are typically close enough to construct a direct connection to the IEBL and produce enough waste to economically justify the connection cost. Indirect dischargers generate waste streams that are high in total dissolved solids and are not located close enough to the IEBL to make a direct connection. In general, the volume of wastewater discharged at liquid waste hauler (LWH) discharge stations varies. The quantity of liquid waste discharged at these stations can vary from one or two truckloads per week to 100,000 gallons per day in some cases. Liquid waste from indirect dischargers is disposed of at discharge stations using a permitted commercial LWH permitted by SAWPA. On August 8, 2012, EEC completed a performance evaluation of the regulatory controls at the Angelica Textile Services (Angelica) industrial laundry facility located at 925 South 8th Street in the City of Colton, California (Appendix A, Site Photographs, Photo 1). The facility is permitted and monitored by the San Bernardino Municipal Water District (SBMWD; Appendix B, Indirect User Discharge Permit No. SARI-IU- 021). The inspection was conducted to evaluate whether Angelica has developed and implemented Industrial User Inspection Report: Angelica Textile Services November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 2 EEC sufficient measures to ensure that discharges into the IEBL comply with the terms and conditions of all applicable agreements and regulations, including OCSD ordinances and 40 CFR 403. 1.1 General and Process Description Angelica is an industrial laundry service company. The subject facility washes, dries, and presses gowns, bed sheets, towels, curtains, and cafeteria linens from the Loma Linda Hospital. Incoming laundry is suspended in large bags on an overhead transportation system that feeds the three banks of tunnel washers. From the washers, the clean laundry is pressed to remove excess water before the laundry is loaded into the dryers. The industry employs 150 people on a two-shift basis. 1.2 Wastewater Sources All potable water used by the facility is softened prior to use in the laundry. Approximately 139,000 gallons of water are used every day. Laundry process wastewater is discharged directly to the City of Colton sewer system through a lint trap. The wastewater is monitored by the City of Colton Industrial Pretreatment Program. No wastewater from the laundry process is discharged to the IEBL. 1.3 Facility Process Wastewater Treatment System Incoming potable water passes through one of three ion-exchange softeners prior to use in the laundry (Appendix A, Photo 2). The softeners are operated by a control system that switches automatically to the next softener as soon as the current one needs to be regenerated. The Zeolite ion-exchange resin is regenerated by a concentrated solution of sweet brine. This sweet brine solution is formulated in a separate mixing tank using potable water and crystalline salt (sodium chloride). The crystalline salt is delivered to the laundry by tanker truck and stored outside the facility in 7,200-gallon brine tank (Appendix A, Photo 6). Once the sweet brine solution has regenerated the softener resin, the excess regenerate fluid is transferred directly to a 7,200-gallon storage tank outside the facility (Appendix A, Photo 3). Both storage and brine tanks are located inside a bermed area in case of spillage, accident, or overflow. A spigot on the base of the storage tank is used as the sample point (Appendix A, Photo 5). 1.4 Wastewater Discharge The contents of the storage tank (maximum 5,000 gallons) are collected weekly by a tanker truck from HazMat Trans waste-hauler company (Appendix A, Photo 4). The storage tank is emptied through a pipe placed at the bottom of the tank. The tank contents do not mix. The hauler delivers the brine wastewater to the SBMWD LWH disposal station at the SBMWD water reclamation plant, where it is discharged into the IEBL. The facility uses a three-part manifest system. The generator retains the top copy of the manifest, the hauler retains the middle copy of the manifest, and the SBMWD LWH discharge station retains the bottom copy of the manifest. 2.0 COMPLIANCE WITH FEDERAL CATEGORICAL STANDARDS The laundry is not a categorical industry and is therefore not subject to federal categorical standards. The facility must meet the requirements specified in the permit issued by SBMWD (Appendix B). Industrial User Inspection Report: Angelica Textile Services November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 3 EEC 2.1 Compliance with Other Federal Pretreatment Requirements Since the facility is classified as a nonsignificant industrial user in the permit, it is not subject to federal and local biannual sampling and reporting requirements. The facility is required to comply with the San Bernardino Valley Municipal Water District (SBVMWD) ordinance, the SAWPA ordinance, and the OCSD ordinance concerning the IEBL local limits and general and specific prohibitions. 2.2 Compliance with Local Limits and Actions by the Agency The permit contains all OCSD-required local limits and surcharge components and requires annual sampling for the pollutants. As indicated in Section 3.8 below, the permit does not explicitly require the permittee to perform the sampling. G & G Environmental Compliance, Inc. inspects this facility once per year in January on behalf of SBVMWD, which does not collect any samples. 3.0 SUMMARY OF FINDINGS 3.1 The Angelica facility was found to be in clean operating condition. No immediate problems were identified. 3.2 The water treatment system was found to be in good operating condition. No immediate problems were identified. 3.3 All exterior tanks, pumps, and associated equipment were found to be in good condition and properly bermed in case of emergency spills or accidents. 3.4 The facility reported that sampling line is purged and sample bucket is rinsed prior to sample collection. No written standard operating procedures were available and the audit team did not observe a sampling event. 3.5 Angelica has an indirect discharge permit prepared by G & G Environmental Compliance, Inc. and issued by SBVMWD. The permit was approved for structure and content by both SAWPA and OCSD (Permit No. SARI-IU-021, Effective Date: March 20, 2011, Expiry date: March 19, 2014). 3.6 The facility 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 under Permit No. SARI-IU-021. 3.7 The first paragraph on page 2 of the permit refers to CSM Bakery Products, not Angelica (Appendix B). It appears that another industrial user permit, rather than a clean template, was used to prepare the permit for Angelica. 3.8 Part IIB of the permit refers to a sample point located on the tanker truck that transports the waste; however, the audit team was informed that the spigot on the storage tank is the sample point (Appendix A, Photo 5). Industrial User Inspection Report: Angelica Textile Services November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 4 EEC 3.9 Part IIIA of the permit requires that wastewater sampling be conducted each January but it does not specify that the permittee must perform the sampling. 3.10 The audit team was informed that G & G Environmental Compliance, Inc. inspects this facility for once per year in January on behalf of for SBVMWD and that SBVMWD does not collect any samples. 3.11 No record of any enforcement was identified for the past year. The discharge was apparently in compliance with all permit limits and requirements. However, it should be noted that this finding is based on one annual sample and one inspection only. 3.12 Angelica’s permit to discharge into the IEBL via SBVMWD’s LWH discharge station is issued by the SBMWD and signed by both SBMWD and SBVMWD. If proper jurisdiction was granted by SBVMWD to SBMWD to permit and monitor the indirect dischargers, only one controlling agency should issue the permit and monitor the industrial user. Should there be any questions regarding the contents of this inspection report, please contact Mr. Najib Saadeh by phone at (714) 667-2300 or by e-mail at nsaadeh@eecworld.com. Appendices: A. Site Photographs B. Indirect User Discharge Permit No. SARI-IU-021 APPENDIX A SITE PHOTOGRAPHS Industrial User Inspection Report: Angelica Textile Services November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit A-0 EEC Photo 1 Angelica Textile Services laundry building, City of Colton, California Photographed by John Parnell Photo 2 Ion-exchange cylinders and controllers Photographed by John Parnell Photo 4 7,200-gallon wastewater discharge tank Photographed by John Parnell Photo 3 Waste-hauler truck coupling point Photographed by John Parnell Industrial User Inspection Report: Angelica Textile Services November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit A-1 EEC Photo 5 Sampling point on wastewater tank Photographed by John Parnell Photo 6 Crystalline salt storage tank Photographed by John Parnell APPENDIX B INDIRECT USER DISCHARGE PERMIT NO. SARI-IU-021 Industrial User Inspection Report Santa Ana Watershed Project Authority Audit Industrial User: Chino II Desalter Facility Industrial User Address: 11251 Harrel Street, Mira Loma, CA 91752 Industrial User Permit Number: 4D-06-S58 Industrial User Representatives: Mr. Steven Ibach, Plant Manager Indirect/Direct User: Direct Agency Area: Santa Ana Watershed Project Authority Agency Representative/s: Mr. Benjamin Burgett, G & G Environmental Compliance Inc., Consultants to Santa Ana Watershed Project Agency Inspection Date: August 29, 2012, Scheduled Inspection EEC/PSI Inspectors: Nr. John R. Parnell, Ph.D., Pretreatment Solutions, Inc. Mr. Najib Saadeh, Environmental Engineering & Contracting, Inc. Report Date: November 1, 2012 1.0 SCOPE AND PURPOSE On behalf of the Orange County Sanitary District (OCSD), Environmental Engineering & Contracting (EEC) performed an inspection of selected industrial users discharging into the Inland Empire Brine Line (IEBL; formerly known as the Santa Ana Regional Interceptor, SARI). This inspection is part of an audit of the pretreatment programs of the Santa Ana Watershed Project Authority (SAWPA) and its member agencies. Industrial users were selectively inspected based on volume of wastewater discharged and/or industry type in order to evaluate the performance of the pretreatment programs. The current evaluation is one of a series of inspections of direct and indirect dischargers into the IEBL. Direct dischargers are typically close enough to construct a direct connection to the IEBL and produce enough waste to economically justify the connection cost. Indirect dischargers generate waste streams that are high in total dissolved solids and are not located close enough to the IEBL to make a direct connection. In general, the volume of wastewater discharged at liquid waste hauler (LWH) discharge stations varies. The quantity of liquid waste discharged at these stations can vary from one or two truckloads per week to 100,000 gallons per day in some cases. Liquid waste from indirect dischargers is disposed of at discharge stations using a permitted commercial LWH permitted by SAWPA. On August 29, 2012, EEC completed a performance evaluation of the regulatory controls at the Chino II Desalter Facility located at 11251 Harrel Street in the City of Mira Loma, California (Appendix A, Site Photograph). The facility is permitted and monitored by SAWPA (Appendix B, Direct User Discharge Permit No. 4D-06-S58). The inspection was conducted to evaluate whether the Chino II Desalter Facility has developed and implemented sufficient measures to ensure that discharges into the IEBL comply with the terms and conditions of all applicable agreements and regulations, including OCSD ordinances and 40 CFR 403. Industrial User Inspection Report: Chino II Desalter Facility November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 2 EEC 1.1 General and Process Description The Chino II Desalter Facility has been set up by the Chino Desalter Authority to remove salt and other contaminants from local well water to produce drinking water (Appendix A). The facility draws source water from eight wells located in the Chino Basin at a daily rate of 1.2 to 1.8 million gallons per day. The incoming well water is split between three reverse osmosis trains and eight ion exchange units. The reverse osmosis trains remove the majority of all contaminants from the well water, whereas the ion exchange units mostly remove nitrate and a few other minerals. The resulting purified waters from both units are mixed together in a clear well and chlorinated prior to discharge to the local potable water system. The potable water system receives approximately 825 gallons per minute from the facility. Currently, both systems are very well operated. The plant has only needed to shut down once in the past six years for maintenance and the inventory of spare parts ensures first-class reliability. The system is continuously monitored to ensure that the reject wastewater is in continuous compliance with the OCSD local limits. Also, there are cross checks on the ion exchange units to ensure that no breakthroughs occur when the resins become loaded and regenerations are required. The membranes have been in place for 7 years and are anticipated to need replacement in 3 years. The resin in four of the ion-exchange units is 7 years old, and the other four units have been in place only in the past two years. The estimated life span for the resin, if it is not damaged, is 20 years. Samples of resins are analyzed every 2 years to determine efficiency of the resins. Complete records of all maintenance and repair operations are maintained on-site with analytical results. An expansion system for the facility is planned to double the output capacity of the plant. Some of the reverse osmosis reject wastewater will be reprocessed to remove calcium carbonate and silica and then it will re-enter the reverse osmosis trains to increase production of potable water. It is anticipated that the expansion will be functional by early 2015. Currently, the facility employs three persons and operates five days per week. One employee is on call throughout the night. 1.2 Wastewater Sources High-salinity reject wastewater is continuously produced by the reverse osmosis trains. Also, the Dow TWA 15 resin in the ion-exchange units is periodically regenerated, producing high-brine wastewater. Some clean-in-place wastewater is also discharged to the IEBL through floor drains. 1.3 Facility Process Wastewater Treatment System The entire plant is a treatment system, so there is no other specific, separate treatment system. 1.4 Wastewater Discharge The reject wastewater from reverse osmosis is discharged directly through a 15-inch sewer lateral located at 11251 Harrel Street on the east side of the property, which discharges into a tributary to the Etiwanda Metering Station connection to the IEBL. The sampling point for the reverse osmosis wastewater is a manhole in Jurupa Community Service District (JCSD) service yard northeast of the fuel tanks. Three flow meters constantly measure the volume of wastewater discharged from the reverse osmosis system. The regeneration wastewater from the ion-exchange units is also discharged through Industrial User Inspection Report: Chino II Desalter Facility November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 3 EEC an 8-inch sewer lateral located at 11251 Harrel Street on the west side of the property, which discharges into the tributary to the Wineville Metering Station connection to the IEBL. The sampling point for the regeneration wastewater is a manhole located on the west side of the JCSD service yard (Appendix A). 2.0 COMPLIANCE WITH FEDERAL CATEGORICAL STANDARDS Federal categorical standards are not applicable as the facility is not a categorical industry. The facility is required to meet the requirements specified in the permit issued by SAWPA (Appendix B). 2.1 Compliance with Other Federal Pretreatment Requirements The facility should be classified as a Significant Industrial User, which is subject to the OCSD local limits. Like any industrial user, the facility must also comply with pretreatment requirements in 40 CFR 403, including but not limited to, national prohibitions in 40 CFR 403.5 and reporting requirements in 40 CFR 403.12. 2.2 Compliance with Local Limits and Actions by the Agency The permit requires that sampling be performed by the permittee twice per year in April and October. WMWD (on behalf of SAWPA) also samples once annually for compliance and monthly for billing. G & G Environmental Compliance Inc. inspects the facility twice per year. All OCSD local limits are included in the permit and must be sampled using composite sampling except for pH and oil & grease samples. The facility is in compliance at the time of the inspection. 3.0 SUMMARY OF FINDINGS 3.1 The Chino II Desalter Facility was found to be clean and in good operating condition. No immediate problems were identified. 3.2 The water treatment system was found to be in good operating condition and no immediate problems were identified. 3.3 All exterior tanks, pumps, and associated equipment were found to be in good condition and properly bermed in case of accidental spills. 3.4 The current permit contains errors and omissions. Instead of referencing SAWPA’s current ordinance (Ordinance No. 6), the permit references SAWPA’s Ordinance No. 5. The phone number to report an accidental discharge to the OCSD Source Control Manager is incorrect. The permit does not state that the facility is classified as a significant industrial user. 3.5 The Chino II Desalter Facility holds a direct discharge permit prepared by G & G Environmental Compliance, Inc. on behalf of SAWPA. The permit has been approved for structure and content by both SAWPA and OCSD (Permit No. 4D-06-S58 Effective Date: January 31, 2011, Expiry date: January 30, 2013). Industrial User Inspection Report: Chino II Desalter Facility November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 4 EEC 3.6 Best management practices (written standard operating procedures) were implemented for both the reverse osmosis and ion exchange equipment to ensure a continuous supply of potable water. Should there be any questions regarding the contents of this inspection report, please contact Mr. Najib Saadeh by phone at (714) 667-2300 or by e-mail at nsaadeh@eecworld.com. Appendices: A. Site Photographs B. Direct User Discharge Permit No. 4D-06-S58 APPENDIX A SITE PHOTOGRAPH Industrial User Inspection Report: Chino II Desalter Facility November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit A-1 EEC Photo 1 Chino II Desalter effluent discharge Photographed by John Parnell APPENDIX B DIRECT USER DISCHARGE PERMIT NO. 4D-06-S58 Industrial User Inspection Report Santa Ana Watershed Project Authority Audit Industrial User: Corona Energy Partners, Ltd. Industrial User Address: 1130 West Rincon Street, Corona, California 92880 Industrial User Permit Number: 4B-93-S20 Industrial User Representatives: Mr. Wayne Kawamoto, Plant Manager Mr. Wayne Thomson, OSM Supervisor Indirect/Direct User: Direct User Agency Area: Western Municipal Water District Agency Representatives: Mr. Benjamin Burgett, G & G Environmental Compliance Inc., Consultants to Western Municipal Water District Inspection Date: August 28, 2012, Scheduled Inspection EEC/PSI Inspectors: Dr. John R. Parnell, Pretreatment Solutions, Inc. Mr. Najib Saadeh, Environmental Engineering & Contracting, Inc. Report Date: November 1, 2012 1.0 SCOPE AND PURPOSE On behalf of the Orange County Sanitary District (OCSD), Environmental Engineering & Contracting (EEC) performed an inspection of selected industrial users discharging into the Inland Empire Brine Line (IEBL; formerly known as the Santa Ana Regional Interceptor, SARI). This inspection is part of an audit of the pretreatment programs of the Santa Ana Watershed Project Authority (SAWPA) and its member agencies. Industrial users were selectively inspected based on volume of wastewater discharged and/or industry type in order to evaluate the performance of the pretreatment programs. The current evaluation is one of a series of inspections of direct and indirect dischargers into the IEBL. Direct dischargers are typically close enough to construct a direct connection to the IEBL and produce enough waste to economically justify the connection cost. Indirect dischargers generate waste streams that are high in total dissolved solids and are not located close enough to the IEBL to make a direct connection. In general, the volume of wastewater discharged at LWH discharge stations varies. The quantity of liquid waste discharged at these stations can vary from one or two truckloads per week to 100,000 gallons per day in some cases. Liquid waste from indirect dischargers is disposed of at discharge stations using a permitted commercial LWH permitted by SAWPA. On August 28, 2012, EEC completed a performance evaluation of the regulatory controls at the Corona Energy Partners, Ltd. facility located at 1130 West Rincon Street in the City of Corona, California (Appendix A, Site Photograph). The facility is permitted and inspected by G & G Environmental Compliance Inc. on behalf of the Western Municipal Water District (WMWD), and monitored directly by WMWD (Appendix B, Indirect User Discharge Permit No. 4B-93-S20). The inspection was conducted to evaluate whether Corona Energy Partners, Ltd. has developed and implemented sufficient measures to Industrial User Inspection Report: Corona Energy Partners, Ltd. November 1, 2012 W2422.01T 2 EEC ensure that discharges into the IEBL comply with the terms and conditions of all applicable agreements and regulations, including OCSD ordinances and 40 CFR 403. 1.1 General and Process Description Corona Energy Partners Ltd. operates a natural gas–fired turbine that powers an electrical cogenerating plant producing up to 47 megawatts of electricity. The electricity from the plant is fed into the Southern California Edison grid system. Incoming water is passed through a reverse osmosis plant and reject wastewater is discharged to the IEBL. The clean water is fed into a boiler to produce high-pressure steam used to augment power production. In addition, the plant produces steam to reduce the firing temperature and reduce nitrous oxide emissions to the atmosphere. Low-pressure steam is also supplied directly to a Dairy Farmers of America distillation plant located next door to the facility. Dairy Farmers of America uses the thermal energy in the steam and returns the condensate back to the Corona Energy Partners, Ltd. facility. Cooling towers are also required for cooling the oils used in the gas turbine and the air compressors for the generators. In addition, the air intakes into the turbine need to be cooled. 1.2 Wastewater Sources Process wastewater is produced from boiler blowdown, reverse osmosis reject water, cooling tower blowdown, and regeneration wastewater. All wastewater is collected in a central monitoring sump. 1.3 Facility Process Wastewater Treatment System The central monitoring sump is equipped with pH and temperature control and contains an ultrasonic transducer for flow measurement. The sump drains directly to the IEBL through an automatic valve that can shut down the flow in an emergency and redirect the flow to a temporary storage tank. 1.4 Wastewater Discharge The sample point is a manhole outside of the property in a grassy area in Rincon Road. The manhole is equipped with a metering flume and is directly connected to the IEBL. 2.0 COMPLIANCE WITH FEDERAL CATEGORICAL STANDARDS Federal categorical standards are not applicable as the facility is not a categorical industry. The facility is required to meet the requirements specified in the permit issued by WMWD (Appendix B). 2.1 Compliance with Other Federal Pretreatment Requirements The facility is a Significant Industrial User and is subject to the local limits developed by OCSD. Like any industrial user, it must also comply with pretreatment requirements in 40 CFR 403, including, but not limited to, national prohibitions in 40 CFR 403.5 and reporting requirements in 40 CFR 403.12. Industrial User Inspection Report: Corona Energy Partners, Ltd. November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 3 EEC 2.2 Compliance with Local Limits and Actions by the Agency The permit requires that sampling be performed by the permittee twice per year in January and July. WMWD also samples once annually for compliance and monthly for billing. G & G Environmental Compliance Inc. inspects the facility twice per year. All OCSD local limits are included in the permit and must be sampled for using composite sampling except for pH and oil and grease samples. The facility is currently in 100% compliance. 3.0 SUMMARY OF FINDINGS 3.1 The facility was found to be in clean operating condition. No immediate problems were identified. 3.2 The water treatment system was found to be in good operating condition. No immediate problems were identified. 3.3 All exterior tanks, pumps, and associated equipment were found to be in good condition and properly bermed in case of accidental spills. 3.4 Corona Energy Partners, Ltd. holds a direct discharge permit prepared by G & G Environmental Compliance, Inc. for WMWD. The permit was approved for structure and content by both the SAWPA and OCSD (Permit No. 4B-93-S20, Effective Date: July 27, 2012, Expiry date: July 26, 2014). 3.5 No problems were found with the present permit. 3.6 No record of any enforcement was observed in the past year. The discharge was apparently in compliance with all permit limits and requirements. Should there be any questions regarding the contents of this inspection report, please contact Mr. Najib Saadeh by phone at (714) 667-2300 or by e-mail at nsaadeh@eecworld.com. Appendices: A. Site Photograph B. Direct User Discharge Permit No. 4B-93-S20 APPENDIX A SITE PHOTOGRAPH Industrial User Inspection Report: Corona Energy Partners, Ltd. November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit A-1 EEC Photo 1 Corona Energy Partners, Ltd. Generator Building Photographed by John Parnell APPENDIX B DIRECT USER DISCHARGE PERMIT NO. 4B-93-S20 Industrial User Inspection Report Santa Ana Watershed Project Authority Audit Industrial User: Dairy Farmers of America Distilled Water Plant (Sections 1–3) Industrial User 2: Corona Resource Recovery, LLC (Sections 4.0–6.0) Industrial User Address: 1138 West Rincon Street, Corona, California 92880 Industrial User Permit Number: 4B-08-S63 Industrial User Representative: Mr. Larry Edwards, Plant Operator Indirect/Direct User: Direct Agency Area: Western Municipal Water District Agency Representative: Mr. Benjamin Burgett, G & G Environmental Compliance Inc., Consultants to Western Municipal Water District Inspection Date: August 28, 2012, Scheduled Inspection EEC/PSI Inspectors: Dr. John R. Parnell, Pretreatment Solutions, Inc. Mr. Najib Saadeh, Environmental Engineering & Contracting, Inc. Report Date: November 1, 2012 1.0 SCOPE AND PURPOSE On behalf of the Orange County Sanitary District (OCSD), Environmental Engineering & Contracting (EEC) performed an inspection of selected industrial users discharging into the Inland Empire Brine Line (IEBL; formerly known as the Santa Ana Regional Interceptor, SARI). This inspection is part of an audit of the pretreatment programs of the Santa Ana Watershed Project Authority (SAWPA) and its member agencies. Industrial users were selectively inspected based on volume of wastewater discharged and/or industry type in order to evaluate the performance of the pretreatment programs. The current evaluation is one of a series of inspections of direct and indirect dischargers into the IEBL. Direct dischargers are typically close enough to construct a direct connection to the IEBL and produce enough liquid waste to economically justify the connection cost. Indirect dischargers generate waste streams that are high in total dissolved solids and are not located close enough to the IEBL to make a direct connection. In general, the volume of wastewater discharged at liquid waste hauler (LWH) collection stations varies. The quantity of liquid waste discharged at these stations can vary from one or two truckloads per week to 100,000 gallons per day in some cases. Liquid waste from indirect dischargers is disposed of at collection stations using a permitted commercial LWH permitted by SAWPA. On August 28, 2012, EEC completed a performance evaluation of the regulatory controls at the Dairy Farmers of America Distilled Water Plant located at 1138 West Rincon Street in the City of Corona, California. The equipment used by Corona Resource Recovery, LLC on the same site was also inspected. Dairy Farmers of America is permitted and inspected by G & G Environmental Compliance Inc. on behalf of the Western Municipal Water District (MWMD) and is monitored by WMWD. The inspection was conducted to evaluate whether Dairy Farmers of America has developed and implemented sufficient Industrial User Inspection Report: Dairy Farmers of America and Corona Resource Recovery, LLC November 1, 2012 W2422.01T 2 EEC measures to ensure that discharges into the IEBL comply with the terms and conditions of all applicable agreements and regulations, including OCSD ordinances and 40 CFR 403. 1.1 General and Process Description The primary sources of influent water that Dairy Farmers of America receives comes from a series of onsite wells and the reverse osmosis high-strength brine reject wastewater from the City of Corona- Temescal Desalter. In addition, the clean-in-place wash waters used to clean the distillation plant and the cooling tower waters for the condenser unit are also recycled through the distillation process. The distillation equipment heats the incoming water in a heat exchanger using low-pressure steam from the Corona Energy Partners electrical generating plant located next door to the Dairy Farmers of America facility. Dairy Farmers of America originally used the steam in a cheese manufacturing plant but the plant was closed and the equipment was modified to form the current distillation plant. In the distillation process, the steam condenses in the heat exchanger and the condensate is recycled to the Corona Energy Partners plant to be reheated. The steam created from heating the incoming water supply is condensed in a series of distillation towers and produces pure distilled water (Appendix A, Site Photographs, Photo 1). Approximately 110,000 gallons of distilled water are produced for every 170,000 gallons of water processed every day. The distilled water is pumped back to the City of Corona-Temescal Desalter where it undergoes reverse osmosis again before being discharged to the local potable water system. Currently, Dairy Farmers of America employs four employees who work in two shifts (two persons per shift) covering a 14-hour day from 9:00 a.m. to 11:00 p.m., seven days per week. No immediate expansion of the distillation plant is anticipated in the next few years; however, the plant may shut down once the steam-supply contract with Corona Energy Partners expires. 1.2 Wastewater Sources The reject wastewater from the distillation process is the only source of wastewater. The wastewater is discharged in batches to an equalization tank. 1.3 Facility Process Wastewater Treatment System The well water at the Dairy Farmers of America plant has a high concentration of manganese that remains in the reject wastewater from the distillation process. Concentrated reject wastewater from the distillation process is collected in a 500,000-gallon equalization tank. If necessary, the pH of the wastewater can be adjusted in this tank using sodium hydroxide or sulfuric acid. The reject wastewater normally has a pH around 8.0 and does not need any adjustment before being discharged directly to the IEBL. 1.4 Wastewater Discharge Wastewater from the equalization tank discharges directly into the 6-inch sewer lateral. The flow can be controlled by a hand-operated valve that reduces the flow to 350 gallons per minute. The Dairy Farmers of America’s sewer lateral connects to the IEBL, which is located on Rincon Street, via a pit that also Industrial User Inspection Report: Dairy Farmers of America and Corona Resource Recovery, LLC November 1, 2012 W2422.01T 3 EEC receives the discharge from Corona Energy Partners. A monitoring manhole/metering flume located on- site in the northeast corner of the service yard is the permitted sampling point for the subject facility. 2.0 COMPLIANCE WITH FEDERAL CATEGORICAL STANDARDS Federal categorical standards are not applicable as the distillation plant is not a categorical industry. The facility is required to meet the requirements specified in the permit issued by WMWD. 2.1 Compliance with Other Federal Pretreatment Requirements Dairy Farmers of America is classified as a significant industrial user (Part 1D of the permit) and is subject to the local limits developed by OCSD. Like any industrial user, it must also comply with pretreatment requirements in 40 CFR 403, including but not limited to, national prohibitions in 40 CFR 403.5 and reporting requirements in 40 CFR 403.12. 2.2 Compliance with Local Limits and Actions by the Agency All OCSD local limits are included in the permit and must be sampled for using composite sampling except for pH and oil and grease, which must be collected as grab samples. The permit requires that sampling be performed by the permittee twice per year (in April and in October) at the designated sampling point. Daily recording is required for pH and flow measurement. WMWD also samples once annually for compliance and monthly for billing. G & G Environmental Compliance, Inc. inspects the facility twice per year for WMWD. The facility is currently in 100% compliance with local limits. 3.0 SUMMARY OF FINDINGS 3.1 The facility was inspected and found to be in clean operating condition and no immediate problems were identified. 3.2 The wastewater treatment system was found to be in good operating condition and no immediate problems were identified. 3.3 All exterior tanks, pumps, and associated equipment were found to be in good condition and properly bermed in case of emergency spills or accidents. 3.4 Dairy Farmers of America is correctly identified as a noncategorical significant industrial user subject to 40 CFR 403, OCSD ordinance, and local limits. Dairy Farmers of America holds a direct discharge permit prepared by G & G Environmental Compliance, Inc. on behalf of WMWD. The permit has been approved for structure and content by both, SAWPA and OCSD. Since the indirect discharge to the IEBL and the OCSD wastewater treatment plant originates from the permittee’s industrial processes, the permit contains OCSD’s local limits and surcharge limits that apply at the end of pipe discharge point. In this instance, the sample point represents the end of pipe discharge (Permit No. 4B-08-S63, Issue Date: July 1, 2011, Effective Date: July 14, 2011, Expiration date: July 13, 2013). Industrial User Inspection Report: Dairy Farmers of America and Corona Resource Recovery, LLC November 1, 2012 W2422.01T 4 EEC 3.5 The permit does not contain any limit for biological oxygen demand or total suspended solids, and semiannual sampling is required for both parameters. Monthly sampling by WMWD for surcharge purposes is not mentioned in the permit. 3.6 The multijurisdictional pretreatment agreement between WMWD and SAWPA does not define a “standby” permit nor does it contain a process for issuing such a permit. Consequently, there is no basis for the legality and validity of this type of permit. The permit should be reissued as a regular permit. In the future, instead of issuing “standby” permits, WMWD should develop a process for expediting the issuance of permits without undermining the necessary due diligence process. 3.7 In Sections 1.A.1 and 1.B, the permit refers to the sample location as Location 001. In Section 1.G, the permit describes the same location as Discharge Point A. In Section 2A, the permit refers to a designated sample location that is described and very poorly illustrated in Section 2.C as a sample location. The permit should be revised to make the sample location the same in all sections. 3.8 Dairy Farmers of America has been in compliance since the permit was last issued on July 1, 2011. 4.0 RELATIONSHIP BETWEEN DAIRY FARMERS OF AMERICA AND CORONA RESOURCE RECOVERY On April 30, 2010, G & G Environmental Compliance Inc. (on behalf of WMWD) received a permit application from Corona Resource Recovery to use a large amount of equipment from the Dairy Farmers of America’s to process grease trap and food processor waste at 1138 West Rincon Street, Corona, California. Thirteen months later, on July 1, 2011, after Dairy Farmers of America and Corona Resource Recovery signed an industrial lease agreement, a direct discharge permit (Permit 4B-11-S66) issued to Dairy Farmers of America names Corona Resource Recovery as the operator. This permit allowed Corona Resource Recovery to discharge wastewater from the distilled water process and the food waste and grease interceptor processes directly to the IEBL through the monitoring manhole Sample Location 001 located on the property. On the same day (July 1, 2011) Permit 4B-08-S63, was reissued to Dairy Farmers of America as a “standby” permit allowing the discharge of distilled water and reject wastewater through the same Sample Location 001 discharge point to the IEBL. The standby permit is intended to avoid an interruption in Dairy Farmers of America’s manufacturing in case Corona Resource Recovery stopped receiving the wastewater from Dairy Farmers of America. If Dairy Farmers of America could not operate until a permit is issued, this would also cause the Corona Energy Partners facility to cease its production until WMWD issues a permit. Corona Resource Recovery began receiving and discharging grease trap and food waste to the IEBL in October 2011. The discharge continued until April 6, 2012, when the WMWD issued a cease and desist order to Corona Resource Recovery. Dairy Farmers of America terminated its lease with Corona Resource Recovery on July 27, 2012, and by the middle of August 2012, Corona Resource Recovery was locked out of the premises and unable to secure its wastes remaining on the site. Industrial User Inspection Report: Dairy Farmers of America and Corona Resource Recovery, LLC November 1, 2012 W2422.01T 5 EEC 5.0 PERMIT DETAILS The permit was issued to Dairy Farmers of America with the operator listed as Corona Resource Recovery, LLC: Permit No. 4B-11-S66. Effective Date: July 13, 2011, Expiration date: July 12, 2013. 6.0 INSPECTION OF EQUIPMENT USED BY CRR The site visit on August 28, 2012, included an inspection of the equipment used by Corona Resource Recovery. This equipment included a complete-mix biological treatment system, oil and grease separation equipment, flow equalization tanks, a centrifuge and pH neutralization equipment. All equipment appeared to be in the same condition as when Corona Resource Recovery had originally leased the property. No sign of any damage or any removal of equipment was noted (Appendix A, Photo 2). EEC was informed that Corona Resource Recovery left behind 300,000 gallons of waste oil. The plant operator informed the inspection team that the waste oil was still on-site. Should there be any questions regarding the contents of this inspection report, please contact Mr. Najib Saadeh by phone at (714) 667-2300 or by e-mail at nsaadeh@eecworld.com. Appendices: A. Site Photographs B. Direct User Discharge Permit No. 4B-08-S63 APPENDIX A SITE PHOTOGRAPHS Industrial User Inspection Report: Dairy Farmers of America and Corona Resource Recovery, LLC November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit A-1 EEC Photo 1 Dairy Farmers of America Distilled Water Plant Photographed by John Parnell Photo 2 Part of Biological Treatment System Used by Corona Resource Recovery, LLC Photographed by John Parnell APPENDIX B DIRECT USER DISCHARGE PERMIT NO. 4B-08-S63 Industrial User Inspection Report Santa Ana Watershed Project Authority Audit Industrial User: Menifee Valley Liquid Waste Hauler Discharge Station Industrial User Address: 29541 Murietta Road, Sun City, CA 92586 Industrial User Permit Number: 552 Industrial User Representative: Mr. Gregg Murray, Source Control Manager, Eastern Municipal Water District Indirect/Direct User: Direct User Agency Area: Eastern Municipal Water District Agency Representatives: Mr. Gregg Murray, Source Control Manager, Eastern Municipal Water District Mr. Dennis Martz, Senior Source Control Inspector, Eastern Municipal Water District Inspection Date: August 30, 2012, Scheduled Inspection EEC/PSI Inspectors: Dr. John Parnell, Pretreatment Solutions, Inc. Mr. Najib Saadeh, Environmental Engineering & Contracting, Inc. Report Date: November 1, 2012 1.0 SCOPE AND PURPOSE On behalf of the Orange County Sanitary District (OCSD), Environmental Engineering & Contracting (EEC) performed an inspection of selected industrial users discharging into the Inland Empire Brine Line (IEBL; formerly known as the Santa Ana Regional Interceptor, SARI). This inspection is part of an audit of the pretreatment programs of the Santa Ana Watershed Project Authority (SAWPA) and its member agencies. To evaluate the performance of the pretreatment programs, industrial users were selectively inspected based on volume of wastewater discharged and/or industry type. The inspections were scheduled ahead of time with agency representatives in charge. The agency representatives contacted the key personnel at the various facilities to confirm their availability and to describe the scope of the inspection and introduce the audit team. As part of the audit, all four liquid-waste hauler (LWH) discharge stations within SAWPA’s service area were inspected. The current evaluation is one of a series of inspections of direct and indirect dischargers into the IEBL. Direct dischargers are typically close enough to construct a direct connection to the IEBL and produce enough waste to economically justify the connection cost. Indirect dischargers generate waste streams that are high in total dissolved solids and are not located close enough to the IEBL to make a direct connection. In general, the volume of wastewater discharged at LWH discharge stations varies. The quantity of liquid waste discharged at these stations can vary from one or two truckloads per week to 100,000 gallons per day in some cases. Liquid waste from indirect dischargers is disposed of at LWH discharge stations using a commercial LWH permitted by SAWPA. Industrial User Inspection Report: Menifee Valley Liquid Waste Hauler Discharge Station November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 2 EEC On August 30, 2012, EEC completed a performance evaluation of the regulatory controls at the Menifee Valley LWH discharge station (Appendix A, Site Photographs, Photo 1). The station is permitted, operated, and managed by the Eastern Municipal Water District (EMWD). The inspection was conducted to evaluate whether SAWPA has developed and implemented sufficient measures to ensure that discharges through the LWH discharge station in Sun City comply with the terms and conditions of all applicable agreements and regulations, including OCSD ordinances and 40 CFR 403. 1.1 General and Process Description The Menifee Valley LWH discharge station serves as a discharge point allowing indirect dischargers in the EMWD or any permitted LWH within SAWPA’s service area to discharge wastewater into the IEBL. The discharge point at the station is a hose connection to a large wet well from which the wastewater can be pumped to the IEBL connection, (Appendix A, Photos 2 and 3). The wet well also directly receives wastewater effluents from the Perris and Menifee Desalter plants (both of which are located on the same property; Appendix A, Photo 4). The wet well has a covered roof to minimize rainwater intrusion. The effluent from the Inland Empire Energy Center (IEEC) is also piped directly to the Menifee Valley Truck Waste Disposal Facility. IEEC is permitted to directly discharge up to 1.2 million gallons of wastewater per day to the Menifee Valley LWH discharge station via a dedicated force main. Currently, only the wastewater from International Rectifier is allowed to be discharged at the station and the only LWH permitted to transport the wastewater is Hazardous Waste transportation Services, Inc. (HTS). A supervisor employed by HTS is on duty 24 hours per day at the International Rectifier facility. In order to reduce response time, the supervisor calls HTS whenever enough wastewater is produced at the site to fill a truckload, and the company sends an empty truck to pick up the load. Truckloads of approximately 6,200 gallons per load from International Rectifier are discharged at the Menifee Valley LWH discharge station, 12 to 16 times over each 24-hour period, 7 days per week. Before the LWH truck leaves the International Rectifier site, one-quart grab samples are collected from each truckload to ensure compliance with the pH limits. Beckman pH meters are used to monitor pH. The pH meters are calibrated each time they are used. In addition, a three-part manifest is completed for every truckload, with one part retained by International Rectifier, one part by the LWH, and the third part is sent to EMWD. Based on an agreement with International Rectifier has an agreement with the Western Municipal Water District (WMWD), should the Menifee Valley Truck Waste Disposal Facility become unavailable or close for any reason, International Rectifier can discharge at the WMWD’s discharge station until the Menifee Valley disposal station reopens. Discharges from Minegar Environmental Systems, Inc. are no longer allowed at the Menifee Valley LWH discharge station because the permittee is outside the SAWPA service area. Access to the Menifee Valley station is restricted. Prior to entering the Menifee Valley LWH discharge station, the truck driver must enter a security code to open the main entrance gate (Appendix A, Photo 5). A video camera mounted on the lamppost beside the gate continuously monitors truck movement through the gate and records number plates for verification (Appendix A, Photo 5). Once inside the facility, the truck driver directly connects the hose to the truck and can discharge the load directly into the wet well. No attendant is on duty and there is no sampling of the wastewater at this point. Twice a month an inspector from EMWD visits the Menifee Valley LWH discharge station and collects pH samples directly from the hauler trucks discharging at the station. If the pH value is out of the permitted limits, the inspector refuses to allow the truck to discharge the load. Legal loads are Industrial User Inspection Report: Menifee Valley Liquid Waste Hauler Discharge Station November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 3 EEC discharged to the wet well where they directly mix with the effluents from the Perris and Menifee Desalter Plants. Once the wet well reaches a certain level, the float switches turn on the pumps that pump the wastewater mixture through a force main to the connection with the IEBL several miles away (Appendix A, Photo 6). Automatic samplers located on the top of the wet well can collect samples from the Perris and Menifee Desalter flows and from the wet well mixture of wastewater (Appendix A, Photo 7). By agreement with SAWPA, EMWD is responsible for the implementation of the pretreatment program for industries located in its jurisdiction and is permitted to transport and discharge brine wastewater into the Menifee Valley LWH discharge station. 1.2 Wastewater Sources The sole source of the indirect wastewater discharged at the Menifee Valley LWH discharge station is the effluent transported from International Rectifier by HTS hauler trucks. Direct discharges also occur from the Perris and Menifee Desalters and the IEEC. 1.3 Facility Process Wastewater Treatment System The wastewater is not treated at the Menifee Valley LWH discharge station. Wastewater is pumped from the wet well to the connection with the IEBL and is not treated before it reaches the OCSD water treatment facility. 1.4 Wastewater Discharge Wastewater received at the LWH discharge station is pumped to the connection with the IEBL without any treatment. 2.0 COMPLIANCE WITH FEDERAL CATEGORICAL STANDARDS The facility is not subject to any federal categorical standards. The facility is required to meet only requirements specified in the permit issued by WMWD. 2.1 Compliance with Other Federal Pretreatment Requirements While the facility is not subject to federal pretreatment requirements, limits that apply to dischargers with categorical standards also apply at this location. 2.2 Compliance with Local Limits and Actions by the Agency The facility’s most recent direct-user discharge permit (Permit No. 552) was issued to EMWD by EMWD. As is the case with all four LWH disposal stations within SAWPA’s service area, each member agency permits and monitors its own collection station. 3.0 SUMMARY OF FINDINGS 3.1 Overall, the Menifee Valley LWH discharge station was observed to be clean and in good working order. Industrial User Inspection Report: Menifee Valley Liquid Waste Hauler Discharge Station November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 4 EEC 3.2 Copies of manifests were provided to the audit team during the interview with EMWD on August 21, 2012. These manifests contained the pH readings taken by HTS from both the source tank and the loading flow. No verification of the pH by EMWD was entered on the required section of the form on the three different manifests produced at the interview. There does not appear to be a cross-check of the pH level for each load prior to delivery to the Menifee Valley LWH discharge station. Furthermore, there is no place on the manifest form for any delivery signature and there is no operator at the Menifee Valley LWH discharge station to sign the form or receive the wastewater discharge. 3.3 Since only one permittee (International Rectifier) is allowed to discharge wastewater and only one hauler (HTS) is allowed to enter the station, the possibility of unauthorized waste entering the discharge station is currently minimal. If other permittees and haulers are allowed to discharge wastewater in the future, the present system would need to be modified to ensure greater protection of the IEBL. 3.4 No samples are being collected of the wastewater discharged at the LWH discharge station. Part 2C of the permit states, “Permittee is not required to monitor wastewater to be discharged to the IEBL System.” Sampling at the station is essential; the permit must be changed to include a requirement for sampling and testing. The station is subject to local limits, and compliance with these limits must be demonstrated. Furthermore, LWH discharge station is subject to the more stringent limits for categorical dischargers when these limits apply. Therefore, in addition to sampling at the loading point, the audit team highly recommends implementation of a regular or random sampling program at the LWH discharge station. Other member agencies have adopted procedures to sample LWH loads at the point of discharge into the IEBL. Once samples are collected, the control agency can then submit the samples for analysis based on suspected loads or random selection. In addition to monitoring compliance with local and categorical limits, sampling of trucks at the LWH discharge stations is recommended because it raises the level of confidence that the LWH does not tamper with the load during transit. 3.5 The term liquid-waste hauler (LWH) discharge station should be used throughout the permit and other documents because it better conveys that the station is only an intermediate destination before the wastewater is treated at OCSD’s treatment facility and subsequently released into the environment. 3.6 The EMWD LWH discharge station’s most recent direct-user discharge permit (Permit No. 552) was issued to EMWD by EMWD. In general, self-permitting is not recommended because it does not always provide the desired level of control to ensure compliance with regulatory controls. Should there be any questions regarding the contents of this inspection report, please contact Mr. Najib Saadeh by phone at (714) 667-2300 or by e-mail at nsaadeh@eecworld.com. Appendices: A. Site Photographs B. Direct User Discharge Permit No. 552 APPENDIX A SITE PHOTOGRAPHS Industrial User Inspection Report: Menifee Valley Liquid Waste Hauler Discharge Station November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit A-1 EEC Photo 1 Menifee Valley liquid waste hauler discharge station Photographed by John Parnell Photo 2 Discharge station Photographed by John Parnell Photo 3 Closer view of discharge hose connection Photographed by John Parnell Photo 4 Discharge from Perris and Menifee desalter plants to disposal wet well Photographed by John Parnell Industrial User Inspection Report: Menifee Valley Liquid Waste Hauler Discharge Station November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit A-2 EEC Photo 5 View of main gate from inside the facility Photographed by John Parnell Photo 6 Pumps transferring wastewater from wet well to Inland Empire Brine Line connection Photographed by John Parnell Photo 7 Automatic samplers for Perris and Menifee desalters and the wet well mixture Photographed by John Parnell APPENDIX B DIRECT USER DISCHARGE PERMIT NO. 552 Industrial User Inspection Report Santa Ana Watershed Project Authority Audit Industrial User: Frontier Aluminum Corporation Industrial User Address: 2480 Railroad Street, Corona, California 92880-5418 Industrial User Permit Number: DS-064 Industrial User Representative/s: Mr. Ron Paez, Suron Solutions, Inc. Consultant to Frontier Aluminum Corporation Indirect/Direct User: Indirect User Agency Area: Western Municipal Water District Agency Representative/s: Mr. Benjamin Burgett, G & G Environmental Compliance Inc. (Consultants to Western Municipal Water District) Inspection Date: August 28, 2012, Scheduled Inspection EEC/PSI Inspectors: Mr. John R. Parnell, Ph.D., Pretreatment Solutions, Inc. Mr. Najib Saadeh, Environmental Engineering & Contracting, Inc. Report Date: October 9, 2012 1.0 SCOPE AND PURPOSE On behalf of the Orange County Sanitary District (OCSD), Environmental Engineering & Contracting (EEC) performed an inspection of selected industrial users discharging into the Inland Empire Brine Line (IEBL; formerly known as the Santa Ana Regional Interceptor, SARI). This inspection is part of an audit of the pretreatment programs of the Santa Ana Watershed Project Authority (SAWPA) and its member agencies. Industrial users were selectively inspected based on volume of wastewater discharged and/or industry type in order to evaluate the performance of the pretreatment programs. The current evaluation is one of a series of inspections of direct and indirect dischargers into the IEBL. Direct dischargers are typically close enough to construct a direct connection to the IEBL and produce enough waste to economically justify the connection cost. Indirect dischargers generate waste streams that are high in total dissolved solids and are not located close enough to the IEBL to make a direct connection. In general, the volume of wastewater discharged at LWH discharge stations varies. The quantity of liquid waste discharged at these stations can vary from one or two truck loads per week to 100,000 gallons per day in some cases. Liquid waste from indirect dischargers is disposed of at discharge stations using a permitted commercial LWH permitted by SAWPA. On August 28, 2012, EEC completed a performance evaluation of the regulatory controls at the Frontier Aluminum Corporation located at 2480 Railroad Street in the City of Corona. The facility is permitted and inspected by G & G Environmental Compliance Inc., consultants to Western Municipal Water District (WMWD). The inspection was conducted to evaluate whether Frontier Aluminum Corporation has developed and implemented sufficient measures to ensure that its discharges into the IEBL comply with Industrial User Inspection Report: Frontier Aluminum Corporation November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 2 EEC the terms and conditions of all applicable agreements and regulations, including OCSD ordinances and 40 CFR 403. 1.1 General and Process Description Frontier Aluminum Corporation prepares and paints various extruded aluminum parts for window and door frames, medical devices, and motor home parts. After they are painted, some of the parts are used to build finished articles. The facility also performs specialty jobs such as secondary machining of wheel chair parts, etc. When the current permit was issued, the facility was extruding aluminum, but this process was recently shut down and only painting continues at the facility. Up to 45 employees still work at the facility but production is down to one shift on one day per week at present. 1.2 Wastewater Sources Process wastewater is produced from the preparation of extruded aluminum parts prior to painting in a painting booth. Aluminum extrusions are hung on racks on a moveable overhead belt system, cleaned in a caustic bath, and rinsed prior to treatment (Appendix A, Site Photographs, Photo 1). The extrusions are then treated with a chrome phosphate and hydrofluoric acid solution to improve adhesion of the paint to the aluminum. Finally, the parts are rinsed twice to remove particulates. The parts then move through a painting booth and through an oven before emerging dry and ready for construction. 1.3 Facility Process Wastewater Treatment System Wastewaters from the alkaline and acid solutions described above are transferred to storage tanks prior to processing. The wastewater is transferred to a 3,000-gallon treatment tank and mixed with sodium metabisulfite to reduce the hexavalent chrome to trivalent chrome (Appendix A, Photo 2). Then, magnesium oxide and lime are added to reduce fluoride levels. Phosphoric acid is added to reduce the pH further, and the trivalent chrome precipitates out of the liquid and collects at the bottom of the tank. The precipitate is removed from the bottom of the tank and a filter press is used to produce a chrome hazardous waste sludge, which is hauled off by a licensed waste hauler (Appendix A, Photo 3). 1.4 Wastewater Discharge The wastewater liquid is decanted from the top of the tank and transferred to the 4,500-gallon storage tank to await transfer by a HazMat Trans, Inc. hauler company truck to the WMWD brine line truck disposal site (Appendix A, Photo 4). Currently, wastewater is collected approximately once every other week. 2.0 COMPLIANCE WITH FEDERAL CATEGORICAL STANDARDS This facility is no longer correctly categorized as a categorical industrial user (CIU) subject to 40 CFR Part 467 (Aluminum Forming Point Source Category), Subpart C, (Extrusion Subcategory) Paragraph 467.36 (Pretreatment Standards for New Sources) as it no longer performs any form of extrusion at the site. The permit expires in October 2012 and a new inspection of the facility should determine that the etching process performed on the aluminum parts prior to painting suggests that the facility should be reclassified as a Metal Finishing Point Source Category subject to the regulations in 40 CFR 433. Industrial User Inspection Report: Frontier Aluminum Corporation November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 3 EEC 2.1 Compliance with Other Federal Pretreatment Requirements Currently, the facility is a CIU subject to a federal categorical standard and therefore is a significant industrial user. Like any industrial user, the facility must comply with pretreatment requirements in 40 CFR 403, including, but not limited to, federal prohibitions in 40 CFR 403.5 and reporting requirements in 40 CFR 403.12. 2.2 Compliance with Local Limits and Actions by the Agency The permit must be completely rewritten to represent the change in classification of this facility. The new permit should contain both OCSD-required local limits and categorical standards found at 40 CFR 433. The sample point is a spigot located on the 4,500-gallon wastewater storage tank (Appendix A, Photo 5). The tank is mixed for 5 to 10 minutes prior to sampling and all samples are collected as grabs. Currently, WMWD performs compliance sampling quarterly and monthly (for surcharge purposes), and G & G Environmental Compliance Inc. inspects the facility quarterly. The permittee will still need to collects samples quarterly to meet pretreatment standards and local limits and monthly for billing purposes. WMWD also samples and inspects on a quarterly basis. In 2010, the facility recorded violations of the chromium limits and received a notice of violation from WMWD. 3.0 SUMMARY OF FINDINGS 3.1 The facility was inspected and found to be in clean operating condition. No immediate problems were identified. 3.2 The wastewater treatment system was found to be in good operating condition. No immediate problems were identified. 3.3 Frontier Aluminum Corporation is now incorrectly identified as a CIU subject to 40 CFR 467, as all extrusion has ceased at the site indefinitely. The facility should be reclassified as a Metal Finisher subject to 40 CFR 433. WMWD representative became aware of the change at the time of the inspection conducted by EEC. 3.4 Frontier Aluminum Corporation holds a permit for indirect discharge. The permit was prepared by G & G Environmental Compliance, Inc. for WMWD and has been approved for structure and content by both the Santa Ana Watershed Project Authority and OCSD (Permit No. DS-064, Effective Date: October 29, 2010, Expiration date: October 28, 2012). 3.5 Extrusion at the facility ceased approximately one year ago and since, WMWD inspected the facility at least three times. Frontier should have informed WMWD, as required in its permit (Part 1 – Discharge Requirements, Section C.4), of the process change in the planning stage. Furthermore, WMWD’s inspections should have revealed that extrusion has stopped at the facility. 3.6 The permit should be reissued after an inspection to determine if the facility intends to continue production or not. 3.7 No best management practices were noted. Industrial User Inspection Report: Frontier Aluminum Corporation November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 4 EEC Should there be any questions regarding the contents of this inspection report, please contact Mr. Najib Saadeh by phone at (714) 667-2300 or by e-mail at nsaadeh@eecworld.com. Appendices: A. Site Photographs B. Indirect User Discharge Permit No. DS-064 APPENDIX A SITE PHOTOGRAPHS Industrial User Inspection Report: Frontier Aluminum Corporation October 9, 2012 W2422.01T Santa Ana Watershed Project Authority Audit A-1 EEC Photo 1 Aluminum Parts Prior to Washing Photographed by John Parnell Photo 2 Wastewater Treatment system Photographed by John Parnell Industrial User Inspection Report: Frontier Aluminum Corporation October 9, 2012 W2422.01T Santa Ana Watershed Project Authority Audit A-2 EEC Photo 3 Filter Press Producing Chrome Hazardous Waste Photographed by John Parnell Photo 4 Hauler Connection Point Photographed by John Parnell Photo 5 Sample Spigot (Small Pipe Hanging on Tank) Photographed by John Parnell APPENDIX B DIRECT USER DISCHARGE PERMIT NO. DS-064 Industrial User Inspection Report Santa Ana Watershed Project Authority Audit Industrial User: Inland Empire Energy Center Industrial User Address: 26226 Antelope Road, Romoland, CA 92585 Industrial User Permit Number: 554 Industrial User Representative: Mrs. Alisa Moretto, Environmental, Health and Safety Manager Indirect/Direct User: Direct User Agency Area: Eastern Municipal Water District Agency Representative: Mr. Gregg Murray, EMWD Source Control Manager Inspection Date: September 6, 2012, Scheduled Inspection EEC/PSI Inspector: Mr. Najib Saadeh, Environmental Engineering & Contracting, Inc. Report Date: November 1, 2012 1.0 SCOPE AND PURPOSE On behalf of the Orange County Sanitary District (OCSD), Environmental Engineering & Contracting (EEC) performed an inspection of selected industrial users discharging into the Inland Empire Brine Line (IEBL; formerly known as the Santa Ana Regional Interceptor, SARI). This inspection is part of an audit of the pretreatment programs of the Santa Ana Watershed Project Authority (SAWPA) and its member agencies. To evaluate the performance of the pretreatment programs, industrial users were selectively inspected based on volume of wastewater discharged and/or industry type. The current evaluation is one of a series of inspections of direct and indirect dischargers into the IEBL. Direct dischargers are typically close enough to construct a direct connection to the IEBL and produce enough waste to economically justify the connection cost. Indirect dischargers generate waste streams that are high in total dissolved solids and are not located close enough to the IEBL to make a direct connection. In general, the volume of wastewater discharged at LWH discharge stations varies. The quantity of liquid waste discharged at these stations can vary from one or two truckloads per week to 100,000 gallons per day in some cases. Liquid waste from indirect dischargers is disposed of at discharge stations using a permitted commercial LWH permitted by SAWPA. On September 6, 2012, Environmental Engineering & Contracting, Inc. (EEC) completed a performance evaluation of the regulatory controls at the Inland Empire Energy Center (IEEC) located at 26226 Antelope Road, Romoland, California. The facility is permitted by the Eastern Municipal Water District (EWMD). IEEC is owned and operated by General Electric (GE). The inspection was conducted to evaluate whether EWMD has developed and implemented sufficient measures to ensure that discharges into the IEBL comply with the terms and conditions of all applicable agreements and regulations, including OCSD ordinance and 40 CFR 403. Industrial User Inspection Report: Inland Empire Energy Center November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 2 EEC 1.1 General and Process Description The IEEC facility was previously owned by the Calpine Corporation before being purchased by GE in April 2008. The facility became fully operational in July 2010 and is GE's first 60Hz H-System power plant producing 800 MW of electricity. With both units operational, IEEC is currently generating a 740 MW output. An on-site switchyard connects IEEC to the existing Southern California Edison Valley substation. The substation is approximately one mile east of the site, across a 500 kV transmission line. Natural gas is delivered through the 20-inch Menifee Road pipeline which is connected to the existing Sempra Energy lines. The source of the water used by IEEC consists of reclaimed water from EMWD at the maximum rate of 5,000 gallons per minute. The IEEC facility is connected to the IEBL though a 4.7 mile, 18 in pipeline. Wastewater discharge from the IEEC facility into the IEBL commenced on May 1, 2008. The IEEC facility has the capacity to discharge a maximum of 1.2 Million gallons per day of wastewater into the Brine Line. EMWD has issued a Direct User Discharge Permit for the IEEC facility WMWD collection station (Appendix B, Permit No. 554). The permit was issued on October 1, 2010, and became effective on October 5, 2010. The permit is due to expire on October 4, 2012. Sanitary wastewater is discharged to a separate sewer line on McLaughlin Road. 1.2 Wastewater Sources Currently, the IEEC wastewater consists of 1.2 million gallons of process wastewater from boiler blow- down, air scrubber air pollution control system, ion exchange water treatment system, RO reject water, cooling tower blow-down and floor drains. All floor drains lead to the cooling towers. Water from floor drains is added to the cooling tower make up water and is subsequently treated with the cooling tower blow-down. IEEC does not discharge any storm water into the IEBL. The IEEC facility includes two open interception ditches along the northern and eastern perimeters to capture run-on storm water flows. The interception ditch along the northern boundary has a capacity of 4.6 cubic feet per second for the 100-year, 1-hour event; drains to the west through a culvert under Antelope Road; and continues in a southward direction via an existing shallow ditch on the west side of Antelope Road. The interception ditch along the easterly boundary is a landscaped ditch sized for a capacity of 407 cubic feet per second for the 100-year, 1-hour event; drains to the south; and discharges along the southern boundary of the IEEC property. 1.3 Facility Process Wastewater Treatment System Blowdown from the cooling tower is discharged into the IEBL. Other wastewater streams are recycled for use as cooling tower makeup. Recycled streams include the reject stream from reverse osmosis, blowdown from the heat recovery steam generator (HRSG), and recovery from plant service water drains. IEEC produces nonreclaimable wastewater at an average rate of approximately 0.86 million gallon per day and up to 1.2 million gallon per day at peak flow. The nonreclaimable wastewater is discharged into Industrial User Inspection Report: Inland Empire Energy Center November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 3 EEC a 4.7-mile-long pipeline that conveys the wastewater to EMWD’s Reach 4 Pipeline, which in turn conveys the wastewater to the Temescal Valley Regional Interceptor and the IEBL. 1.4 Wastewater Discharge Wastewater discharge is sampled for categorical limits at Sample Point 001 (Appendix A, Site Photographs, Photo 1) and for local limits at Sample Point 002 (Appendix A, Photo 2) before both wastewater streams discharge into the IEBL. IEEC is subject to self-monitoring requirements and two permanently installed composite samples are used to collect quarterly samples (Appendix A, Photo 3). 2.0 COMPLIANCE WITH FEDERAL CATEGORICAL STANDARDS The facility is a significant industrial user and is subject to federal and State pretreatment standards and requirements as specified in 40 CFR 403, “Federal Pretreatment Regulations for Existing and New Sources of Pollution,” 40 CFR 423, “Steam Electric Power Generation Point Source Category,” Subpart 423.17. 2.1 Compliance with Other Federal Pretreatment Requirements The facility is not subject to any other federal pretreatment requirements. 2.2 Compliance with Local Limits and Actions by the Agency In addition to the federal and State requirements, the facility is subject to the requirements of EMWD Non-Reclaimable Wastewater Ordinance, SAWPA’s Ordinance, and the industrial wastewater discharge permit issued by EMWD. 3.0 SUMMARY OF FINDINGS 3.1 Overall, the IEEC facility was observed to be clean and in good working order. 3.2 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. Although not a regulatory requirement, EEC recommends that a list of the waste streams with categorical limits be made into an integral part of the permit. 3.3 The facility is equipped with permanent gauges to provide real-time flow rates and pH measurements (Appendix A, Photo 4). Flow rates and pH measurements are also monitored in real-time by EMWD. This very advanced monitoring system was not encountered at any other facility inspected during the audit and is considered a Best Management Practice. Should there be any questions regarding the contents of this inspection report, please contact Mr. Najib Saadeh by phone at (714) 667-2300 or by e-mail at nsaadeh@eecworld.com. Appendices: A. Site Photographs (only photographs of sampling/monitoring points were allowed) B. Direct User Discharge Permit No. 554 APPENDIX A SITE PHOTOGRAPHS Industrial User Inspection Report: Inland Empire Energy Center November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit A-1 EEC Photo 1 Categorical limits sampling point (Outfall 001) Photographed by Najib Saadeh Photo 2 Local limits sampling point (Outfall 002) Photographed by Najib Saadeh Photo 3 Wastewater samplers Photographed by Najib Saadeh Photo 4 Flow and pH monitoring system Photographed by Najib Saadeh APPENDIX B DIRECT USER DISCHARGE PERMIT NO. 554 Industrial User Inspection Report Santa Ana Watershed Project Authority Audit Industrial User: Inland Empire Utilities Agency (IEUA) Liquid Waste Hauler Discharge Station Industrial User Address: 16400 El Prado Road, Chino, California Industrial User Permit Number: SSP027 Industrial User Representatives: 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 Indirect/Direct User: Direct User Agency Area: IEUA Agency Representatives: 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 Inspection Date: August 23, 2012, Scheduled Inspection EEC/PSI Inspectors: Dr. John Parnell, Pretreatment Solutions Inc. Mr. Najib Saadeh, Environmental Engineering & Contracting, Inc. Report Date: November 1, 2012 1.0 SCOPE AND PURPOSE On behalf of the Orange County Sanitary District (OCSD), Environmental Engineering & Contracting (EEC) performed an inspection of selected industrial users discharging into the Inland Empire Brine Line (IEBL; formerly known as the Santa Ana Regional Interceptor, SARI). This inspection is part of an audit of the pretreatment programs of the Santa Ana Watershed Project Authority (SAWPA) and its member agencies. Industrial users were selectively inspected based on volume of wastewater discharged and/or industry type in order to evaluate the performance of the pretreatment programs. The inspections were scheduled ahead of time with agency representatives in charge. The agency representatives contacted the key personnel at the various industrial user facilities to confirm their availability and to describe the scope of the inspection and introduce the audit team. As part of the audit, all four liquid waste hauler (LWH) discharge stations within SAWPA’s service area were inspected. The current evaluation is one of a series of inspections of direct and indirect dischargers into the IEBL. Direct dischargers are typically close enough to construct a direct connection to the IEBL and produce enough waste to economically justify the connection cost. Indirect dischargers generate waste streams that are high in total dissolved solids and are not located close enough to the IEBL to make a direct connection. In general, the volume of wastewater discharged at LWH discharge stations varies. The Industrial User Inspection Report: IEUA Liquid Waste Hauler Discharge Station November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 2 EEC quantity of liquid waste discharged at these stations can vary from one or two truck loads per week to 100,000 gallons per day in some cases. Liquid waste from indirect dischargers is disposed of at LWH discharge stations using a commercial LWH permitted by SAWPA. On August 23, 2012, EEC completed a performance evaluation of the regulatory controls at the liquid- waste collection station located in Chino, California (Appendix A, Site Photographs, Photo 1). The collection station is permitted, operated, and managed by the Inland Empire Utilities Agency (IEUA). The inspection was conducted to evaluate whether SAWPA has developed and implemented sufficient measures to ensure that discharges through the station in Chino comply with the terms and conditions of all applicable agreements and regulations, including OCSD ordinances and 40 CFR 403. 1.1 General and Process Description The sole purpose of the IEUA LWH discharge station is to allow permitted LWHs within the SAWPA service area to discharge wastewater from indirect users into the IEBL. Access to the station is restricted to authorized LWH truck drivers only. Prior to entering the station, the LWH truck driver is required to place the “Door King Card” against a reader to open the gate. The station has two lanes leading to its entrance and has two separate gates. For each lane, a reader is placed to activate each gate. The station accommodates two trucks simultaneously. The station is under constant surveillance by a closed circuit television system including a camera monitoring system. Once inside the station, the driver connects the truck to the automated station using a 3-inch hose. The driver then opens the door to the keypad using his assigned key (Appendix A, Photo 2) and enters his assigned three-digit access code. The driver must enter a second code (four-digit personal identification number) assigned to each individual driver by his/her manager. The driver is then prompted to enter a three-digit code that identifies the valid liquid waste generator of the transported load. The driver must then enter the manifest number. Once the manifest number is entered, the driver is asked to verify that the hose is attached before beginning to discharge the load. Once the load is completely discharged, the driver is instructed to close the truck valve and to drain the hose. After two minutes, the valve to the IEBL shuts and the system flushes the line and re-sets for the next truck driver. The truck driver then places the manifest in the designated box (Appendix A, Photo 3) and exits the station. If the system detects a pH value outside of the permitted range of 6.0 to 12.0, or if it detects a dissolved sulfides concentration above 0.5 mg/L, the station shuts down. The security codes assigned to the driver are immediately rendered invalid until reactivated by an IEUA staff member. For each of the two station discharge lanes, the pH meter is calibrated weekly and the flow meter is calibrated annually. An ISCO automatic sampler is used at each discharge lane. Samples are collected from every truck and refrigerated (Appendix A, Photos 4 and 5). Samples are randomly analyzed. 1.2 Wastewater Sources The source of the wastewater is the wastewater transported by the LWHs and discharged at the station. Storm water is diverted away from the IEBL discharge point and directed into a storm water sewer (Appendix A, Photo 6). Industrial User Inspection Report: IEUA Liquid Waste Hauler Discharge Station November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 3 EEC 1.3 Facility Process Wastewater Treatment System The wastewater is not treated at the LWH discharge station. It flows by gravity through the IEBL and does not undergo any treatment until it reaches the OCSD water treatment facility. 1.4 Wastewater Discharge The same wastewater that is received at the LWH discharge station is discharged into the IEBL without any treatment. The connection to the IEBL from the discharge station is made via an 8-inch c lateral and is located at a manhole on El Prado Road in the City of Chino. 2.0 COMPLIANCE WITH FEDERAL CATEGORICAL STANDARDS The facility is not subject to any federal categorical standards. The facility is required to meet only the requirements specified in the permit issued by IEUA. 2.1 Compliance with Other Federal Pretreatment Requirements While the facility may not be subject to federal pretreatment requirements, nonetheless, limits that apply to dischargers with categorical standards also apply at this location. 2.2 Compliance with Local Limits and Actions by the Agency The facility's most recent wastewater discharge permit (Permit No. SSP027) was issued to IEUA by IEUA. As is the case with all four liquid waste collection stations within SAWPA’s service area, each member agency permits and monitors its own collection station. 3.0 SUMMARY OF FINDINGS 3.1 Overall, the IEUA liquid waste hauler discharge station at the City of Chino was observed to be clean and in good working order. 3.2 Among the four LWH discharge stations inspected, the logistics and technologies used to secure the IEUA LWH discharge station and monitor the discharged wastewater are considered state of the art. Compared to the other three LWH discharge stations, the IEUA station provides the highest level of protection to OCSD’s treatment system and to the IEBL. Should there be any questions regarding the contents of this inspection report, please contact Mr. Najib Saadeh by phone at (714) 667-2300 or by e-mail at nsaadeh@eecworld.com. Appendices: A. Site Photographs B. Wastewater Discharge Permit No. SSP027 APPENDIX A SITE PHOTOGRAPHS Industrial User Inspection Report: IEUA Liquid Waste Hauler Discharge Station November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit A-1 EEC Photo 1 Inland Empire Utilities Agency liquid waste hauler discharge station Photographed by Najib Saadeh Photo 2 Top: keypad Bottom: printed instructions on operating station Photographed by Najib Saadeh Photo 3 Box for depositing manifests Photographed by Najib Saadeh Photo 4 In-situ chemical oxidation samplers Photographed by Najib Saadeh Industrial User Inspection Report: IEUA Liquid Waste Hauler Discharge Station November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit A-2 EEC Photo 5 In-situ chemical oxidation samplers inside insulated enclosure Photographed by Najib Saadeh Photo 6 Storm sewer Photographed by Najib Saadeh APPENDIX B INDUSTRIAL WASTEWATER DISCHARGE PERMIT NO. SSP027 2 IEUA Trucked Wastewater Disposal Station Wastewater Discharge Permit No. SSP027 I. GENERAL CONDITIONS A. Abbreviations: CFR - Code of Federal Regulations IEUA - Inland Empire Utilities Agency NRWS - Non-Reclaimable Waste System OCSD - Orange County Sanitation Districts POTW - Publicly Owned Treatment Works SARI - Santa Ana Regional Interceptor SAWPA - Santa Ana Watershed Project Authority USEPA - United States Environmental Protection Agency B. Wastewater Discharges This permit authorizes the discharge of brine wastewater trucked from permitted Users (listed in Appendix D) within the IEUA service area. No domestic quality wastewater may be discharged through the outfall/sample locations identified in this permit. The discharge of any other type of wastewater will require prior approval from IEUA and SAWPA. Facility contact information for wastewater discharge issues: Authorized Officer: Thomas Love (909) 993-1730 Primary Contact Person: Craig Proctor (909) 993-1645 Secondary Contact Person Chris Berch (909) 993-1762 C. Duty to Comply The Permittee must comply with all conditions of this permit. Failure to comply with the requirements of this permit may be justification for administrative action or enforcement proceedings, including civil or criminal penalties, injunctive relief, and summary abatements. D. Notification of Change The Permittee, during the tenure of this permit, is required to notify IEUA and SAWPA in advance of any change in the status of the facility, including, but not limited to, ownership, authorized representative, operating responsibilities, business name, operating hours, and discharge duration. E. Duty to Mitigate The Permittee shall take all reasonable steps to minimize or correct any adverse impact to the POTW collecting and treating the permitted discharge and the environment resulting from noncompliance with this permit, including such accelerated or additional monitoring as necessary to determine the nature, source, and impact of the non-compliant discharge. Any discharge to the SARI in excess of the discharge limitations contained herein requires immediate corrective action by Permittee. 3 IEUA Trucked Wastewater Disposal Station Wastewater Discharge Permit No. SSP027 F. Property Rights The issuance of this permit does not convey property rights of any sort, any exclusive privileges, or authorize any activity that results in injury to private property or any invasion of personal rights, nor any violation of Federal, State, or local laws or regulations. G. Severability The provisions of this permit are severable and if any provision of this permit or the application of any provision of this permit to any circumstance is held invalid, the application of such provision to other circumstances and the remainder of this permit shall not be affected. H. Pretreatment Standards and Requirements The Permittee shall comply at all times with applicable Federal and State pretreatment standards and requirements as given in 40 CFR 403, "Federal Pretreatment Regulations for Existing and New Sources of Pollution," the current IEUA Ordinance, the current SAWPA Ordinance, and any subsequent amendments thereof, and this permit, whichever is more stringent. I. Permit Modification This permit is issued based on the information provided by the Permittee in their permit application. Any significant change in wastewater quantity or quality, by a threshold level as specified in this permit, if any, from the values reported in the permit application may constitute grounds for a permit modification. This permit may be modified for good cause including, but are not limited to, the following: 1) Incorporation of any new or revised Federal, State, or local pretreatment standards or requirements; 2) Alterations or additions to the Permittee’s operational processes, discharge volume, or discharge characters which are not covered in the effective permit; 3) Change in any condition requiring either a temporary or permanent reduction or elimination of the authorized discharge; 4) Respond to information indicating that the permitted discharge poses a threat to IEUA, SAWPA, and OCSD collection and treatment systems, personnel or the receiving waters; 5) Respond to violation of any terms or conditions of this permit; 6) Respond to misrepresentation or failure to disclose fully relevant facts in the permit application or in any required reporting; 7) Revise or grant a variance from such categorical standards pursuant to 40 CFR 403.13; 8) Correct typographical or other errors in the permit; 9) Reflect the transfer of facility ownership and/or operation to a new owner/operator; 10) Respond to a permit modification request from the Permittee, provided that such a request does not create a violation of any applicable requirements, standards, laws, rules or regulations. J. Permit Termination This permit may be terminated for the following reasons: 1) Falsifying statements, representations, records, reports, or other documents to IEUA, OCSD and/or SAWPA; 2) Tampering with, or knowingly rendering inaccurate, any monitoring device or sample collection method; 4 IEUA Trucked Wastewater Disposal Station Wastewater Discharge Permit No. SSP027 3) Refusing to allow timely access to the facility premises for the purpose of inspection and monitoring by IEUA, SAWPA, and OCSD representatives; 4) Refusing to provide records, reports, plans, or other documents required by IEUA, OCSD and/or SAWPA to determine permit terms, conditions or limitations, discharge compliance, or compliance with the current IEUA Ordinance and the SAWPA Ordinance; 5) Failing to meet effluent limitations; 6) Failing to make timely payment of all amounts owed to IEUA, SAWPA, and OCSD for user charges, non-compliance fees, or any other fees; 7) Failing to meet compliance schedules; 8) Failing to report significant changes in operations or wastewater constituents and characteristics; 9) Failing to comply with the terms and conditions of enforcement or permit suspension action or order; 10) Discharging wastewater to the SARI while its permit is under suspension; 11) Failing to submit oral notice or written report of the occurrence of bypass; 12) Discharging wastewater that causes pass through or interference with the SARI collection, treatment, or disposal system; 13) Discharging a slug load to the SARI; 14) Violation of any terms or conditions of this permit. K. Permit Amendment Any proposed permit revision, which results in a significant change in the wastewater quantity or quality from the information reported in the permit application for the existing permit, will require a new permit application to be submitted to IEUA, SAWPA and/or OCSD for approval. Approval must be first obtained prior to implementation of any intended revisions. L. Permit Transfers and the Requirement for a New Permit on Ownership Change Permit transfers are prohibited as specified in Section 422 of the IEUA Ordinance and Section 407.0 of the SAWPA Ordinance. A new permit is required if business ownership changes. The new owner shall notify IEUA and/or SAWPA of the ownership change immediately within twenty-four (24) hours, and submit a new permit application to IEUA and/or SAWPA within five (5) days of the change. M. Treatment Permits Required for Hazardous Wastes The Permittee shall not accept, treat, or dispose of wastes, determined to be hazardous according to 40 CFR 261 or Title 22, Division 4.5 of the California Code of Regulations, without a hazardous waste facilities permit as required by California Health and Safety Code, Section 25201. N. Annual Publication of Names of Dischargers in Significant Non-Compliance A list of permitted Users discharging to the SARI, which are determined to be in significant noncompliance, as defined by the IEUA Ordinance, SAWPA Ordinance, and USEPA General Pretreatment Regulation, will be published annually by IEUA in the largest daily newspaper within IEUA service area. O. Administrative Civil Penalties Any person, or groups of persons, who violates any portion of the IEUA Ordinance, SAWPA Ordinance, any permit condition, prohibition, or effluent limit, and any permit suspension or revocation order will be subject to administrative civil penalties. 5 IEUA Trucked Wastewater Disposal Station Wastewater Discharge Permit No. SSP027 The administrative civil penalties that may be assessed are not to exceed $2,000 for each day for failing or refusing to furnish technical or monitoring reports, $3,000 for each day for failing or refusing to timely comply with any compliance schedules, $5,000 for each day and each violation for discharging wastewater in violation of any waste discharge limit or permit condition, and $10 per gallon for discharging wastewater in violation of any permit suspension, permit revocation, cease and desist order or other orders, or prohibition issued or adopted by IEUA, SAWPA and OCSD. P. Judicial Civil Penalties Any person, or group of persons, who violates any conditions established in this permit will be subject to civil penalties including, but not limited to, a fine of up to $25,000 per day of violation. Any person who violates any provisions of the IEUA Ordinance, SAWPA Ordinance, permit conditions, prohibitions, or effluent limitations shall be liable civilly for a penalty pursuant to Section 508 of the IEUA Ordinance and Section 612 of the SAWPA Ordinance for each day in which such violation occurs. Q. Criminal Penalties Any person, who violates any provisions of the IEUA Ordinance, SAWPA Ordinance, or any permit conditions, discharge prohibitions or effluent limitations, is guilty of a misdemeanor, which upon conviction is punishable by a fine not to exceed $1,000, or imprisonment for not more than thirty (30) days, or both. Each day in which a violation occurs shall constitute a new and separate offense, and shall be subject to the penalties contained herein. R. Recovery of Costs Incurred In addition to civil and criminal liabilities, the Permittee and/or permitted Users violating any of the provisions established in this permit, or the IEUA Ordinance, SAWPA Ordinance, or causing damage to, or otherwise obstructing the SARI, or the OCSD sewerage system, shall be liable to IEUA, SAWPA and OCSD for any expense, loss, or damage caused by such violation. IEUA shall bill the Permittee and/or the permitted Users for all costs incurred by IEUA, SAWPA and OCSD for any repair, cleaning, or replacement necessary because of the violation. Refusal to pay the assessed costs shall constitute a separate violation. S. Inspection and Entry The Permittee shall allow any authorized representative of IEUA, SAWPA, OCSD, the California Water Quality Control Board and its Regional Boards, USEPA and other related agencies to: 1) Have immediate access without delay to any facility directly or indirectly connected to the SARI any time wastewater is being discharged, any time the Permittee’s facility is open or operating, and at any other reasonable times including, but not limited to, emergency situations; 2) Enter upon the Permittee's premises where a regulated facility or activity is located or conducted, or where records, as required by this permit, are kept; 3) Have access and copy any records that must be maintained by the Permittee under the provisions of this permit; 4) Inspect any facilities, equipment (including equipment used for monitoring and/or controlling discharge to the SARI), practices, or operations that are regulated and/or required under the provisions of this permit; 5) Sample or monitor, at any time, for purposes of assuring permit compliance, any substances, or parameters at any location; 6 IEUA Trucked Wastewater Disposal Station Wastewater Discharge Permit No. SSP027 6) Inspect any production, manufacturing, fabrication, or storage area where pollutants regulated under the provisions of this permit, could originate, be stored, or be discharged to the sewerage system, and 7) Study the industrial wastewater management facilities and wastewater discharges for the purpose of regulatory research. T. Equipment Requirements 1) The Permittee shall, at all times, properly operate and maintain a magnetic effluent flow meter, pH monitoring system, automatic sampler, closed circuit television camera monitoring system, and six- inch gate valve for each automated septage receiving system. The Permittee shall maintain the automated disposal station and any systems of treatment and control and related appurtenances to achieve compliance with the conditions of this permit. 2) The Permittee shall implement a plan for regular calibration of all monitoring devices used to ensure proper functioning of the monitoring equipment at the disposal station. Records of all calibrations conducted shall be kept on file for a period of three (3) years and provided to representatives of the IEUA, SAWPA, and OCSD upon request. 3) The Permittee shall implement a plan for regular cleaning and proper disposal of all solids, oil and grease, or any constituents not permitted for discharge to the SARI, accumulating at the automated disposal station. Records of all cleaning and material disposal shall be kept on file for a period of three (3) years and provided to representatives of IEUA, SAWPA, and OCSD upon request. 4) The Permittee shall prepare and maintain an up-to-date Operation and Maintenance Manual for the automated disposal station for ready reference and trouble-shooting by employees, IEUA, SAWPA and OCSD. This manual does not need to be submitted to IEUA, SAWPA and/or OCSD for approval. 5) Passive spill containment must be provided for containers, vessels, or tanks which contain cyanide, acids, bases, caustic substances, heavy metals of more than ten (10) pounds of metals in solution, or any toxic, poisonous, or hazardous material in solution in a significant quantity. 6) Any plans for changes in equipment or process must be submitted to IEUA, SAWPA and/or OCSD for approval prior to implementation. U. SARI Point of Connection Requirements 1) The Permittee’s point of connection (Appendix F) is made via an 8-inch VCP lateral to the SARI, located at manhole 4A-0450 (Station 280+20.00), on El Prado Road, in the City of Chino. 2) The Permittee shall, at all times, properly operate and maintain the point of connection to the SARI. 3) In the event the point of connection becomes damaged, the Permittee shall cease all operations at the automated disposal station and immediately notify IEUA, SAWPA, and/or OCSD. The Permittee shall follow the steps in the Contingency Plan attached in Appendix E and propose an alternate location acceptable to IEUA, SAWPA, and/or OCSD to receive brine wastewater from permitted Users. 4) The Permittee shall be liable for all costs required to clean and repair the point of connection to the SARI in the event the connection should become damaged, 7 IEUA Trucked Wastewater Disposal Station Wastewater Discharge Permit No. SSP027 II. WASTEWATER DISCHARGE LIMITS The effluent discharge limitations for this permit are listed in Appendix A, Wastewater Discharge Limits and Monitoring Requirements. Discharges exceeding the specified effluent limitations are prohibited without prior approval and permit amendments by IEUA, SAWPA and/or OCSD. The Permittee is authorized to allow permitted Users to discharge to the SARI and shall strictly comply, at all times, with the effluent limitations and the general prohibition standards as specified below: 1) Comply with all general prohibition standards in the IEUA Ordinance and SAWPA Ordinance (Appendix B). 2) Wastewater shall not be discharged to the SARI unless it has been effectively neutralized to a pH value between 6.0 and 12.0. 3) Wastes that result in encrustation or scale build up in the SARI shall not be discharged. 4) Petroleum products, non-biodegradable cutting oil, or products of mineral origin which form persistent water emulsions, cause interference, or pass-through at OCSD shall not be discharged to the SARI. 5) Any spill that cannot be treated adequately for sewer disposal must be disposed of at a legally approved disposal site. Under no circumstances shall process solution spills be discharged directly to the sewer. Waste haulers reports or manifests must be kept on file at the permitted user’s site address for four (4) years for any spills disposed of in this manner. 6) No hazardous wastes, as defined in 40 CFR Part 261 or in Title 22, Division 4.5 of the California Code of Regulations, shall be discharged to the SARI. 8 IEUA Trucked Wastewater Disposal Station Wastewater Discharge Permit No. SSP027 III. WASTEWATER MONITORING REQUIREMENTS A. General Requirements 1) The permitted Users shall monitor discharges to the SARI according to the methodology and frequency specified in Appendix A of this permit, "Discharge Limitations and Monitoring Requirements." 2) Sampling, sample preservation, sample storage, and sample analysis shall be performed in conformance with 40 CFR Part 136, Guidelines Establishing Test Procedures for the Analysis of Pollutants, or as prescribed by IEUA, SAWPA and OCSD. Any alternative test procedures must be approved by IEUA, SAWPA and OCSD before analysis and may require approval by the California Regional Water Quality Control Board and USEPA. 3) The permitted Users must immediately re-sample if a sample is not taken, preserved or stored properly. Samples not properly taken, preserved, or stored are not valid. 4) No attempt shall be made by the permitted Users, or any authorized representative of the permitted Users, to submit analysis results from any samples known to be invalid in order to demonstrate compliance with applicable wastewater discharge limitations. A willful attempt to do so shall subject the permitted Users to civil and/or criminal penalties stated in Section I, General Conditions, Part O, P, and Q of this permit. 5) Chemical or physical analysis for any parameter required by this permit must be performed by a laboratory certified by the State of California or approved by IEUA, SAWPA and/or OCSD. 6) IEUA, SAWPA and OCSD reserve the right to modify the monitoring and sampling requirements in this permit as needed. B. Sampling Location(s) Permitted Users of this facility have monitoring requirements in each of their respective permits. The Permittee shall operate an automatic sampler for each automated septage receiving system to collect grab samples from the discharge line on each individual tanker truck. The permitted Users are responsible for maintaining and cleaning the discharge line on each individual tanker truck to prevent any build-up of sediment or sludge, if any. Failure to do so does not invalidate sample test results. Safe and convenient access to the sampling location must be provided for representatives of IEUA, SAWPA and/or OCSD. If IEUA, SAWPA and/or OCSD determine that the sampling location is unsafe or difficult to access, the Permittee shall propose an alternate location acceptable to IEUA, SAWPA and/or OCSD. IEUA, SAWPA and/or OCSD representative may provide a split of any composite sample collected if sufficient sample volume is available. The representative may also provide a split of a concurrent or sequential grab sample. The split samples are to be deposited with a designated company representative, or with whoever is available if the designated representative is not available. C. Additional Monitoring Requirements 9 IEUA Trucked Wastewater Disposal Station Wastewater Discharge Permit No. SSP027 1) The Permittee is required to keep the following monitoring records for three (3) years for each of the samples collected in accordance with the requirements of this permit: a) Location where the sample was collected. b) Date and time the sample was collected. c) Preservation method used, if required. d) Type of sample container used for the sampling. e) Analysis method for the sample. f) Analysis results of the sample. g) Name and affiliation of the person conducting the sampling. h) Name of the laboratory performing the analysis. i) Name of the person performing the analysis. j) Signature of a responsible official of the laboratory that performed the analysis. 2) The Permittee shall keep a logbook of chemical or solution spills, and shall make it available for inspection by representatives of IEUA, SAWPA and OCSD. Any material that enters a spill containment area must be handled as a spill, including rainwater and any process wastewater from normal operations. All materials removed from the spill containment area, whether restricted or non- restricted must be included in the logbook. The logbook shall contain the following information relevant to the removal of all materials from the contaminated area: a) Date and time of the spill. b) Identity of the spilled material (an analysis is required if the spill is of unknown origin, to determine the type of treatment or remediation needed for proper disposal). c) Quantity or volume of the spill and the contaminated materials. d) Cause of the spill. e) Method of disposition of the spilled material, including transfer to an off-site waste treatment facility. f) Any corrective actions taken to prevent recurrence of the spill. 3) Each permitted User shall maintain waste hauler's reports or manifests must be kept on file for a period of at least four (4) years for any liquid, solids or hazardous wastes removed from the facility. These reports must be made available for inspection by representatives of IEUA, SAWPA and OCSD upon request. 10 IEUA Trucked Wastewater Disposal Station Wastewater Discharge Permit No. SSP027 IV. REPORTING REQUIREMENTS A. Periodic Reporting 1) Wastewater Monitoring Reports: a) The Permittee is not required to submit a wastewater monitoring report. The permitted Users discharging to the SARI shall submit wastewater monitoring report results periodically as required in each of their respective permits. 2) Wastewater Flow Reports: The Permittee shall measure and record the total wastewater discharged to the SARI. Any variation or adjustment to the reported flow must be requested for review within one hundred eighty (180) days from the submittal date of that reported flow. After the one-hundred-eighty-day period, the reported flow shall become final and any request for variation or adjustment will not be considered. B. Accidental Discharge Reports 1) In case of an accidental discharge, spill, bypass, or slug load to the SARI of any substance prohibited by this permit or the IEUA NRWS Ordinance, or SAWPA Ordinance. The Permittee shall notify IEUA, SAWPA, and OCSD immediately. During normal business hours (Monday - Friday, 7:00 A.M. - 5:00 P.M.), IEUA shall be notified by telephone at (909) 993-1600, SAWPA shall be notified by telephone at (951) 354-4220, and OCSD by telephone at (714) 593-7025. 2) The notification shall include the following: a) Location of the discharge b) Time and date of the discharge c) Duration of the discharge d) Type of waste discharged e) Concentration and volume of waste discharged f) Any actions taken to halt the discharge 3) Notification of accidental discharge in accordance with this section does not relieve the Permittee of other reporting actions required under Federal, State and local laws. C. Discharge Violation Reports and Automatic Re-sampling If the result of Permittee's wastewater analysis indicates a violation of the wastewater discharge requirements has occurred, Permittee shall take the following actions: 1) Inform IEUA and SAWPA of the violation(s) within twenty-four (24) hours of becoming aware of the violation. The Permittee is advised that failure to review a chemical analysis report upon receipt from its contracted laboratory shall not excuse the Permittee from this requirement. 2) Repeat the sampling and analysis for the constituents in violation and submit the results to IEUA, on behalf of SAWPA, within thirty (30) days of the discovery of the violation(s). D. Operations Upsets or Slug Load Discharge 11 IEUA Trucked Wastewater Disposal Station Wastewater Discharge Permit No. SSP027 1) The Permittee that experiences an operational upset or discharges a slug load to the SARI that places the Permittee in a temporary state of noncompliance with the provisions of this permit shall submit notification according to Section IV, Part B above. A slug load is defined as any discharge of a non- routine and episodic nature including, but not limited to, accidental spills and non-customary batch discharge. 2) The Permittee shall submit a written follow-up report of the upset to IEUA and/or SAWPA within five (5) days of the upset or slug load. The report shall specify the following: a) Description of the upset or slug load and the cause(s) thereof, and the impact upon the Permittee's compliance status; b) Duration of the noncompliance, including the exact time and date of noncompliance. If the noncompliance continues, provide the time and date by which compliance is reasonably expected to be achieved; and c) All actions taken, or to be taken, to reduce, eliminate, or prevent a recurrence of the upset or slug load or any related conditions of noncompliance. 3) In addition, the report must demonstrate that the facility was being operated in a prudent and workman-like manner at the time of the upset or slug load. 4) If operating upsets or slug load discharges occur at such intervals that IEUA, SAWPA and OCSD concludes that a Slug Control Plan (Plan) is required, the Permittee shall submit the Plan within thirty (30) days of notification of the requirement. The Plan shall include the following: a) Description of the discharge practices, including non-routine batch discharges, b) Description of the chemicals stored at the facility, c) Procedure to immediately notify IEUA, SAWPA and OCSD of slug loads, including any discharges that would violate a prohibition outlined in 40 CFR Part 403.5 (b), and d) Procedure to prevent adverse impact from the accidental spills, including inspection and maintenance of storage areas, safe handling and transfer of materials, proper loading and unloading operations, control of facility run-off, adequate training of workers, provision of spill containment structures or equipment, and establishment of measures and equipment for emergency response. 5) Each permitted User is required to notify IEUA and SAWPA, immediately upon the occurrence of an accidental discharge of substances, slug loads and/or spills that may enter the SARI. E. Hazardous Waste Discharge Reporting Requirements The Permittee shall notify IEUA, on behalf of SAWPA, in writing, of any discharge into the SARI of a substance that is designated as a hazardous waste according to 40 CFR Part 261. The Permittee shall complete and submit a Notification Report of the Discharge of Hazardous Wastes. Only hazardous wastes according to federal regulations need be considered for this reporting. A form for the report is available from IEUA. Notification must be sent to IEUA, SAWPA, OCSD, USEPA and the California State Department of Toxic Substances Control. A new notification report must be submitted if there is substantial change in the volume or characteristics of the hazardous waste present in the discharge. Notification to IEUA, SAWPA and OCSD of the discharge of hazardous wastes shall be made in advance. A new notification report shall also be required if there are new regulations that identify additional waste as hazardous. The new notification report must be submitted within 12 IEUA Trucked Wastewater Disposal Station Wastewater Discharge Permit No. SSP027 ninety (90) days of the effective date of the new regulations. As part of the notification report, the Permittee must also certify that it has a program in place to reduce the volume and toxicity of the hazardous wastes generated, to the degree the Permittee has determined to be economically practical. The notification report shall include the following information to the extent the information is readily known and available to the Permittee: a) Name of the hazardous waste, b) EPA hazardous waste number, c) Type of sewer discharge conducted (continuous, batch, or others), and d) Estimated mass discharges of the hazardous constituent over one month and twelve months. The notification is required to be made only once for each hazardous waste discharged. This notification does not apply to constituents already reported under the Self-Monitoring Report requirements, if required. F. Notification of Bypass 1) For anticipated bypass, the Permittee shall submit a written notice to the IEUA and SAWPA at least ten (10) days before the actual date of the bypass. 2) For an unanticipated bypass, the Permittee shall immediately notify IEUA and SAWPA by telephone as described in Section IV (B)(1) above, and submit a written notice within five (5) days. This notice shall contain the following information: a) A detailed description of the bypass, including the cause and duration; b) A statement whether the bypass has been corrected; and c) The actions being taken, or to be taken, to reduce, eliminate and/or prevent a recurrence of the bypass. G. Special Requirements 1) Pursuant to Section 103.0 of the SAWPA Ordinance, the General Manager of SAWPA shall administer, implement and enforce the provisions of the SAWPA Ordinance. Any powers granted or duties imposed upon the General Manager may be delegated by the General Manager to persons acting in the beneficial interest or employ of SAWPA, but shall remain the responsibility of the General Manager. In addition to the authority to prevent or eliminate discharges through enforcement of discharge limitations and prohibitions, the General Manager shall, after informal notice to the affected user, may immediately and effectively halt or prevent any discharge of pollutants into the SARI System or tributaries thereto, by any means available, including physical disconnection from the SARI System or tributaries thereto, whenever the wastewater discharge may endanger reasonably appears to present an imminent endangerment to the health or welfare of the community, the environment, or threatens to damage or interfere with the operation of the SARI System or tributaries thereto or the collection system and treatment facilities of IEUA or OCSD. Such discharges may be halted or prevented without regard to the compliance by the user with other provisions of this Ordinance. The Permittee is required to submit, and retain a copy on-site, a Contingency Plan that details the actions that will be taken in the event of an emergency or other event that causes IEUA, SAWPA or OCSD to shut down the SARI Line. Said Plan shall include, but is not limited to the following: 13 IEUA Trucked Wastewater Disposal Station Wastewater Discharge Permit No. SSP027 a) A list of names and telephone numbers of emergency contacts that can be reached 24 hours a day. The Permittee shall provide IEUA, on an annual basis (January), a list containing the names and phone numbers of contacts who can be reached 24 hours a day in the event of an emergency with the SARI discharge. b) A written plan that describes all available alternatives to discharging to the SARI Line, including on-site storage, hauling, ceasing the discharge, or directing all wastewater flows to IEUA. The Permittee shall develop such plan, update and provide to IEUA, on behalf of SAWPA, annually in January. 2) The permitted Users shall reimburse IEUA and SAWPA surcharge fee, if any, resulting from the permitted User’s discharge to the SARI. The permitted User shall reimburse IEUA and/or SAWPA for all costs incurred as a result of any enforcement action. 3) The permitted Users are required to notify IEUA or SAWPA of any planned process changes or other modifications which will alter the amount of or pollutant strength of any wastewater which is discharged to the SARI System, 30 days prior to the actual implementation of the changes. 4) IEUA may suspend service to any permitted User in order to stop an actual or threatened discharge which presents or may present an imminent or substantial endangerment to health or welfare of persons or the environment, or which causes interference to the NRWS, SARI, or OCSD’s POTW, or if the permitted Users have failed to obtain a valid wastewater discharge permit. 14 IEUA Trucked Wastewater Disposal Station Wastewater Discharge Permit No. SSP027 Appendix A DISCHARGE LIMITATIONS AND MONITORING REQUIREMENTS Parameter Limit Sample Type Frequency Foot Note Arsenic (As), Total 2.0 mg/l, Max for any 1 day Composite Not Required 1,2 Cadmium (Cd), Total 1.0 mg/l, Max for any 1 day Composite Not Required 1,2 Chromium (Cr), Total 2.0 mg/l, Max for any 1 day Composite Not Required 1,2 Copper (Cu), Total 3.0mg/l, Max for any 1 day Composite Not Required 1,2 Cyanide (CN), Total 5.0 mg/l, Max for any time Grab Not Required 1,2 Lead (Pb), Total 2.0 mg/l, Max for any 1 day Composite Not Required 1,2 Mercury (Hg), Total 0.03 mg/l, Max for any 1 day Composite Not Required 1,2 Nickel (Ni), Total 10.0 mg/l, Max for any 1 day Composite Not Required 1,2 Silver (Ag), Total 5.0 mg/l, Max for any 1 day Composite Not Required 1,2 Zinc (Zn), Total 10.0mg/l, Max at any time Composite Not Required 1,2 Oil & Grease (Non-Polar Origins) 100 mg/l, Max at any time Grab Not Required 1,2,3 pH 6.0 - 12.0, Standard pH Unit, Min/Max at any time Grab Not Required 1,2 Total Dissolved Solids (TDS) Not Specified Composite Not Required 1,2 Sulfides (Total) 5.0 mg/l, Max at any time Grab Not Required 1,2 Sulfides (Dissolved) 0.5 mg/l, Max at any time Grab Not Required 1,2 Total Suspended Solids (TSS) Surcharge Threshold Composite Not Required 1,2,4 Biological Oxygen Demand (BOD) Surcharge Threshold Composite Not Required 1,2,5 Polychlorinated Biphenyl's (PCB's) (*) 0.01 mg/l, Max at any time Grab Not Required 1,2,7 Pesticides (*) 0.01 mg/l, Max at any time Grab Not Required 1,2,7 Total Toxic Organics (TTO) (*) 0.58 mg/l, Max at any time Grab Not Required 1,2,6,7 Temperature 140 Fahrenheit (60 Centigrade), Max at any time Grab Not Required 1,2 Silica Not Specified Composite Not Required 1,2 Total Hardness Not Specified Composite Not Required 1,2 Volatile Suspended Solids (VSS) Not Specified Composite Not Required 1,2 Dissolved Organic Carbon (DOC) Not Specified Composite Not Required 1,2 Average Wastewater Discharge Maximum Wastewater Discharge 51,000 GPD (Estimated) 82,000 GPD (Estimated) Continuous Continuously (*) Refer to Appendix C for listed pollutants Footnote: 1. A composite sample shall be a collection of at least 12 discrete samples obtained at equal flow proportioned or time intervals for the duration of the discharge over a representative workday not to exceed a 24-hour period. A grab sample shall be an individual sample collected in less than 5 minutes. 2. Refer to Section III (A) for monitoring periods and submittal requirements. The semi-annual monitoring periods are July 1 through December 31 and January 1 through June 30 of each fiscal year. 3. Non-polar oil and grease must be analyzed using EPA Method 1664 – Silica Gel Treated n-Hexane Extractable Material (Method 1664 SGT-HEM). 15 IEUA Trucked Wastewater Disposal Station Wastewater Discharge Permit No. SSP027 4. A quality surcharge will be assessed for monthly Total Suspended Solids (TSS) discharge exceeding the level indicated in the IEUA Resolution which is adopted each July by the IEUA Board of Directors. The surcharge will be assessed based on an arithmetic mean of available analysis results obtained from all representative samples, composite or grab, taken during a calendar month. The arithmetic mean shall be used for surcharge assessment for the months in which sampling results are not available. The surcharge does not eliminate any liability for excessive discharge of TSS that may cause severe impact to wastewater quality in IEUA sewer system. IEUA issue surcharge invoice once for each quarterly monitoring period noted in (1) above. 5. A surcharge may be assessed for monthly Biological Oxygen Demand (BOD) discharge exceeding the level indicated in the IEUA Resolution which is adopted each July by the IEUA Board of Directors. The surcharge will be assessed based on an arithmetic mean of available analysis results obtained from all representative samples, composite or grab, taken during a calendar month. The arithmetic mean shall be used for surcharge assessment for the months in which sampling results are not available. The surcharge does not eliminate any liability for excessive discharge of BOD that may cause severe impact to wastewater quality in IEUA sewer system. IEUA issue surcharge invoice once for each quarterly monitoring period noted in (1) above. 6. Total toxic organics (TTO) shall mean the sum of concentration of each of the toxic organic compounds found in the discharge at a concentration greater than 0.010 mg/l. The toxic organic compounds that make up the TTO are listed in the Appendix C. Analysis for TTO shall be in conformance with EPA Test Methods or Standard Methods. IEUA may reduce the number of listed toxic organic compounds based on representative TTO sampling results obtained during the last 24 months. 7. Sampling for this parameter can be reduced if previous sampling date indicates satisfactory compliance with discharge requirement. 8. Grab sample can be used to assess ammonia loading. Analysis for ammonia shall be conducted in accordance with EPA Method 350 as specified in 40 CFR 136.3. 16 IEUA Trucked Wastewater Disposal Station Wastewater Discharge Permit No. SSP027 Appendix B IEUA Non-Reclaimable Wastewater Ordinance and SAWPA Ordinance The IEUA Non-Reclaimable Wastewater Ordinance (currently No. 62) is available from www.IEUA.org The SAWPA Ordinance (currently No. 5 with Amendment No. 1) is available from www.SAWPA.org 17 IEUA Trucked Wastewater Disposal Station Wastewater Discharge Permit No. SSP027 Appendix C Pollutants Identified as Polychlorinated Biphenyls, Pesticides, and Total Toxic Organics Appendix C-1 - Polychlorinated Biphenyls PCB-1016 PCB-1221 PCB-1232 PCB-1242 PCB-1248 PCB-1254 PCB-1260 Appendix C-2 – Pesticides Aldrin BHC BHC BHC BHC Chlordane 4,4'-DDD 4,4'-DDE 4,4'-DDT Dieldrin Endosulfan I Endosulfan II Endosulfan sulfate Eldrin Endrin aldehyde Heptachlor Heptachlor expoxide Toxaphene 18 IEUA Trucked Wastewater Disposal Station Wastewater Discharge Permit No. SSP027 Appendix C-3 - Total Toxic Organics acenaphthene acenaphthylene acrolein acrylonitrile aldrin anthracene BHC BHC BHC BHC benzene benzidine benzo(a)anthracene benzo(a)pyrene benzo(b)fluoranthene benzo(ghi)perylene benzo(k)fluoranthene benzyl butyl phthalate bis(2-chloroethoxy)methane bis(2-chloroethl)ether bis(2-chloroisopropyl)ether bis(2-ethylhexyl)phthalate bromodichloromethane bromoform bromomethane carbon tetrachloride chlordane chlorobenzene chloroethane chloroform chloromenthane chrysene di-n-butyl phthalate di-n-octyl phthalate dibenzo(a,h)anthracene dibromochloromethane dieldrin diethyl phthalate dimethyl phthalate endosulfan I endosulfan II endosulfan sulfate endrin endrin aldehyde ethylbenzene fluoranthene fluorene heptachlor heptachlor epoxide hexachlorobenzene hexachlorobutadiene hexachlorocyclopentadiene hexachloroethane indeno(1,2,3-cd)pyrene isophorone methylene chloride N-nitrosodi-n-propylamine N-nitrosodimethylamine N-nitrosodiphenylamine naphthalene nitrobenzene pentachlorophenol phenanthrene phenol pyrene tetrachloroethene toluene toxaphene trans-1,2-dichloroethene trichloroethene vinyl chloride 4-bromophenyl phenyl ether 4-chloro-3-methylphenol 2-chloroethyl vinyl ether 2-chloronapthalene 2-chlorophenol 4-chlorophenyl phenyl ether 4,4-DDD 4,4-DDE 4,4-DDT 1,2-dichlorobenzene 1,3-dichlorobenzene 1,4-dichlorobenzene 3,3-dichlorobenzidine 1,1-dichloroethane 1,2-dichloroethane 1,1-dichloroethene 2,4-dichlorophenol 1,2-dichloropropane 2,4-dimethylphenol 2,4-dinitrophenol 2,4-dinitrotoluene 2,6-dinitrotoluene 1,2-diphenylhydrazine 2-methyl-4,6-dinitrophenol 2-nitrophenol 4-nitrophenol 2,3,7,8-tetrachlorodibenzo-p- dioxin 1,1,2,2-tetrachloroethene 1,2,4-trichlorobenzene 1,1,1-trichloroethane 1,1,2-trichloroethane 2,4,6-trichlorophenol 19 IEUA Trucked Wastewater Disposal Station Wastewater Discharge Permit No. SSP027 Appendix D Permitted Generators and Truckers Hauling Wastewater to the Disposal Station INLAND EMPIRE UTILITIES AGENCY CONTINGENCY PLAN INDUSTRIAL WASTEWATER DISCHARGE PERMIT NO. SSP027 IEUA’s contingency plan is to maintain the operations of the SARI line and effectively serve the permitted Users which discharge to the IEUA Trucked Wastewater Disposal Station (Disposal Station). This contingency plan addresses the available alternatives to discharging to the Disposal Station and also contains a list of IEUA employees to contact in case of an emergency. IEUA shall update and submit this contingency plan annually in January to SAWPA. Emergency Contacts: In case of emergency, the following IEUA employees shall be contacted in the following order. The contacts below can be reached 24 hours a day in the event that there is an emergency with the discharge to the SARI Line. IEUA Employee Primary Contact Phone Number Secondary Contact Phone Number Craig Proctor (909) 993-1645 (909) 573-5709 Martyn Draper (909) 993-1643 (909) 631-3708 Collections On-Call (951) 675-1131 -- Jann Ritchie (909) 732-2240 -- Randy Lee (909) 993-1810 (909) 472-1722 Alternatives to Discharging to Disposal Station: In the event that IEUA, SAWPA, and/or OCSD shuts down the SARI Line or the connection to the SARI Line is damaged, the following alternatives shall be used to ensure that the permitted Users of the Disposal Station can continue to dispose of wastewater. 1) Within an hour of notice regarding a shutdown of the SARI line, the Permittee shall inform all generators and haulers of wastewater (Appendix D) to cease transportation of wastewater to the Disposal Station. 2) IEUA shall provide the generators and haulers alternative disposal sites for their wastewater. 3) IEUA shall inform all generators and haulers of the timeline for the resumption of disposal services to the SARI Line or the Disposal Station within 24 hours of the line becoming operational again. 20 IEUA Trucked Wastewater Disposal Station Wastewater Discharge Permit No. SSP027 Appendix E IEUA Contingency Plan for Disposal Station INLAND EMPIRE UTILITIES AGENCY CONTINGENCY PLAN INDUSTRIAL WASTEWATER DISCHARGE PERMIT NO. SSP027 IEUA’s contingency plan is to maintain the operations of the SARI line and effectively serve the permitted Users which discharge to the IEUA Trucked Wastewater Disposal Station (Disposal Station). This contingency plan addresses the available alternatives to discharging to the Disposal Station and also contains a list of IEUA employees to contact in case of an emergency. IEUA shall update and submit this contingency plan annually in January to SAWPA. Emergency Contacts: In case of emergency, the following IEUA employees shall be contacted in the following order. The contacts below can be reached 24 hours a day in the event that there is an emergency with the discharge to the SARI Line. IEUA Employee Primary Contact Phone Number Secondary Contact Phone Number Craig Proctor (909) 993-1645 (909) 573-5709 Martyn Draper (909) 993-1643 (909) 631-3708 Collections On-Call (951) 675-1131 -- Jann Ritchie (909) 732-2240 -- Randy Lee (909) 993-1810 (909) 472-1722 Alternatives to Discharging to Disposal Station: In the event that IEUA, SAWPA, and/or OCSD shuts down the SARI Line or the connection to the SARI Line is damaged, the following alternatives shall be used to ensure that the permitted Users of the Disposal Station can continue to dispose of wastewater. 1) Within an hour of notice regarding a shutdown of the SARI line, the Permittee shall inform all generators and haulers of wastewater (Appendix D) to cease transportation of wastewater to the Disposal Station. 2) IEUA shall provide the generators and haulers alternative disposal sites for their wastewater. 3) IEUA shall inform all generators and haulers of the timeline for the resumption of disposal services to the SARI Line or the Disposal Station within 24 hours of the line becoming operational again. 21 IEUA Trucked Wastewater Disposal Station Wastewater Discharge Permit No. SSP027 Appendix F Permittee Connection to SARI Industrial User Inspection Report Santa Ana Watershed Project Authority Audit Industrial User: International Rectifier Industrial User Address: 41915 Business Park Drive, Temecula, CA 92590 Industrial User Permit Number: EMWD No. 552 WMMD Indirect User Discharge Permit No. DS-012 Industrial User Representatives: Mr. Pankaj Garg, Environmental, Health and Safety Manager Mr. Alan Follis, Technical/Outsourced Services Manager Mr. Ignacio Verduzco, Technician Indirect/Direct User: Direct User Agency Area: Eastern Municipal Water District Agency Representatives: Mr. Gregg Murray, EMWD Source Control Manager Mr. Dennis Martz, EWMD Senior Source Control Inspector Inspection Date: August 30, 2012, Scheduled Inspection EEC/PSI Inspectors: Dr. John R. Parnell, Pretreatment Solutions, Inc. Mr. Najib Saadeh, Environmental Engineering & Contracting, Inc. Report Date: November 1, 2012 1.0 SCOPE AND PURPOSE On behalf of the Orange County Sanitary District (OCSD), Environmental Engineering & Contracting (EEC) performed an inspection of selected industrial users discharging into the Inland Empire Brine Line (IEBL; formerly known as the Santa Ana Regional Interceptor, SARI). This inspection is part of an audit of the pretreatment programs of the Santa Ana Watershed Project Authority (SAWPA) and its member agencies. To evaluate the performance of the pretreatment programs, industrial users were selectively inspected based on volume of wastewater discharged and/or industry type. On August 30, 2012, Environmental Engineering & Contracting, Inc. (EEC) completed a performance evaluation of the regulatory controls at the International Rectifier (IR) facility located at 41915 Business Park Drive, Temecula, CA 92590. The facility is permitted by the Eastern Municipal Water District (EWMD). The inspection was conducted to evaluate whether EWMD has developed and implemented sufficient measures to ensure that discharges from the IR facility into the IEBL comply with the terms and conditions of all applicable agreements and regulations, including OCSD ordinance and 40 CFR 403. Industrial User Inspection Report: International Rectifier November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 2 EEC 1.1 General and Process Description The IR facility began operating in 1987. The facility uses complex acid- and solvent-etching techniques to insert a series of various types of high-performance analog-, digital-, and mixed-signal integrated circuits onto precut silicon wafers. Acid etching involves the use of hydrofluoric, sulfuric, hydrochloric, and nitric and phosphoric acids. Solvent etching involves the use of xylene as well as an ethyl lactate base solvent. The etching process is performed by a wide range of different etching machines located in ultra clean rooms within the facility. Visitors entering the ultra-clean rooms must wear full-body overalls, head covers, and face masks. Entry to the ultra-clean rooms was deemed unnecessary because no wastewater connections could be traced back to the rooms. The facility operates 24 hours a day, 7 days per week and employs more than 600 workers who work in five alternate shifts. The silicon wafers containing the integrated circuits are then sent to another IR facility in Mexico where the wafers are cut into smaller parts. The smaller integrated circuits are then manufactured into finished products by the addition of protective covers and contact pins. The finished products are used in multiple applications including the automotive, commercial and industrial appliance, computer, and cellular telephone industries. 1.2 Wastewater Sources Wastewater is produced from a variety of washing and rinsing processes performed by the acid and solvent etching machines. The etching machines use ultra-pure water to clean and rinse the silicon wafers. The ultra-pure water is produced from potable water by extensive reverse osmosis and deionization processes. Wastewater streams from the reject reverse osmosis and deionization processes are considered process wastewaters because they are an integral part of the process required for the manufacturing of integrated circuits. 1.3 Facility Process Wastewater Treatment System Wastewater from the etchers is separated into wastewater streams of low and high fluoride concentration. Low concentration fluoride wastewater is collected in outside Tank T- 14, whereas high concentration fluoride wastewater is collected in outside Tank T-13. The content of Tank T-13 is sent off- site for treatment and disposal. Solvent wastes are also discharged to a separate tank and hauled off- site by a hazardous waste tanker truck. Wastewater from Tank T-14 is first processed by the addition of potassium hydroxide in a series of tanks in the neutralization system. A pH regulation system recycles acid waste through the neutralization system until the correct pH is attained. Neutralized wastewater is then circulated through one of two ultra reverse osmosis systems to reclaim some of the water for reuse in the etchers. An estimated 1.8 gallons of water pass through the plant for every gallon of water that is supplied by the potable water system. This results in a water recycling rate of 80%. Reject wastewater from the ultra reverse osmosis system is mixed in Tank T-9 with process wastewater from the neutralization system, cooling tower reverse osmosis reject and the deionization regenerant. Neutralization system wastewater can also be discharged to Tank T-10 for extra volume. Tanks T-9 and T-10 are sampled at Sample Points 003 and 004, respectively. After final pH control at Tanks T-9 and Industrial User Inspection Report: International Rectifier November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 3 EEC T-10, the wastewater passes through a Vibratory Shear Enhanced Process (VSEP) unit where additional water is reclaimed for recirculation to the etchers. Final reject from the VSEP is mixed in Tank T-21 with other nonprocess wastewater before being discharged through the tanker-truck pickup point (Sample Point 002) for disposal at EMWD’s liquid- waste hauler (LWH) discharge station. Sample Point 005 is located between the VSEP system and Tank T-21 and is used to monitor wastewater discharge for compliance with the applicable categorical standards. The maintenance of the ultra-pure water producing systems (reverse osmosis and deionization) and the operation of the wastewater treatment system are subcontracted by IR to Kurida America Inc. 1.4 Wastewater Discharge The reject reverse osmosis wastewater in Tank T-21 and other wastewater streams from Tanks T-9 and T-10 are discharged through a tanker truck coupling. A supervisor from the HTS hauling company is stationed permanently on site to organize the collection and transport of the wastewater to the EMWD LWH collection station. 2.0 COMPLIANCE WITH FEDERAL CATEGORICAL STANDARDS This facility is correctly categorized as a categorical industrial user subject to 40 CFR Part 469 (Electrical and Electronic Components Point Source Category), Subpart A, (Semiconductor Category) Paragraph 469.18 (Pretreatment Standards for New Sources; Existing Source for this category is prior to August 24, 1982). 2.1 Compliance with Other Federal Pretreatment Requirements The facility is a categorical industrial user subject to a federal categorical standard and is therefore a significant industrial user. The facility must comply with pretreatment requirements in 40 CFR 403, including, but not limited to, national prohibitions in 40 CFR 403.5 and reporting requirements in 40 CFR 403.12. 2.2 Compliance with Local Limits and Actions by the Agency The IR facility was issued permit no. 522 by EMWD. Permit no. 522 has an effective date of October 1, 2011, and an expiration date of September 30, 2013. Prior to the issuance of the permit by EMWD, the IR facility was issued Permit No. DS-012 by the Western Municipal Water District (WMWD). Permit no. DS-012 has an effective date of July 27, 2011, and an expiration date of July 26, 2013. Wastewater from this facility was originally collected by tanker trucks and delivered to the WMWD LWH disposal station. Currently, the wastewater is discharged at the EMWD LWH disposal station. The IR facility retains both permits to ensure that disposal of its wastewater could still occur if any one of the two disposal stations were out of service for any length of time. Industrial User Inspection Report: International Rectifier November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 4 EEC The permit developed by EMWD requires IR to collect a composite sample quarterly from sample points 002, 003 and 004. Sample composition is determined based on data from the facility on the percentage discharge to each point within the 24-hour period covered by the sample collection event. Sampling for the total toxic organics (TTO) requirement in the federal regulation is conducted twice per year from sample point 005 as previously negotiated with OCSD. EMWD conducts all of the sampling and the permittee is not required to submit compliance reports. Inspections of this facility are performed on a quarterly basis by EMWD. EMWD also performs quarterly compliance sampling. The current indirect discharge permit issued by EMWD was approved for structure and content by SAWPA and OCSD. The indirect discharge to the IEBL and subsequently to OCSD’s Wastewater Treatment Plant originates from the permittee’s categorical industrial processes. Therefore, the permit must contain both the categorical limits, which apply at the end of process, and OCSD’s local limits, which apply at the end of pipe discharge point. In this instance, the Sample Point 005 is the end of process sample point and the Sample Points 002, 003, and 004 are composited as the end of pipe sample points. 3.0 SUMMARY OF FINDINGS 3.1 The facility was inspected and found to be in excellent operating condition. No immediate problems were identified. 3.2 All pipes throughout the facility are clearly labeled. The labels indicate the pipe content and the flow direction. 3.3 The water treatment system was found to be in good operating condition. No immediate problems were identified. 3.4 The EMWD permit correctly identifies the difference between OCSD’s TTO local limit (which only requires an EPA 624 analysis) and the federal pretreatment standard for TTO in 40 CFR 469.18 (which requires both a 624 and 625 analysis). The WMWD permit does not distinguish between these two limits and incorrectly compares the OCSD limit to the 40 CFR 469.18 limit by using the most stringent limit for the single analysis. 3.5 EMWD with assistance from OCSD diligently worked with the IR facility personnel to modify the discharge system so that the federal TTO limit is sampled at the correct location (Sample Point 005). There is no evidence that WMWD exerted the same level of diligence and sought OCSD’s assistance in making the same determination. As a result, the sample points referenced in the WMWD permit are no longer valid. 3.6 The WMWD permit briefly describes the etching processes performed by the permittee as part of the classification of the industrial user. The EMWD permit simply refers to the permittee as “performing processes subject to 40 CFR 469,” which is inadequate in the opinion of the audit team. Industrial User Inspection Report: International Rectifier November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 5 EEC 3.7 Wastewater is handled appropriately in all areas of the facility, and the IR facility is implementing best management practices wherever possible. 3.8 The facility has an ongoing effort to conserve water by processing and recycling water at every possible point in the system. 3.9 Taking photographs is not allowed inside the facility for security reasons. Should there be any questions regarding the contents of this inspection report, please contact Mr. Najib Saadeh by phone at (714) 667-2300 or by e-mail at nsaadeh@eecworld.com. Appendices: A. EMWD Permit No 552 B. WMMD Indirect User Discharge Permit No. DS-012 APPENDIX A EMWD PERMIT NO. 522 APPENDIX B WMWD INDIRECT USER DISCHARGE PERMIT NO. DS-012 Industrial User Inspection Report Santa Ana Watershed Project Authority Audit Industrial User: Metal Container Corporation Industrial User Address: 10980 Inland Avenue, Mira Loma, CA 91752 Industrial User Permit Number: SARI-EMS-101 332431 Industrial User Representatives: Mr. Killam Johnson, EHS Manager II Mr. Diego Genera, Operations Manager Mr. Jason Holtgrewe, Engineering Manager Mr. Wayne Cook, Treatment System Operator Indirect/Direct User: Direct User Agency Area: Jurupa Community Services District Agency Representatives: Mr. Dan Ducasse, JCSD Industrial Wastewater Inspector Ms. Marce Billings, JCSD Source Control Supervisor Mr. John Jackson, JCSD Industrial Wastewater Inspector Mr. Benjamin Burgett, G & G Environmental Compliance Inc., Consultants to Western Municipal Water District Inspection Date: August 27, 2012, Scheduled Inspection EEC/PSI Inspectors: Dr. John R. Parnell, Pretreatment Solutions, Inc. Mr. Najib Saadeh, Environmental Engineering & Contracting, Inc. Report Date: November 1, 2012 1.0 SCOPE AND PURPOSE On behalf of the Orange County Sanitary District (OCSD), Environmental Engineering & Contracting (EEC) performed an inspection of selected industrial users discharging into the Inland Empire Brine Line (IEBL; formerly known as the Santa Ana Regional Interceptor, SARI). This inspection is part of an audit of the pretreatment programs of the Santa Ana Watershed Project Authority (SAWPA) and its member agencies. To evaluate the performance of the pretreatment programs, industrial users were selectively inspected based on volume of wastewater discharged and/or industry type in order to evaluate the performance of the pretreatment programs. The current evaluation is one of a series of inspections of direct and indirect dischargers into the IEBL. Direct dischargers are typically close enough to construct a direct connection to the IEBL and produce enough waste to economically justify the connection cost. Indirect dischargers generate waste streams that are high in total dissolved solids and are not located close enough to the IEBL to make a direct connection. In general, the volume of wastewater discharged at liquid waste hauler (LWH) discharge stations varies. The quantity of liquid waste discharged at these stations can vary from one or two truckloads per week to 100,000 gallons per day in some cases. Liquid waste from indirect dischargers is disposed of at discharge stations using a commercial LWH permitted by SAWPA. Industrial User Inspection Report: Metal Container Corporation November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 2 EEC On August 27, 2012, EEC completed a performance evaluation of the regulatory controls at the Metal Container Corporation facility located at 10980 Inland Avenue, Mira Loma, CA 91752. The facility is permitted, inspected and monitored directly by Jurupa Community Services District (JCSD). JCSD issued Permit No. SARI-EMS-101. The permit effective date is January 1, 2012, and its expiration date is December 31, 2014. The inspection was conducted to evaluate whether the Metal Container Corporation has developed and implemented sufficient measures to ensure that discharges into the IEBL comply with the terms and conditions of all applicable agreements and regulations, including OCSD ordinances and 40 CFR 403. 1.1 General and Process Description Metal Container Corporation is one of the Anheuser-Busch Companies that manufactures 10 to 12 million aluminum cans from sheet aluminum for all types of beer and other drinks. The facility began production in 1995 and has discharged into the IEBL since that year. The production of cans entails a series of processes: First, “cups” are produced directly from aluminum sheets by a series of stamping machines. The cups are then washed in a series of three six-stage counter current washers. Drawing machines are used to draw out the cups to form the complete can body with an open top. Various colored logos are then applied to the can bodies by printing machines. Finished can bodies are stacked on pallets and transported to other locations where the can top is added after cans are filled. The facility is continuously operational with 177 employees working 12-hour shifts. 1.2 Wastewater Sources All potable water used in the manufacturing of cans is purified using a reverse osmosis (RO) system or a deionization (DI) process. The primary source of wastewater is the washing of the cups by the three industrial washing machines. Other wastewater sources originate from the cupping and drawing processes (through an oil splitter unit), RO reject water, DI regenerant water, cooling tower blowdown, boiler blowdown, and a small amount of oily wash-down water. All these wastewater sources are considered a part of the integral process and are not considered “dilute” with respect to categorical standards. The facility uses approximately 200,000 gallons of water per day. 1.3 Facility Process Wastewater Treatment System The wastewater treatment system consists of three large equalization tanks feeding a four-stage reactor. In the first stage, sulfuric acid is added to lower the pH to 2.0 and to break the chemical emulsion. Breaking the emulsion allows the oil to rise to the surface. The second stage consists of a oil skimming with a rope mop. In stage three, lime is added to raise the pH to 8.0 for the cationic polymer coagulation. In the fourth stage, coagulated wastewater enters a clarifier for the separation of solids. The solids are processed in a filter press. Sludge from the filter press is transported off-site to a nonhazardous landfill. The filtrate from the press is returned to the clarifier. The pH of the effluent from the clarifier is continuously monitored. A total facility flow sample point containing both process and all other domestic waste is located in a monitoring manhole on Inland Industrial User Inspection Report: Metal Container Corporation November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 3 EEC Avenue utilizing a Parshall flume and a bubbler type flow meter (Appendix A, Sampling Point, Photos 1 and 2). Site photographs were not taken because photography is prohibited inside the facility. 1.4 Wastewater Discharge Process and domestic wastewater from the facility is directly discharged into the IEBL through a 10-inch sewer lateral, located at 10980 Inland Avenue, that discharges into the JCSD sewer system. The JCSD sewer system serves as a tributary to the IEBL. 2.0 COMPLIANCE WITH FEDERAL CATEGORICAL STANDARDS This facility is correctly categorized as a categorical industrial user subject to 40 CFR 465 (Coil Coating Point Source Category), Subpart D, (Can-making Subcategory) Paragraph 465.45 (Pretreatment Standards for New Sources; existing source for this category is prior to February 10, 1983). Pretreatment standards are production-based mass limits and are based on the wastewater discharge from the manufacture of 1 million cans. The requirement for production per 1 million cans manufactured is contained in 40 CFR 465.41, Subpart D, BPT Effluent Limitations. 2.1 Compliance with Other Federal Pretreatment Requirements The facility is a categorical industrial user and is therefore a significant industrial user because it is subject to a federal categorical standard. Metal Container Corporation must comply with pretreatment requirements in 40 CFR 403, including but not limited to, national prohibitions in 40 CFR 403.5 and reporting requirements in 40 CFR 403.12. 2.2 Compliance with Local Limits and Actions by the Agency The permit contains the OCSD-required local limits and the categorical standards found in 40 CFR 465.45. Some parameters are required to be analyzed quarterly, some semi-annually and others annually. No violations by the facility have ever been recorded. 3.0 SUMMARY OF FINDINGS 3.1 The facility was inspected and found to be in clean operating condition and no immediate problems were identified. 3.2 The water treatment system was found to be in good operating condition and no immediate problems were identified. 3.3 Metal Container Corporation is correctly identified as a categorical industrial user subject to 40 CFR 465.45 categorical standards, which are set correctly. There are no other categorical operations. 3.4 Part 2A of the permit indicates that sampling must occur at various intervals but does not indicate that two sample points must be used. Industrial User Inspection Report: Metal Container Corporation November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 4 EEC 3.5 The permit does not specify that the industry must provide production data for the number of cans manufactured on the sampling day although it is included in the monitoring report in Attachment 5. Mass emission rate is calculated based on an estimate rather that an actual production number. This is unacceptable in most cases. 3.6 Permit contains a few errors and omissions. The permit was not signed by the issuing agency (JCSD) and is missing language in the first paragraph of page 2. 3.7 The permit prohibits the discharge of any wastewater with a pH lower that 5.0, whereas the OCSD’s pH limit is 6.0. 3.8 Under the general requirements for flow measurement, the permit requires that the selected device must be capable of measuring flow with a maximum deviation of less than 10%. This represents a lower accuracy than the 5% deviation required by OCSD. Flow meters with accuracy of 5% are widely available and should be calibrated and operated according to manufacturer’s instructions. 3.9 A technician from Douglas Environmental Group collects samples and submits them to TestAmerica for analysis. Reportedly, Douglas Environmental Group is performing the required calibration of the flow meter, but no documentation of such was obtained. 3.10 Monitoring sheets (permit Attachments 4 and 5) indicate that different locations must be used for federal and local limits, but this is not made clear in the body of the permit. 3.11 Federal law [40 CFR 403.12(e) and (h)] requires a minimum of semiannual monitoring for any limits included in the permit. Annual sampling parameters should be increased to semiannual in the monitoring table. 3.12 No specific best management practices were noted. 3.13 No record of any enforcement was observed in the past year. The discharge was apparently in compliance with all permit limits and requirements. 3.14 The permit does not clearly describe two sampling locations. Part 1E of the permit identifies two sampling locations but only describes the outfall (sewer manhole for the end of pipe local limits) as Outfall 001 in Part 1A. The Table of Pollutants in the permit refers to one sampling point (Outfall 001). The clarifier sampling location is mentioned in Section 1.E. of the permit but it is not included in the table heading. The same section of the permit states that samples should be collected at either the clarifier or the manhole. The permit should be corrected to clearly indicate the sampling point for the categorical limits and the sampling point for the local limits. Also, the Discharge Limitation Table in Part 1G only notes limits from Outfall 001. Federal limits do not apply at Outfall 001 without a combined waste-stream formula conversion. Further investigation should be conducted to verify that domestic and industrial wastewater streams are not comingled prior to discharge into the IEBL. Industrial User Inspection Report: Metal Container Corporation November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 5 EEC Should there be any questions regarding the contents of this inspection report, please contact Mr. Najib Saadeh by phone at (714) 667-2300 or by e-mail at nsaadeh@eecworld.com. Appendices: A. Site Photograph B. Direct User Discharge Permit No. SARI-EMS-101 332431 APPENDIX A SITE PHOTOGRAPHS Industrial User Inspection Report: Metal Container Corporation November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit A-1 EEC Photo 1 Manhole on Inland Avenue Photographed by Najib Saadeh Photo 2 Bubbler flow meter Photographed by Najib Saadeh APPENDIX B DIRECT USER DISCHARGE PERMIT NO. SARI-EMS-101 332431 Industrial User Inspection Report Santa Ana Watershed Project Authority Audit Industrial User: Mountainview Generating Station (Edison International) Industrial User Address: 2492 West San Bernardino Ave., Redlands, CA 92374 Industrial User Permit Number: 4E-00-S35 Industrial User Representative: Ms. Kimberly Brown, Safety & Environmental Specialist Indirect/Direct User: Direct User Agency Area: San Bernardino Valley Municipal Water District Agency Representative: Mr. Benjamin Burgett, G&G Consultants to SBVMWD Inspection Date: September 10, 2012, Scheduled Inspection EEC/PSI Inspector: Mr. Najib Saadeh, Environmental Engineering & Contracting, Inc. Report Date: November 1, 2012 1.0 SCOPE AND PURPOSE On behalf of the Orange County Sanitary District (OCSD), Environmental Engineering & Contracting (EEC) performed an inspection of selected industrial users discharging into the Inland Empire Brine Line (IEBL; formerly known as the Santa Ana Regional Interceptor, SARI). This inspection is part of an audit of the pretreatment programs of the Santa Ana Watershed Project Authority (SAWPA) and its member agencies. To evaluate the performance of the pretreatment programs, industrial users were selectively inspected based on volume of wastewater discharged and/or industry type. The inspections were scheduled ahead of time with agency representatives in charge. The agency representatives contacted the key personnel at the various facilities to confirm their availability, describe the scope of the inspection and introduce the audit team. As part of the audit, all four liquid waste hauler (LWH) discharge stations within SAWPA’s service area were inspected. The current evaluation is one of a series of inspections of direct and indirect dischargers into the IEBL. Direct dischargers are typically close enough to construct a direct connection to the IEBL and produce enough waste to economically justify the connection cost. Indirect dischargers generate waste streams that are high in total dissolved solids and are not located close enough to the IEBL to make a direct connection. In general, the volume of wastewater discharged at LWH discharge stations varies. The quantity of liquid waste discharged at these stations can vary from one or two truckloads per week to 100,000 gallons per day in some cases. Liquid waste from indirect dischargers is disposed of at discharge stations using a permitted commercial LWH permitted by SAWPA. On September 10, 2012, EEC completed a performance evaluation of the regulatory controls at the Mountainview Generating Station (MVGS) in Redlands, California. MVGS is owned and operated by Edison International. The facility is permitted by the San Bernardino Valley Municipal Water District (SBVMWD). The inspection was conducted to evaluate whether SBVWMD has developed and implemented sufficient measures to ensure that discharges from the MVGS facility comply with the Industrial User Inspection Report: Mountainview Generating Station November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 2 EEC terms and conditions of all applicable agreements and regulations, including OCSD ordinances and 40 CFR 403. Site photographs are not provided because photographing the facility is prohibited for security reasons. 1.1 General and Process Description The MVGS facility uses General Electric frame 7FA gas turbines and D-11 steam turbines to produce electricity in a combined cycle power plant. Operation at the plant began in January 2006. In cycle one, air is mixed with natural gas and ignited in four combustion turbines that increases the temperature, velocity, and volume of the gases moving through the unit. The gas flow is then directed through nozzles and across turbine blades that spin and thereby generate electricity. In single-cycle plants, heat from this process is then vented up the exhaust stack. In cycle two, MVGS’s combined-cycle design recovers heat by directing it from cycle one to a boiler that produces steam to turn the steam turbines, generating extra electricity from the same amount of natural gas. In this process, two GE F-Class gas turbines are combined with one steam turbine to form a three-turbine train capable of generating 527 megawatts (MW) of power. The plant has two such trains and a total generating capacity of 1,054 MW. MVGS uses three sources of water primarily for cooling tower makeup. Raw water from the mid-aquifer wells (2,296 gallons per minute) and reclaimed water from the City of Redlands (2,297 gallons per minute) are stored in Raw Water Tank 1 and used as makeup water in the cooling towers. In addition, raw water from Deep Wells 1 and 2 is collected in Raw Water Tank V911 (70,000 gallons). Sodium hypochlorite (NaOCl) is added and the water then is filtered and used as cooling tower makeup water after the addition of an antiscalant. 1.2 Wastewater Sources Wastewater from the MVGS consists of reject stream from reverse osmosis, direct and treated blowdown from the cooling towers, and wastewater streams from the neutralization system. All turbine wash water is collected and disposed of off-site. 1.3 Facility Process Wastewater Treatment System The wastewater treatment plant at MVGS recovers 85% of its wastewater. Blowdown from the cooling towers and backwash from the water treatment plant are first treated in a combined reactor-clarifier. The effluent from the clarifier is then treated using gravity filters, weak-acid cation exchangers, and a high-efficiency reverse osmosis (HERO) system. The permeate from the HERO system is returned to the cooling towers and the reject is discharged into the IEBL. 1.4 Wastewater Discharge MVGS is not permitted to discharge any wastewater to the IEBL other than the reverse osmosis reject stream, treated cooling tower blowdown, direct cooling tower blowdown, and pH neutralization system wastewater. Industrial User Inspection Report: Mountainview Generating Station November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 3 EEC 2.0 COMPLIANCE WITH FEDERAL CATEGORICAL STANDARDS MVGS is classified as a categorical industrial user pursuant to 40 CFR 423.17 (Pretreatment Standards for New Sources). Categorical pollutants are required comply with whichever is the most stringent between the local limits for pollutants or the concentration-based standards under 40 CFR, Part 423.17 for steam- electric power generation. Categorical limits apply only to contaminants that result from cooling tower maintenance chemicals. Wastewater is sampled and monitored at Sample Location 001 for compliance with local limits. This sampling point is located near MVGS’s industrial water Outfall 001 on the City of San Bernardino Water Reclamation Plant property, near the discharge point to the IEBL. Wastewater is sampled and monitored at Sample Location 002 for compliance with 40 CFR 423.17. This sampling point is located at the MVGS site at the cooling tower blowdown discharge lines, where samples can be collected prior to mixing with any other wastewater discharges. 2.1 Compliance with Other Federal Pretreatment Requirements No other federal requirements apply to this facility. 2.2 Compliance with Local Limits and Actions by the Agency The facility’s most recent direct-user discharge permit (Permit No. 4E-00-S35) was issued by SBVMWD on January 14, 2012. The permit expires on January 27, 2014. The permit contains special conditions related to the perchlorate in the groundwater used at the plant. Because the mid-level aquifer is contaminated with perchlorate, the California Energy Commission requires MVGS to use water from this source, along with reclaimed water, for cooling. MVGS recycles its cooling water to reduce the amount of water consumed. The average concentration of perchlorate in the extracted groundwater is approximately 60 to 90 parts per billion. The wastewater discharged to the IEBL is expected to contain perchlorate at a concentration of approximately 800 to 1,200 parts per billion due to the recycling of water through MVGS’s cooling towers and water treatment plant. MVGS met with SAWPA and OCSD several times in 2005, 2006, and 2007 to discuss the perchlorate discharge. Currently, the concentration of perchlorate in the wastewater discharged into the IEBL is acceptable to SAWPA and OCSD. However, SAWPA, OCSD, and SBVMWD have retained the right to revise MVGS’s permit and require a long-term contingency plan from MVGS if it is determined that the wastewater constituents from MVGS are causing interference, operational problems, or other problems in SAWPA’s or OCSD’s sewerage collection or at OCSD’s facilities. MVGS’s long-term contingency plan may include a proposal for the installation of a pretreatment system and other disposal options regarding the removal of perchlorate or other detected constituents of concern in the wastewater. 3.0 SUMMARY OF FINDINGS 3.1 Overall, the MVGS facility was observed to be clean and in good working order. Industrial User Inspection Report: Mountainview Generating Station November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 4 EEC 3.2 In the last quarterly report (third quarter 2012), a perchlorate concentration of 0.280 milligrams per liter (approximately 280 parts per billion) was detected. The value is still below the concentration threshold of 800 to 1,200 parts per billion that is acceptable to SAWPA and OCSD. Nonetheless, it is recommended that perchlorate concentrations be monitored and seasonal trends be used to anticipate any rise in perchlorate concentrations. This is particularly important considering that MVGS discharges 432,000 gallons of wastewater per day. 3.3 Part 5, Special Conditions, of the permit states, “SAWPA owns the meter and WMWD will maintain including performing annual calibration. Mountainview Generating Station shall immediately notify WMWD of any concerns or issues.” However, the Western Municipal Water District is not the control agency for MVGS, so the permit should be corrected accordingly. Should there be any questions regarding the contents of this inspection report, please contact Mr. Najib Saadeh by phone at (714) 667-2300 or by e-mail at nsaadeh@eecworld.com. Appendices: A. Direct User Discharge Permit No. 4E-00-S35 APPENDIX A DIRECT USER DISCHARGE PERMIT NO. 4E-00-S35 Industrial User Inspection Report Santa Ana Watershed Project Authority Audit Industrial User: OLS Energy Chino Industrial User Address: 5601 Eucalyptus Avenue, Chino, CA 91708 Industrial User Permit Number: C-87-002 Industrial User Representative: Mr. Bill Wimer, Plant Manager Indirect/Direct User: Direct User Agency Area: Inland Empire Utilities Agency Agency Representatives: Mr. Kenneth Tam, Inland Empire Utilities Agency Assistant Engineer Mr. Michael Barber, Inland Empire Utilities Agency Inspector II Inspection Date: September 13, 2012, Scheduled Inspection EEC/PSI Inspector: Mr. Najib Saadeh, Environmental Engineering & Contracting, Inc. Report Date: November 1, 2012 1.0 SCOPE AND PURPOSE On behalf of the Orange County Sanitary District (OCSD), Environmental Engineering & Contracting (EEC) performed an inspection of selected industrial users discharging into the Inland Empire Brine Line (IEBL; formerly known as the Santa Ana Regional Interceptor, SARI). This inspection is part of an audit of the pretreatment programs of the Santa Ana Watershed Project Authority (SAWPA) and its member agencies. To evaluate the performance of the pretreatment programs, industrial users were selectively inspected based on volume of wastewater discharged and/or industry type. The current evaluation is one of a series of inspections of direct and indirect dischargers into the IEBL. Direct dischargers are typically close enough to construct a direct connection to the IEBL and produce enough waste to economically justify the connection cost. Indirect dischargers generate waste streams that are high in total dissolved solids and are not located close enough to the IEBL to make a direct connection. In general, the volume of wastewater discharged at liquid waste hauler (LWH) discharge stations varies. The quantity of liquid waste discharged at these stations can vary from one or two truckloads per week to 100,000 gallons per day in some cases. Liquid waste from indirect dischargers is disposed of at discharge stations using a permitted commercial LWH permitted by SAWPA. On September 13, 2012, EEC inspected the OLS Energy facility, located at 5601 Eucalyptus Avenue, Chino, California, to evaluate the performance of the facility’s regulatory controls. The facility is permitted by the Inland Empire Utilities Agency (IEUA). NAES Corporation (NAES), a service provider to energy-related infrastructure markets, provides the personnel to operate and maintain the facility. The inspection was conducted to evaluate whether OLS has developed and implemented sufficient measures to ensure that discharges into the IEBL comply with the terms and conditions of all applicable agreements and regulations, including OCSD ordinances and 40 CFR 403. Industrial User Inspection Report: OLS Energy Chino November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 2 EEC 1.1 General and Process Description The OLS facility is located on the California Institution for Men (CIM) complex. CIM was opened in San Bernardino County in 1941 on 2,500 acres of land. The CIM is a large prison complex that houses four facilities with varying levels of security. Each facility consists of dormitory housing units and educational and recreational activity areas. The CIM complex also includes ancillary facilities that provide water and wastewater treatment, laundry services, central kitchen, and steam and electricity. OLS Energy supplies steam and electricity to the entire CIM complex. The OLS facility was constructed in 1988 and began discharging to the IEBL in March 1988. Photography is forbidden throughout the CIM high-security prison complex, so no site photographs were taken. OLS uses natural gas to drive the on-site turbine engine to generate electricity. The exhaust gas from the turbine is sent to a heat-recovery steam generator that produces high-pressure steam, which is then collected and supplied to a steam turbine that also produces electricity. Steam from the turbine is supplied to the CIM complex. OLS’s power-generation system is subject to 40 CFR 423 (Steam Electric Power Generating Point Source Category). OLS produces up to 30 megawatts per hour (MWh) of electricity and 15,000 pounds per hour of steam. The electricity is fed into the Southern California Edison grid system at a rate of 26 MWh, and 4 MWh are supplied to the CIM complex for on-site consumption. OLS can also operate a stand-by boiler to supply steam to the CIM laundry when the heat-recovery steam generator is not operational. The sources of the water used by OLS consist of reclaimed water from IEUA at the rate of 3 million gallons per month and potable water from the City of Chino at the rate of 5.5 million gallons per month. Incoming water is treated on-site by a demineralizer and a reverse osmosis system. 1.2 Wastewater Sources Process wastewater is produced from boiler blowdown, air scrubber air-pollution control system, ion- exchange water treatment system, reverse osmosis reject water, cooling tower blowdown, and floor drains. All floor drains lead to a sump, and all wastewater streams are collected in a sump prior to treatment and discharge. The cooling tower blowdown is monitored separately from the rest of the wastewater because it is subject to categorical limits. The facility has a separate sewer system connection for sanitary wastewater. OLS connects to the CIM sanitary sewer. 1.3 Facility Process Wastewater Treatment System Wastewater treatment consists of a 10,000-gallon sump, a clarifier, and pH adjustment. 1.4 Wastewater Discharge OLS connects to the IEBL though a lateral connection that is 2.0 miles in length, 1.5 miles of which is owned by OLS. Categorical limits and local limits are properly monitored at two separate sampling locations. Wastewater is sampled at Sampling Location No. 1 for compliance with IEUA limits; this sampling point is located at the outlet of the sump near the neutralization tanks in the southwest corner of the facility. Cooling tower blowdown is sampled at Sample Location No. 2, located in the manhole by Central Avenue, to ensure compliance with categorical limits. Industrial User Inspection Report: OLS Energy Chino November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 3 EEC 2.0 COMPLIANCE WITH FEDERAL CATEGORICAL STANDARDS The facility is subject to federal categorical standards contained in 40 CFR 423. This regulation defines existing sources as those that began discharging prior to October 14, 1980, and new sources as those that began discharging after this date. The OLS facility began discharging in 1988 and is therefore classified as a new source that is subject to 40 CFR 423.17. The facility must also meet requirements specified in the IEUA-issued permit. 2.1 Compliance with Other Federal Pretreatment Requirements The facility is classified as a categorical industrial user pursuant to 40 CFR 423. Under 40 CFR 423, industrial dischargers that engage primarily in the generation of electricity with fossil fuels and employ a steam water system are considered categorical industrial users. 2.2 Compliance with Local Limits and Actions by the City In addition to the federal and State requirements, the facility is subject to the requirements of IEUA’s Non-Reclaimable Wastewater Ordinance, SAWPA’s ordinance, OCSD’s ordinance, and the IEUA-issued permit. 3.0 SUMMARY OF FINDINGS 3.1 Overall, the OLS facility was observed to be clean and in good working order. 3.2 The pH alarm at the cooling towers’ pH monitoring station was determined to be in good working condition. Should there be any questions regarding the contents of this inspection report, please contact Mr. Najib Saadeh by phone at (714) 667-2300 or by e-mail at nsaadeh@eecworld.com. Appendices: A. Industrial Wastewater Discharge Permit No. C-87-002 APPENDIX A INDUSTRIAL WASTEWATER DISCHARGE PERMIT NO. C-87-002 Page 2 of 23 OLS Energy - Chino Wastewater Discharge Permit No. C-87-002 I. GENERAL CONDITIONS A. Abbreviations: CFR - Code of Federal Regulations Brine Line - Inland Empire Brine Line IEUA - Inland Empire Utilities Agency NRWS - Non-Reclaimable Waste System OCSD - Orange County Sanitation District POTW - Publicly Owned Treatment Works SAWPA - Santa Ana Watershed Project Authority USEPA - United States Environmental Protection Agency B. Wastewater Discharges This permit authorizes the discharge of cooling tower blow down and low volume wastes generated in the process of generating electric power and steam. The low volume waste include wastewater or discharges from wet scrubber air pollution control systems, ion exchange water treatment system, water treatment evaporation, boiler blow down, floor drains, cooling tower basin cleaning wastes, and re-circulating house service water systems. The discharge of any other type of waste will require prior approval from IEUA and/or SAWPA. CONTACT/AUTHORIZED PERSON FOR WASTEWATER DISCHARGE ISSUES: Authorized Officer: Robert Henderson, Vice President Contact Person: William B. Wimer, Plant Manager Phone: (909) 597-0338 E-mail: bwimer@olsenergy.com C. Duty to Comply The Permittee must comply with all conditions of this permit. Failure to comply with the requirements of this permit may be justification for administrative action or enforcement proceedings, including civil or criminal penalties, injunctive relief, and summary abatements. D. Notification of Change The Permittee, during the tenure of this permit, is required to notify IEUA in advance of any change in the status of the facility, including, but not limited to, ownership, authorized representative, operating responsibilities, business name, operating hours, and discharge volume or duration. E. Duty to Mitigate The Permittee shall take all reasonable steps to minimize or correct any adverse impact to the POTW and NRWS and the environment resulting from noncompliance with this permit, including such accelerated or additional monitoring as necessary to determine the nature, source, and impact of the non-compliant discharge. Any discharge to the NRWS or Brine Line in excess of the discharge limitations contained herein requires immediate corrective action by the Permittee. Page 3 of 23 OLS Energy - Chino Wastewater Discharge Permit No. C-87-002 F. Property Rights The issuance of this permit does not convey property rights of any sort, any exclusive privileges, or authorize any activity that results in injury to private property or any invasion of personal rights, nor any violation of Federal, State, or local laws or regulations. G. Severability The provisions of this permit are severable, and if any provision of this permit or the application of any provision of this permit to any circumstance is held invalid, the application of such provision to other circumstances and the remainder of this permit shall not be affected. H. Pretreatment Standards and Requirements The Permittee shall comply at all times with applicable Federal and State pretreatment standards and requirements as given in 40 CFR 403, "Federal Pretreatment Regulations for Existing and New Sources of Pollution," 40 CFR 423, "Steam Electric Power Generation Point Source Category," Subpart 423.17, the current IEUA Non-Reclaimable Wastewater Ordinance, the current SAWPA Ordinance, and any subsequent amendments thereof, and this permit, whichever is more stringent. I. Permit Modification This permit is issued based on the information provided by the Permittee in its permit application. Any significant change in wastewater quantity or quality, by a threshold level as specified in this permit, if any, from the information reported in the permit application, may constitute grounds for a permit modification. This permit may be modified for good cause including, but not limited to, the following actions: 1) Incorporate any new or revised Federal, State, or local pretreatment standards or requirements; 2) Accommodate material or substantial changes to the Permittee’s industrial processes, production, operations or the method of wastewater treatment, which create a significant change in the quality or quantity of industrial wastewater discharged, 3) Incorporate a change in any condition that requires either a temporary or permanent reduction or elimination of the authorized discharge; 4) Respond to information indicating that the permitted discharge poses a threat to the IEUA, SAWPA and/or OCSD collection and treatment systems, personnel or the receiving waters; 5) Respond to violation of any terms or conditions of this permit; 6) Respond to misrepresentation or failure to disclose fully relevant facts in the permit application or in any required reporting; 7) Revise or grant a variance from such categorical standards pursuant to 40 CFR 403.13; 8) Correct typographical or other errors in the permit; 9) Reflect the transfer of facility ownership and/or operation to a new owner/ operator; 10) Respond to a permit modification request from the Permittee, provided that such request does not create a violation of any applicable requirements, standards, laws, rules or regulations. J. Permit Termination This permit may be terminated for the following reasons: 1) Falsifying statements, representations, records, reports, or other documents sent to IEUA, SAWPA and/or OCSD; 2) Tampering with, or knowingly rendering inaccurate, monitoring device or sample collection method; Page 4 of 23 OLS Energy - Chino Wastewater Discharge Permit No. C-87-002 3) Refusing to allow timely access to the facility for the purpose of inspection and monitoring by IEUA, SAWPA, and/or OCSD representatives; 4) Refusing to provide records, reports, plans, or other documents required by IEUA, SAWPA and/or OCSD to determine permit terms, conditions or limitations, discharge compliance, or compliance with the current IEUA Non-Reclaimable Wastewater Ordinance and the SAWPA Ordinance; 5) Failing to meet effluent limitations; 6) Failing to make timely payment of all amounts owed to IEUA for user charges, noncompliance fees, or any other fees; 7) Failing to meet compliance schedules; 8) Failing to report significant changes in operations or wastewater constituents and characteristics; 9) Failing to comply with the terms of enforcement or permit suspension action or order; 10) Discharging wastewater to the NRWS or Brine Line while its permit is under suspension; 11) Failing to submit oral notice or written report of the occurrence of bypass; 12) Discharging wastewater that causes pass through or interference with the NRWS or Brine Line collection, treatment, or disposal system; 13) Discharging a slug load to the NRWS or Brine Line. K. Permit Amendment Any proposed permit revision, which results in a significant change in the wastewater quantity or quality from the information reported in the permit application for the existing permit, will require a new permit application to be submitted to IEUA for approval. Approval must be first obtained prior to implementation of any intended revisions. L. Permit Transfers and the Requirement for a New Permit on Ownership Change Permit transfers are prohibited as specified in Section 422 of the IEUA Non-Reclaimable Wastewater Ordinance. A new permit is required if a business changes ownership. The new owner shall notify IEUA of the ownership change immediately within twenty-four (24) hours, and submit a new permit application to IEUA within five (5) days of the change. M. Treatment Permits Required for Hazardous Wastes The Permittee shall not accept, treat, or dispose of wastes, determined to be hazardous according to 40 CFR 261 or Title 22, Division 4.5 of the California Code of Regulations, at the pretreatment facility, without a hazardous waste facilities permit as required by California Health and Safety Code, Section 25201. N. Annual Publication of Names of Dischargers in Significant Non-Compliance A list of permittees discharging to the NRWS, which were determined to be in significant noncompliance, as defined by the IEUA Non-Reclaimable Wastewater Ordinance, the SAWPA Ordinance, and USEPA General Pretreatment Regulation, will be published annually by IEUA. The Permittee is advised that significant noncompliance with this permit, may lead to publication of the Permittee’s name in the largest daily newspaper within IEUA service area. O. Administrative Civil Penalties Any person, or groups of persons, who violates any portion of the IEUA Non-Reclaimable Wastewater Ordinance, the SAWPA Ordinance, any permit condition, prohibition, or effluent limit, and any permit suspension or revocation order will be subject to administrative civil penalties. Page 5 of 23 OLS Energy - Chino Wastewater Discharge Permit No. C-87-002 The administrative civil penalties that may be assessed are not to exceed $2,000 for each day for failing or refusing to furnish technical or monitoring reports, $3,000 for each day for failing or refusing to timely comply with any compliance schedules, $5,000 for each day and each violation for discharging wastewater in violation of any waste discharge limit or permit condition, and $10 per gallon for discharging wastewater in violation of any permit suspension, permit revocation, cease and desist order or other orders, or prohibition issued or adopted by IEUA, SAWPA, and/or OCSD. P. Judicial Civil Penalties Any person, or group of persons, who violates any conditions established in this permit will be subject to civil penalties including, but not limited to, a fine of up to $25,000 per day of violation. Any person who violates any provisions of the IEUA Non-Reclaimable Wastewater Ordinance, permit conditions, prohibitions, or effluent limitations shall be liable civilly for a penalty pursuant to Section 508 of the IEUA Non-Reclaimable Wastewater Ordinance for each day in which such violation occurs. Q. Criminal Penalties Any person, or group of persons, who violates any provisions of the IEUA Non-Reclaimable Wastewater Ordinance, the SAWPA Ordinance, or any permit conditions, discharge prohibitions or effluent limitations, is guilty of a misdemeanor, which upon conviction is punishable by a fine not to exceed $1,000, or imprisonment for not more than thirty (30) days, or both. Each day in which a violation occurs shall constitute a new and separate offense, and shall be subject to the penalties contained herein. R. Recovery of Costs Incurred In addition to civil and criminal liabilities, the Permittee violating any of the provisions established in this permit, or the IEUA Non-Reclaimable Wastewater Ordinance, the SAWPA Ordinance, or causing damage to, or otherwise obstructing the NRWS or Brine Line, or the sewerage system of OCSD, shall be liable to IEUA, SAWPA, and/or OCSD for any expense, loss, or damage caused by such violation. IEUA shall bill the Permittee for all costs incurred by IEUA, SAWPA, and/or OCSD for any repair, cleaning, or replacement necessary because of the violation. Refusal to pay the assessed costs shall constitute a separate violation. S. Inspection and Entry The Permittee shall allow any authorized representative of IEUA, OCSD and/or SAWPA, California Water Quality Control Board and its Regional Boards, USEPA and other related agencies to: 1) Have immediate access without delay to any facility directly or indirectly connected to the NRWS or Brine Line any time wastewater is being discharged, any time the Permittee’s facility is open or operating, and at any other reasonable times including, but not limited to, emergency situations; 2) Enter upon the Permittee's premises where a regulated facility or activity is located or conducted, or where records, as required by this permit, are kept; 3) Have access to and copy any records that must be maintained by the Permittee under the provisions of this permit; 4) Inspect any facilities, equipment (including equipment used for monitoring and/or controlling discharge to the NRWS or Brine Line), practices, or operations that are regulated and/or required under the provisions of this permit; 5) Sample or monitor, at any time, for purposes of assuring permit compliance, any substances, or parameters at any location; 6) Inspect any production, manufacturing, fabrication, or storage area where pollutants regulated under the provisions of this permit, could originate, be stored, or be discharged to the sewerage system, and; Page 6 of 23 OLS Energy - Chino Wastewater Discharge Permit No. C-87-002 7) Study the industrial wastewater management facilities and wastewater discharges for the purpose of regulatory research. T. Equipment Requirements 1) The Permittee shall, at all times, properly operate and maintain all facilities and systems of treatment and control, including pH adjustment and control, if necessary, and related appurtenances which are installed or used by the Permittee to achieve compliance with the conditions of this permit. 2) The Permittee shall operate and maintain a flow meter to measure and record the instantaneous flow rate and the total volume of wastewater consisting of cooling tower blowdown and low volume wastes discharged to the NRWS or Brine Line. 3) The Permittee shall implement a plan for regular calibration of all monitoring devices used to ensure proper functioning of pretreatment equipment, or monitor discharges to the NRWS or Brine Line. Records of all calibrations conducted shall be kept on file for a period of three (3) years and provided to representatives of IEUA, SAWPA, and/or OCSD upon request. 4) The Permittee shall prepare and maintain an up-to-date Operation and Maintenance Manual of the ion-exchange and bath pretreatment system for ready reference and trouble-shooting by company employees and by IEUA, SAWPA, and/or OCSD representatives. This manual does not need to be submitted to IEUA, SAWPA, and/or OCSD for approval. 5) The Permittee shall implement a plan for regular cleaning and proper disposal of all solids accumulated in tanks, vessels, or containers, designed to retain these materials as a component of pretreatment. Records of all cleaning and solids disposal shall be kept on file for three (3) years and provided to IEUA, SAWPA, and/or OCSD upon request. 6) Upon loss in the efficiency of wastewater treatment, or the loss or failure of all or part of the pretreatment facility, the Permittee shall, to the extent necessary to maintain compliance with this permit, control its production and/or discharge to the NRWS or Brine Line until operation of the pretreatment facility is restored, or an alternative method of treatment is provided. 7) Passive spill containment must be provided for containers, vessels, or tanks which contain cyanide, acids, bases, caustic substances, heavy metals of more than ten (10) pounds of metals in solution, or any toxic, poisonous, or hazardous material in solution in a significant quantity. 8) Any plans for changes in equipment or process must be submitted to IEUA, OCSD and/or SAWPA for approval prior to implementation. 9) Bypass of Treatment Facilities: a) Bypass is prohibited unless unavoidable to prevent loss of life, personal injury, or severe property damage, and no other available alternative exists. b) The Permittee may allow a bypass to occur which does not cause effluent limitations to be exceeded, but only if it is necessary to accomplish essential maintenance to ensure efficient operation. c) IEUA, SAWPA and/or OCSD may approve an anticipated bypass, after considering its adverse effects, if it is determined that the bypass will meet with all applicable provisions of the current IEUA Non-Reclaimable Wastewater Ordinance and SAWPA Ordinance. Page 7 of 23 OLS Energy - Chino Wastewater Discharge Permit No. C-87-002 d) The Permittee shall notify concurrently IEUA, SAWPA and/or OCSD of the bypass in accordance with the requirements in Section IV, Reporting Requirements, Part D of this permit. Page 8 of 23 OLS Energy - Chino Wastewater Discharge Permit No. C-87-002 II. WASTEWATER DISCHARGE LIMITS The effluent discharge limitations for this permit are listed in Appendix A, Discharge Limits and Monitoring Requirements. Discharges exceeding the specified effluent limitations are prohibited without prior approval and permit amendments by IEUA and/or SAWPA and/or OCSD. The Permittee shall strictly comply, at all times, with the effluent limitations and the general prohibition standards as specified below: 1) Permittee shall comply with all general prohibition standards in the IEUA Non-Reclaimable Wastewater Ordinance and the SAWPA Ordinance (Appendix C). 2) Wastewater shall not be discharged to the NRWS unless it has been effectively neutralized to a pH value between 6.0 and 12.0. 3) Wastes that result in encrustation or scale build up in the sewer line shall not be discharged to the NRWS or Brine Line. 4) Petroleum products, non-biodegradable cutting oil, or products of mineral origin which form persistent water emulsions or cause interference or pass-through at the POTW shall not be discharged to the NRWS or Brine Line. 5) Any spill that cannot be treated adequately for sewer disposal must be disposed of at a legally approved disposal site. Under no circumstances shall process solution spills be discharged directly to the sewer. Waste haulers reports or manifests must be kept on file at the Permittee's site address for four (4) years for any spills disposed of in this manner. 6) No hazardous wastes, as defined in 40 CFR Part 261 or in Title 22, Division 4.5 of the California Code of Regulations, shall be discharged to the NRWS or Brine Line. Page 9 of 23 OLS Energy - Chino Wastewater Discharge Permit No. C-87-002 III. WASTEWATER MONITORING REQUIREMENTS A. General Requirements 1) The Permittee shall monitor all discharges to the NRWS or Brine Line according to the methodology and frequency specified in Appendix A of this permit, "Wastewater Discharge Limitations and Monitoring Requirements." 2) Sampling, sample preservation, sample storage, and sample analysis shall be performed in conformance with 40 CFR Part 136, Guidelines Establishing Test Procedures for the Analysis of Pollutants, or as prescribed by IEUA, SAWPA, and/or OCSD. Any alternative test procedures must be approved by IEUA, SAWPA, and/or OCSD before analysis and may require approval by the California Regional Water Quality Control Board and USEPA. 3) The Permittee must immediately re-sample if a sample is not taken, preserved or stored properly. Samples not properly taken, preserved, or stored are not valid. 4) No attempt shall be made by the Permittee, or any authorized representative of the Permittee, to submit analysis results from any samples known to be invalid in order to demonstrate compliance with applicable wastewater discharge limitations. A willful attempt to do so shall subject the Permittee to civil and/or criminal penalties stated in Section I, General Conditions, Part O, P, and Q of this permit. 5) Chemical or physical analysis for any parameter required by this permit must be performed by a laboratory certified by the State of California or approved by IEUA, SAWPA, and/or OCSD. 6) IEUA, SAWPA, and/or OCSD reserve the right to modify the monitoring and sampling requirements in this permit as needed. Permittee may request modification of the monitoring requirements herein. Such requests shall include sufficient justification for the request. Modifications must be approved by IEUA and may need approval from SAWPA and/or OCSD. 7) The Permittee is advised that the monitoring frequencies required in Appendix A are minimum frequencies. The Permittee may perform additional monitoring to demonstrate compliance if necessary. B. Sampling Location(s) All samples taken by Permittee, IEUA, SAWPA, and/or OCSD for determination of permit compliance shall be taken from the following monitoring points: Location (1) – Cooling Tower Blowdown Sampling: Discharge pipe from cooling tower containment basin. This location is north of the basin and by the condenser. (Refer to Appendix B). Location (2) – Entire Facility Discharge Sampling: Wastewater sump by the neutralization tanks, located in the southwest corner of the facility, or IEUA monitoring manhole by Central Avenue. (Refer to Appendix B). The Permittee is responsible for maintaining and cleaning the sampling location to prevent any build-up of oil and grease, sediment or sludge; failure to do so does not invalidate sample test results. Page 10 of 23 OLS Energy - Chino Wastewater Discharge Permit No. C-87-002 Safe and convenient access to the sampling location must be provided for representatives of IEUA, SAWPA, and/or OCSD. If IEUA, SAWPA, and/or OCSD determine that the sampling location is unsafe or difficult to access, the Permittee shall propose an alternate location acceptable to IEUA, OCSD and/or SAWPA. IEUA, SAWPA, and/or OCSD representatives, at the Permittee’s request, may provide a split of any composite sample collected if sufficient sample volume is available. The Permittee may also request a concurrent or sequential grab sample for any grab sample collected by IEUA, SAWPA, and/or OCSD. The split samples are to be deposited with a designated company representative, or with whoever is available if the designated representative is not available. C. Additional Monitoring Requirements 1) Permittee is required to keep the following monitoring records for three (3) years for each of the samples collected in accordance with the requirements of this permit: a) Location where the sample was collected. b) Date and time the sample was collected. c) Preservation method used, if required. d) Type of sample container used for the sampling. e) Analysis method for the sample. f) Analysis results of the sample. g) Name and affiliation of the person conducting the sampling. h) Name of the laboratory performs the analysis. i) Name of the person performs the analysis. j) Signature of a responsible official of the laboratory that performs the analysis. 2) Permittee shall keep a logbook of chemical or solution spills, and shall make it available for inspection by representatives of IEUA, SAWPA, and/or OCSD. Any material that enters a spill containment area must be handled as a spill, including rainwater and any process wastewater from normal operations. All materials removed from the spill containment area, whether restricted or non- restricted must be included in the logbook. The logbook shall contain the following information relevant to the removal of all materials from the contaminated area: a) Date and time of the spill. b) Identity of the spilled material (an analysis is required if the spill is of unknown origin, to determine the type of treatment or remediation needed for proper disposal). c) Quantity or volume of the spill and the contaminated materials. d) Cause of the spill. e) Method of disposition of the spilled material, including transfer to an off-site waste treatment facility. f) Any corrective actions taken to prevent recurrence of the spill. 3) Waste hauler's reports or manifests must be obtained and kept on file for a period of at least four (4) years for any liquid, solids or hazardous wastes removed from the facility. These reports must be made available for inspection by representatives of IEUA, SAWPA, and/or OCSD upon request. Page 11 of 23 OLS Energy - Chino Wastewater Discharge Permit No. C-87-002 IV. REPORTING REQUIREMENTS A. Periodic Reporting 1) Wastewater Monitoring Reports a) Results from the monitoring requirements under Appendix A of this permit shall be periodically reported to IEUA on a semi- annual basis. IEUA shall receive reports on behalf of SAWPA and/or OCSD. The semi-annual monitoring periods are July 1 through December 31 and January 1 through June 30. b) The monitoring report is due 15 days after the end of the semi-annual monitoring periods, which are on January 15 and July 15 of each calendar year. c) The monitoring report shall contain the following: i) Results of all wastewater quality analyses conducted during the semi-annual monitoring period, including the results for monthly or annual monitoring, if performed during the semi-annual monitoring. ii) Methods of analyses used. iii) Units of measurement for all analyzed constituents. iv) Date and time that each sample was collected. v) Volume of wastewater discharged to the NRWS for the day that the sample was collected. vi) Sampling location(s). vii) Name and affiliation of the person(s) conducting the sampling. viii) Name of the laboratory performs the analyses. ix) Signature of an authorized representative as defined in the Non-Reclaimable Wastewater Ordinance. x) A certification statement as specified in Part VII of the Non-Reclaimable Wastewater Ordinance. The information listed above shall be submitted for all sampling and analyses performed during the semi-annual reporting period preceding the submission date. d) Results of any pollutant monitored more frequently than required by this permit (i.e. monthly, weekly basis, etc…), using USEPA, SAWPA and/or OCSD approved methods and taken at the approved sampling location, shall be included in the monitoring report, and they will be included for use in determining compliance with all applicable standards and requirements. e) A copy of the laboratory report corresponding to the reported analyses shall be included with the monitoring report. f) Revision of the list of parameters required for analysis in the monitoring report may be considered after the initial analyses are examined by representatives of IEUA, SAWPA, and/or OCSD, and upon written request from the Permittee with valid supporting information. Page 12 of 23 OLS Energy - Chino Wastewater Discharge Permit No. C-87-002 2) Wastewater Flow Reports: Permittee shall measure and record monthly the total wastewater discharged to the NRWS or Brine Line. The flow report shall be sent monthly to the IEUA by the seventh (7th) of the month following the discharge month. Any variation or adjustment to the reported flow must be requested for review within one hundred eighty (180) days from the submittal date of that reported flow. After the one-hundred-eighty-day period, the reported flow shall become final and any request for variation or adjustment will not be considered. B. Accidental Discharge Reports 1) In case of an accidental discharge, spill, bypass, or slug load to the NRWS or Brine Line of any substance prohibited by this permit or the IEUA Non-Reclaimable Wastewater Ordinance or the SAWPA Ordinance, the Permittee shall notify IEUA, SAWPA, and/or OCSD immediately. For normal business hours (Monday - Friday, 7:00 A.M. - 5:00 P.M.), IEUA may be notified on behalf of SAWPA and/or OCSD by telephone at (909) 993-1600. 2) The notification shall include the following: a) Location of the discharge b) Time and date of the discharge c) Duration of the discharge d) Type of waste discharged e) Concentration and volume of waste discharged f) Any actions taken to halt the discharge 3) Notification of accidental discharge in accordance with this section does not relieve the Permittee of other reporting actions required under Federal, State and local laws. C. Discharge Violation Reports and Automatic Re-sampling If the result of Permittee's wastewater analysis indicates a violation of the wastewater discharge requirements has occurred, Permittee shall take the following actions: 1) Inform IEUA of the violation(s) within twenty-four (24) hours of becoming aware of the violation. Permittee is advised that failure to review a chemical analysis report upon receipt from its contracted laboratory shall not excuse Permittee from this requirement. 2) Repeat the sampling and analysis for the constituents in violation and submit the results to the IEUA within fifteen (15) days of the discovery of the violation(s). D. Operations Upsets or Slug Load Discharge 1) A Permittee that experiences an operational upset or discharges a slug load to the NRWS or Brine Line that places the Permittee in a temporary state of non-compliance with the provisions of this permit shall submit notification according to Section IV, Reporting Requirements, Part B above. A slug load is defined as any discharge of a non-routine and episodic nature including, but not limited to, accidental spills and non-customary batch discharge. 2) If an operational upset or discharge of a slug load occurs, the Permittee shall submit a written follow-up report of the incident to IEUA within five (5) days of the incident (in accordance with Section IV - Part B above). The report shall specify the following: Page 13 of 23 OLS Energy - Chino Wastewater Discharge Permit No. C-87-002 a) Description of the upset or slug load and the cause(s) thereof, and the impact upon the Permittee's compliance status; b) Duration of the noncompliance, including the exact time and date of noncompliance. If the noncompliance continues, the time and date by which compliance is reasonably expected to be achieved; and c) All actions taken, or to be taken, to reduce, eliminate, or prevent a recurrence of the upset or slug load or any related conditions of noncompliance. 3) In addition, the report must demonstrate that the treatment facility was being operated in a prudent and workman-like manner at the time of the upset or slug load. If operating upsets or slug load discharges occur at such intervals that IEUA, SAWPA and/or OCSD concludes that a Slug Control Plan is required, the Permittee shall submit the plan within thirty (30) days of notification of the requirement. The Plan shall include the following: a) Description of the discharge practices, including non-routine batch discharges, b) Description of the chemicals stored at the facility, c) Procedure to immediately notify IEUA, SAWPA, and/or OCSD of slug loads, including any discharges that would violate a prohibition outlined in 40 CFR Part 403.5 (b), and d) Procedure to prevent adverse impact from the accidental spills, including inspection and maintenance of storage areas, safe handling and transfer of materials, proper loading and unloading operations, control of facility run-off, adequate training of workers, provision of spill containment structures or equipment, and establishment of measures and equipment for emergency response. 4) The Permittee is required to notify IEUA immediately of any changes at its facility affecting the potential for a Slug Load Discharge. E. Hazardous Waste Discharge Reporting Requirements The Permittee shall notify IEUA, in writing, of any discharge into the NRWS or Brine Line of a substance that is designated as a hazardous waste according to 40 CFR Part 261. Permittee shall complete and submit a Notification Report of the Discharge of Hazardous Wastes. Only hazardous wastes according to federal regulations need be considered for this reporting. A form for the report is available from IEUA. Notification must be sent to IEUA, SAWPA, and/or OCSD, USEPA and the California State Department of Toxic Substances Control. A new notification report must be submitted if there is substantial change in the volume or characteristics of the hazardous waste present in the discharge. Notification to IEUA, SAWPA and/or OCSD of the discharge of hazardous wastes shall be made in advance. A new notification report shall also be required if there are new regulations that identify additional waste as hazardous. The new notification report must be submitted within ninety (90) days of the effective date of the new regulations. As part of the notification report, the Permittee must also certify that it has a program in place to reduce the volume and toxicity of the hazardous wastes generated, to the degree Permittee has determined to be economically practical. The notification report shall include the following information to the extent the information is readily known and available to the Permittee: a) Name of the hazardous waste, b) EPA hazardous waste number, c) Type of sewer discharge conducted (continuous, batch, or others), d) Estimated mass discharges of the hazardous constituent over one month and twelve months. Page 14 of 23 OLS Energy - Chino Wastewater Discharge Permit No. C-87-002 The notification is required to be made only once for each hazardous waste discharged. This notification does not apply to constituents already reported as required in the Appendix A of this permit. F. Notification of Bypass 1) For anticipated bypass, the Permittee shall submit a written notice to the IEUA at least ten (10) days before the actual date of the bypass. 2) For unanticipated Bypass, the Permittee shall immediately notify IEUA by telephone as described in Section IV (B)(1) above, and submit a written notice within five (5) days. This notice shall contain the following information: a) A detailed description of the bypass, including the cause and duration; b) A statement whether the bypass has been corrected; and c) The actions being taken, or to be taken, to reduce, eliminate and/or prevent a recurrence of the bypass. G. Special Requirements 1) Pursuant to Section 103.0 of the SAWPA Ordinance, the General Manager of SAWPA shall administer, implement and enforce the provisions of the SAWPA Ordinance. Any powers granted or duties imposed upon the General Manager may be delegated by the General Manager to persons acting in the beneficial interest or employ of SAWPA, but shall remain the responsibility of the General Manager. In addition to the authority to prevent or eliminate discharges through enforcement of discharge limitations and prohibitions, the General Manager shall, after informal notice to the affected user, may immediately and effectively halt or prevent any discharge of pollutants into the Brine Line or tributaries thereto, by any means available, including physical disconnection from the Brine Line or tributaries thereto, whenever the wastewater discharge may endanger reasonably appears to present an imminent endangerment to the health or welfare of the community, the environment, or threatens to damage or interfere with the operation of the Brine Line or tributaries thereto or the collection system and treatment facilities of IEUA or OCSD. Such discharges may be halted or prevented without regard to the compliance by the user with other provisions of this Ordinance. 2) The Permittee is required to submit, and retain a copy on-site, a Contingency Plan that details the actions that will be taken in the event of an emergency or other event that causes IEUA, SAWPA or OCSD to shut down the Brine Line. Said Plan shall include, but is not limited to the following: a) A list of names and telephone numbers of emergency contacts that can be reached 24 hours a day. The Permittee shall provide IEUA, on a semi-annual basis (January and June), a list containing the names and phone numbers of contacts who can be reached 24 hours a day in the event of an emergency with the NRWS or Brine Line discharge. b) A written plan that describes all available alternatives to discharging to the Brine Line, including on-site storage, hauling, ceasing the discharge, or directing all wastewater flows to a local POTW. The Permittee shall develop such plan, update and provide to IEUA, on behalf of SAWPA, annually in January. 3) The Permittee is responsible for all costs associated with the operation, maintenance, repair and replacement of their lateral connection to the Brine Line. Operations and Maintenance of the lateral Page 15 of 23 OLS Energy - Chino Wastewater Discharge Permit No. C-87-002 includes locating the line per requirements of state law. This includes registering with Underground Service Alert. 4) The Permittee is required to notify IEUA, on behalf of SAWPA, of any planned process changes or other modifications which will alter the amount of or pollutant strength of any wastewater which is discharged to the Brine Line, thirty (30) days prior to the actual implementation of the changes. 5) The Permittee shall reimburse IEUA for all permit and disposal costs imposed on IEUA by SAWPA or OCSD resulting from the Permittee’s discharge to the Brine Line. The Permittee shall also reimburse IEUA, SAWPA, OCSD for all costs incurred as a result of any enforcement action. 6) The discharge of fly ash transport water and polychlorinated biphenyl compounds such as those used for transformer fluid are prohibited. 7) The Permittee shall notify IEUA, SAWPA, and/or OCSD in writing should OLS choose to generate and discharge chemical metal cleaning wastes as defined in 40 CFR 432.11(c). 8) The Permittee shall submit a written request to IEUA, SAWPA, and/or OCSD for approval prior to the implementation of new cooling tower maintenance chemicals. Page 16 of 23 OLS Energy - Chino Wastewater Discharge Permit No. C-87-002 Appendix A Discharge Limitations and Monitoring Requirements Location (1): Sampling of Cooling Tower Blow Down Parameter Limit Sample Type Frequency Footnote Chromium (Cr), Total 0.2 mg/L Max for any 1 day Composite Semi-Annual 1,2 Zinc (Zn), Total 1.0 mg/L, Max for any 1 day Composite Semi-Annual 1,2 pH 6.0 – 12.0, Standard Unit, Min/Max at any time Grab Semi-Annual 1,2 Priority Pollutants (Appendix D)** None Detected Certification Statement Semi-Annual Certificate 2 Wastewater Discharge Not Specified Continuous Continuous Location (2): Sampling of Entire Facility Discharge Parameter Limit Sample Type Frequency Footnote Arsenic (As), Total 2.0 mg/L, Max for any 1 day Composite Semi-Annual 1,2 Cadmium (Cd), Total 1.0 mg/L, Max for any 1 day Composite Semi-Annual 1,2 Chromium (Cr), Total 0.39 mg/L, Max for any 1 day Composite Semi-Annual 1,2,7 Copper (Cu), Total 3.0 mg/L, Max for any 1 day Composite Semi-Annual 1,2 Cyanide (CN), Total 5.0 mg/L, Max for any 1 day Grab Semi-Annual 1,2 Lead (Pb), Total 2.0 mg/L, Max for any 1 day Composite Semi-Annual 1,2 Mercury (Hg), Total 0.03 mg/L, Max for any 1 day Composite Semi-Annual 1,2 Nickel (Ni), Total 10.0 mg/L, Max for any 1 day Composite Semi-Annual 1,2 Silver (Ag), Total 5.0 mg/L, Max for any 1 day Composite Semi-Annual 1,2 Zinc (Zn), Total 1.98 mg/L, Max at 1 day Composite Semi-Annual 1,2,7 Oil & Grease - (Non-Polar) 100 mg/L, Max at any time Grab Semi-Annual 1,2,11 pH 6.0 - 12.0, Standard Unit, Min/Max at any time Grab Semi-Annual 1,2 Sulfides (Total) 5.0 mg/L, Max at any time Grab Semi-Annual 1,2 Sulfides (Dissolved) 0.5 mg/L, Max at any time Grab Semi-Annual 1,2 Total Suspended Solids (TSS)* Surcharge Threshold Composite Monthly 1,2,3 Biochemical Oxygen Demand (BOD)* Surcharge Threshold Composite Monthly 1,2,4 Biochemical Oxygen Demand (BOD)* 15,000lbs/day Composite Monthly 1,2,4 Polychlorinated Biphenyl's (PCB's) 0.01 mg/L, Max at any time Grab Annual 1,2,5,8 Pesticides 0.01 mg/L, Max at any time Grab Annual 1,2,5,9 Total Toxic Organics (TTO) 0.58 mg/L, Max at any time Grab Annual 1,2,6,10 Temperature 140 Fahrenheit (60 Centigrade), Max at any time Grab Annual 1,2 Silica Not Yet Established Composite Semi-Annual 1,2 Total Hardness* Not Yet Established Composite Monthly 1,2 Volatile Suspended Solids (VSS) Not Yet Established Composite Semi-Annual 1,2 Dissolved Organic Carbon (DOC) Not Yet Established Composite Semi-Annual 1,2 Wastewater Discharge Daily Maximum Daily Peak 129,600 gallons per day 90 gallons per minute Continuous Continuous * Sampling results of marked constituents are to be reported to IEUA on a monthly basis by the 7th of the month following the discharge month. ** The Permittee shall submit a semi-annual certification statement certifying that cooling tower chemicals do not contain any priority pollutants listed in Appendix D. Refer to Section IV(A) for submittal requirements. Page 17 of 23 OLS Energy - Chino Wastewater Discharge Permit No. C-87-002 Footnote: 1. A composite sample shall be a collection of at least 12 discrete samples obtained at equal flow proportioned or time intervals for the duration of the discharge over a representative workday not to exceed a 24-hour period. A grab sample shall be an individual sample collected in less than 5 minutes. 2. Refer to Section IV(A) for monitoring periods and submittal requirements. 3. The TSS surcharge will be assessed based on an arithmetic mean of available analysis results obtained from all representative samples, composite or grab, taken during a calendar month. If there are no representative samples for a sample month, the arithmetic mean of the previous sample month in which sampling occurs shall be used for surcharge assessment. The surcharge does not eliminate any liability for excessive discharge of TSS that may cause severe impact to wastewater quality in the IEUA/SAWPA sewer system. The IEUA Board of sets the TSS surcharge rate yearly in July. 4. The BOD surcharge will be assessed based on an arithmetic mean of available analysis results obtained from all representative samples, composite or grab, taken during a calendar month. If there are no representative samples for a sample month, the arithmetic mean of the previous sample month in which sampling occurs shall be used for surcharge assessment. The surcharge does not eliminate any liability for excessive discharge of BOD that may cause severe impact to wastewater quality in the IEUA/SAWPA sewer system. The IEUA Board of Directors sets the BOD surcharge rate yearly in July. 5. To be performed in conformance with EPA Test Method 625 or 608. 6. To be performed in conformance with EPA Test Method 624. TTO (Total Toxic Organics) is defined as the sum of the concentrations of specific toxic organic compounds found in the industrial user’s process discharge at a concentration greater than 0.01 mg/L. 7. A flow-weighted limit was obtained since, on average, 89% of the effluent is the cooling tower blow down. Therefore, 89% of the cooling tower blow down limit and 11% of the low volume waste limit were used to derive the effluent limit. Effluent Limit = (0.89)(cooling tower blow down limit) + (0.11)(low volume waste limit) 8. Polychlorinated Biphenyls comprise of the following: PCB-1016, PCB-1221, PCB-1232, PCB-1242, PCB-1248, PCB-1254, and PCB-1260. 9. Pesticides comprise of the following: Aldrin -BHC -BHC -BHC -BHC Chlordane 4,4'-DDD 4,4'-DDE 4,4'-DDT Dieldrin Endosulfan I Endosulfan II Endosulfan Sulfate Endrin Endrin Aldehyde Heptachlor Heptachlor Epoxide Toxaphene 10. The term Total Toxic Organics (TTO) shall mean the summation of all quantifiable values found at concentrations greater than 0.010 milligrams per liter (mg/L) for the following compounds: Benzene Toluene Chloroform Ethylbenzene Methylene Chloride Tetrachloroethene Page 18 of 23 OLS Energy - Chino Wastewater Discharge Permit No. C-87-002 Trichloroethene 1,1,1-Trichloroethane 11. Non-Polar Oil & Grease must be analyzed by EPA Method 1664 (SGT-HEM), Revision A. SUMMARY OF REPORTING AND MONITORING REQUIREMENTS Constituents to be Monitored Monitoring Frequency Reporting Frequency Report Submission Wastewater Discharge Volume, Total Suspended Solids, Biochemical Oxygen Demand, Total Hardness Continuously & Monthly Monthly By 7th of the following month Arsenic, Cadmium, Chromium, Copper, Cyanide, Lead, Mercury, Nickel, Silver, Zinc, pH, Non-Polar Oil & Grease, Sulfides, Silica, Volatile Suspended Solids, Dissolved Organic Carbon Semi-Annual Semi- Annual Jan 15, and July 15 Polychlorinated Biphenyl’s, Pesticides, Total Toxic Organics, Temperature Annual Annual July 15 Page 19 of 23 OLS Energy - Chino Wastewater Discharge Permit No. C-87-002 Appendix B Approved Discharge & Sampling Location (Permittee’s Facility Layout attached and Legal Sampling Location (2) shown here) Sampling Location (2) – Entire Facility Discharge Sampling: Wastewater sump by the neutralization tanks, located in the southwest corner of the facility, or IEUA monitoring manhole by Central Avenue. Permit No. C-87-002 Legal Sampling Location #2 Permit No. C-87-002 Legal Sampling Location #1 IEUA Page 20 of 23 OLS Energy - Chino Wastewater Discharge Permit No. C-87-002 Appendix C IEUA Non-Reclaimable Wastewater Ordinance and SAWPA Wastewater Ordinance The IEUA Non-Reclaimable Wastewater Ordinance No. 62 is available from www.IEUA.org The SAWPA Ordinance is available from www.SAWPA.org. Page 21 of 23 OLS Energy - Chino Wastewater Discharge Permit No. C-87-002 Appendix D List of Priority Pollutants (40 CFR 423 Appendix A) 1. Acenaphthene 2. Acrolein 3. Acrylonitrile 4. Benzene 5. Benzidine 6. Carbon tetrachloride (tetrachloromethane) 7. Chlorobenzene 8. 1,2,4-trichlorobenzene 9. Hexachlorobenzene 10. 1,2-dichloroethane 11. 1,1,1-trichloreothane 12. Hexachloroethane 13. 1,1-dichloroethane 14. 1,1,2-trichloroethane 15. 1,1,2,2-tetrachloroethane 16. Chloroethane 17. Bis(2-chloroethyl) ether 18. 2-chloroethyl vinyl ether (mixed) 19. 2-chloronaphthalene 20. 2,4, 6-trichlorophenol 21. Parachlorometa cresol 22. Chloroform (trichloromethane) 23. 2-chlorophenol 24. 1,2-dichlorobenzene 25. 1,3-dichlorobenzene 26. 1,4-dichlorobenzene 27. 3,3-dichlorobenzidine 28. 1,1-dichloroethylene 29. 1,2-trans-dichloroethylene 30. 2,4-dichlorophenol 31. 1,2-dichloropropane 32. 1,2-dichloropropylene (1,3-dichloropropene) 33. 2,4-dimethylphenol 34. 2,4-dinitrotoluene 35. 2,6-dinitrotoluene 36. 1,2-diphenylhydrazine 37. Ethylbenzene 38. Fluoranthene 39. 4-chlorophenyl phenyl ether 40. 4-bromophenyl phenyl ether 41. Bis(2-chloroisopropyl) ether 42. Bis(2-chloroethoxy) methane 43. Methylene chloride (dichloromethane) 44. Methyl chloride (dichloromethane) 45. Methyl bromide (bromomethane) 46. Bromoform (tribromomethane) 47. Dichlorobromomethane Page 22 of 23 OLS Energy - Chino Wastewater Discharge Permit No. C-87-002 48. Chlorodibromomethane 49. Hexachlorobutadiene 50. Hexachloromyclopentadiene 51. Isophorone 52. Naphthalene 53. Nitrobenzene 54. 2-nitrophenol 55. 4-nitrophenol 56. 2,4-dinitrophenol 57. 4,6-dinitro-o-cresol 58. N-nitrosodimethylamine 59. N-nitrosodiphenylamine 60. N-nitrosodi-n-propylamine 61. Pentachlorophenol 62. Phenol 63. Bis(2-ethylhexyl) phthalate 64. Butyl benzyl phthalate 65. Di-N-Butyl Phthalate 66. Di-n-octyl phthalate 67. Diethyl Phthalate 68. Dimethyl phthalate 69. 1,2-benzanthracene (benzo(a) anthracene 70. Benzo(a)pyrene (3,4-benzo-pyrene) 71. 3,4-Benzofluoranthene (benzo(b) fluoranthene) 72. 11,12-benzofluoranthene (benzo(b) fluoranthene) 73. Chrysene 74. Acenaphthylene 75. Anthracene 76. 1,12-benzoperylene (benzo(ghi) perylene) 77. Fluorene 78. Phenanthrene 79. 1,2,5,6-dibenzanthracene (dibenzo(,h) anthracene) 80. Indeno (,1,2,3-cd) pyrene (2,3-o-pheynylene pyrene) 81. Pyrene 82. Tetrachloroethylene 83. Toluene 84. Trichloroethylene 85. Vinyl chloride (chloroethylene) 86. Aldrin 87. Dieldrin 88. Chlordane (technical mixture and metabolites) 89. 4,4-DDT 90. 4,4-DDE (p,p-DDX) 91. 4,4-DDD (p,p-TDE) 92. Alpha-endosulfan 93. Beta-endosulfan 94. Endosulfan sulfate 95. Endrin 96. Endrin aldehyde 97. Heptachlor 98. Heptachlor epoxide (BHC-hexachlorocyclohexane) Page 23 of 23 OLS Energy - Chino Wastewater Discharge Permit No. C-87-002 99. Alpha-BHC 100. Beta-BHC 101. Gamma-BHC (lindane) 102. Delta-BHC (PCB-polychlorinated biphenyls) 103. PCB-1242 (Arochlor 1242) 104. PCB-1254 (Arochlor 1254) 105. PCB-1221 (Arochlor 1221) 106. PCB-1232 (Arochlor 1232) 107. PCB-1248 (Arochlor 1248) 108. PCB-1260 (Arochlor 1260) 109. PCB-1016 (Arochlor 1016) 110. Toxaphene 111. Antimony 112. Arsenic 113. Asbestos 114. Beryllium 115. Cadmium 116. Chromium 117. Copper 118. Cyanide, Total 119. Lead 120. Mercury 121. Nickel 122. Selenium 123. Silver 124. Thallium 125. Zinc 126. 2,3,7,8-tetrachloro-dibenzo-p-dioxin (TCDD) Industrial User Inspection Report Santa Ana Watershed Project Authority Audit Industrial User: RP No. 5 Solids Handling (Environ Strategy Consultants, Inc.) Industrial User Address: 16090 Mountain Avenue, Chino, California 91710 Industrial User Permit Number: SSP019 Industrial User Representatives: Mr. Bob Olson, Maintenance Mr. Alfredo Ferrin Indirect/Direct User: Direct Agency Area: Inland Empire Utilities Agency (IEUA) Agency Representatives: 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 Inspection Date: August 23, 2012, Scheduled Inspection EEC/PSI Inspectors: Dr. John R. Parnell, Pretreatment Solutions, Inc. Mr. Najib Saadeh, Environmental Engineering & Contracting, Inc. Report Date: November 1, 2012 1.0 SCOPE AND PURPOSE On behalf of the Orange County Sanitary District (OCSD), Environmental Engineering & Contracting (EEC) performed an inspection of selected industrial users discharging into the Inland Empire Brine Line (IEBL; formerly known as the Santa Ana Regional Interceptor, SARI). This inspection is part of an audit of the pretreatment programs of the Santa Ana Watershed Project Authority (SAWPA) and its member agencies. Industrial users were selectively inspected based on volume of wastewater discharged and/or industry type in order to evaluate the performance of the pretreatment programs. The current evaluation is one of a series of inspections of direct and indirect dischargers into the IEBL. Direct dischargers are typically close enough to construct a direct connection to the IEBL and produce enough waste to economically justify the connection cost. Indirect dischargers generate waste streams that are high in total dissolved solids and are not located close enough to the IEBL to make a direct connection. In general, the volume of wastewater discharged at LWH discharge stations varies. The quantity of liquid waste discharged at these stations can vary from one or two truckloads per week to 100,000 gallons per day in some cases. Liquid waste from indirect dischargers is disposed of at discharge stations using a permitted commercial LWH permitted by SAWPA. On August 23, 2012, EEC completed a performance evaluation of the regulatory controls at the RP-5 Solids Handling (Environ Strategy Consultants, Inc.), located at 16090 Mountain Avenue in the City of Chino, California (Appendix A, Site Photographs, Photo 1). The facility is permitted, inspected, and monitored by the Inland Empire Utilities Agency (IEUA). The inspection was conducted to evaluate Industrial User Inspection Report: RP No. 5 Solids Handling Facility November 1, 2012 W2422.01T Santa Ana Watershed Project Authority 2 EEC whether the RP-5 Solids Handling Facility has developed and implemented sufficient measures to ensure that discharges into the IEBL comply with the terms and conditions of all applicable agreements and regulations, including OCSD ordinances and 40 CFR 403. 1.1 General and Process Description This site was originally the sludge processing plant used and owned by IEUA. The land and equipment is still owned by IEUA and is leased to Environ Strategy Consultants, Inc. to operate the RP No. 5 Solids Handling Facility. The RP No. 5 Solids Handling Facility converts food wastes from a variety of different sources into primarily methane gas through a biological digestion process. Liquid and semisolid food waste material is trucked to the site by tanker trucks and discharged into one of three storage tanks with 15,000 gallon of capacity; the tanks are labeled 200, 300, or 400 (Appendix A, Site Photographs, Photo 2). The Food waste material originates from juices (fructose), reverse osmosis, and ultra-filtration reject from Clement Pappas, dissolved air floatation floats from Dean Foods, wash-down from Farmer John, and other sources. The food waste material in the storage tanks is tested for pH and other qualities before being passed to Mixing Tank No. 100 for blending. Blended liquid is fed directly to one of two circular complete-mix digesters that have a capacity of 1.2 Million gallons. Currently, only one digester is in operation. Cow manure and brewery waste are also added to the digester to further enhance the digestion process. The digester can continuously recirculate the food material to the top of the tank from the bottom, halfway up the tank, or two-thirds up the tank using pipes and pumps (Appendix A, Photo 3). In addition, the digester continuously agitates the food material internally by means of a set of rotating fan blades suspended on a central axle shaft. Blended food waste from Mixing Tank No. 100 is directly fed to the digester until the digester is full. Additional feed then continues approximately six times per day in batches of 1,000 gallons at a time. This continuous feed causes approximately 6,000 gallons per day of semisolid digested material to be discharged from the digester. The discharged fluid is heated by the thermo-activity of the bacterial digestion process and is passed through a heat exchanger where the heat is transferred to the material being fed to the digester. In the winter season, a backup boiler may also be used to preheat the digester feed material to speed up the digestion process. The discharged semisolid material is then fed into a large equalization/mixing tank for further processing, including sulfide control by the addition of a hypochlorite solution. From the equalization tank, the material is pumped through a polymer addition system to a 30-gallon- per-minute (gpm) dissolved air floatation (DAF) system located in a receiving building (at present, flow to the DAF unit is 22 gpm. EEC was informed that the unit is too small to handle the projected increased flow and should be replaced with a 100 gpm unit). DAF solids removed from the top of the unit are returned to the digester to maintain bacterial activity and to avoid excessive surcharges due to high total suspended solids (TSS) in discharge to the IEBL. Excess DAF floats can be passed through rotary presses and disposed of as a nonhazardous solid waste. The DAF unit acts solely as an oxidation process, which releases ammonia gas. The BOD concentration is not significantly reduced through this process. DAF effluent passes to a collection pit in the DAF receiving building and is transferred to an outside tank for storage prior to disposal. A refrigerated auto-sampler is located next to the discharge tank, and the strainer on the end of the sample collection line is permanently fixed in the discharge line to the tank. Samples of the discharge are collected daily by the permittee for internal process control. EEC understands that IEUA also samples at this location. Industrial User Inspection Report: RP No. 5 Solids Handling Facility November 1, 2012 W2422.01T Santa Ana Watershed Project Authority 3 EEC Digester gas produced by the complete-mix biological process is extracted from the top of the digester and passes through an antifoaming system and a condensation trap system to an iron sponge filter. This filter removes any hydrogen sulfide present in the gas, which then passes through a continuous hydrogen sulfide detector. Currently, the remaining gas consisting mostly of methane is burnt off by a continuous flame unit (Appendix A, Photo 4). Eventually, when permits are in place, the methane will be passed to storage tanks. Compressors will increase the gas pressure to 10 pounds per square inch and the pressurized gas will be used to fuel two 1.6-megawatt electrical generators at a rate of 500 cubic feet per minute per generator. Currently, the plant is staffed by five individuals working in shifts from 4:30 a.m. to 6:30 p.m. The digester discharges materials for approximately 12 hours per day. The plant does not operate at night. 1.2 Wastewater Sources Process wastewater consists of the effluent from the DAF unit and rotary presses as described in Section 1.1 above. At the time of the inspection, the startup wastewater used for hydraulic testing of the permittee’s equipment referred to in Permit No. SSP019 was no longer being produced. 1.3 Facility Process Wastewater Treatment System The complete facility consists of a wastewater treatment system, the process of which is described in Section 1.1 above. 1.4 Wastewater Discharge The source of wastewater discharged to the IEBL is described in Section 1.1 above. 2.0 COMPLIANCE WITH FEDERAL CATEGORICAL STANDARDS This facility is permitted as a significant industrial user and is not subject to federal categorical standards. Processing of food waste is exempt from the Centralized Waste Treatment Point Source Category at 40 CFR Part 437 as described in 437.1(b)(9). 2.1 Compliance with Other Federal Pretreatment Requirements This facility should be classified as a significant industrial user, which is subject to the local limits developed by OCSD. Like any industrial user, the facility must also comply with pretreatment requirements in 40 CFR 403, including but not limited to, national prohibitions in 40 CFR 403.5 and reporting requirements in 40 CFR 403.12. 2.2 Compliance with Local Limits and Actions by the Agency The permit contains the OCSD-required local limits and other SAWPA limits for surcharge purposes. The IEUA requires the permittee to sample the effluent on a monthly basis from a manhole located on Flower Street as described in Section III B of the permit and illustrated on Appendix B of the permit. There was some confusion as to the manhole sampling point and the discussion of the samples collected in the discharge pipe to the storage tank described above. Industrial User Inspection Report: RP No. 5 Solids Handling Facility November 1, 2012 W2422.01T Santa Ana Watershed Project Authority 4 EEC 3.0 SUMMARY OF FINDINGS 3.1 The facility was inspected and found to be in clean operating condition. The inspection identified the following issues: 1. The final DAF unit discharge effluent is not continuously monitored for pH. The digestion process will not function in excessively high alkaline or excessively low acidic conditions and a pH of 7 to 8 is constantly maintained in the digester. Any excursion of pH in the digester effluent due to the development of septic conditions could result in acidic conditions in the final effluent. A grab sample for pH is required at each sampling event. 2. 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 collection pit on the effluent side of the DAF unit. 3. The exact location of the sample point was described 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. The exact location of all samples collected to date by both IEUA and the permittee should be further investigated 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. The January to March 2012 quarterly report from IEUA to SAWPA referred to a future revision of a sampling point, but no further information could be found. 3.2 All exterior tanks, pumps, and associated equipment were found to be in good condition and adequately bermed in case of emergency spills or accidents. 3.3 RP No. 5 Solids Handling Facility holds a direct discharge permit prepared by IEUA, which has been approved for structure and content by both SAWPA and OCSD (Permit No. SSP019, Effective Date: October 19, 2011, Expiration date: October 18, 2013). 3.4 The IEUA permit is structured differently than permits issued by the other three agencies and the permit format suggested by the U.S. Environmental Protection Agency manual, Industrial User Permitting Guidance Manual, dated September 1989. The main body of the permit consists of the standard regulations, and the required monitoring activities are included in Appendix A of 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 Appendix B of 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. It is recommended that the permit be revised to conform to the standard format established in the USEPA manual; it is also recommended that all requirements for monitoring be included in the body of the permit rather than in appendices. 3.5 The facility is permitted as a nonsignificant industrial user, but neither the classification nor the rationale for classification (e.g. industrial flow exceeding 25,000 gallons per day) is explicitly stated in the body of the permit. Industrial User Inspection Report: RP No. 5 Solids Handling Facility November 1, 2012 W2422.01T Santa Ana Watershed Project Authority 5 EEC 3.6 The permit implies but does not explicitly state that the permittee is responsible for effluent sampling and for paying for all required monitoring activities. Effluent sampling is required on a monthly basis. IEUA inspects the facility on a semiannual basis and performs sampling. 3.7 No enforcement procedures were reported to the auditor for this facility. 3.8 The sampling point should be clearly identified in the permit as well as in the field. This would help ensure that the same sample point is consistently used. Also, IEUA should make sure that the sample collected is representative of the wastewater discharged from RP-5. If a strainer is used to remove solids from the sample, then, the solids in the wastewater should also be removed using the same mesh size strainer. 3.9 In the USEPA Model Ordinance, dated January 2007, a grab sample is defined as “a sample that is taken from a wastestream without regard to the flow in the wastestream and over a period of time not to exceed fifteen (15) minutes.” IEUA’s facility permit defines a grab sample as an individual sample collected in less than 5 minutes, which is not consistent with the USEPA model. 3.10 Since this facility only accepts food waste and is exempt from the centralized waste treatment regulations in 40 CFR Part 437 (see Section 2.0 above), the permit must contain a section that requires the permittee to provide the IEUA with information, at least 90 days before commencing activities, of any new customer with whom it intends to do business. This will guarantee that no customer from inside or outside of the municipal area is allowed to haul waste to the RP-5 facility without full disclosure to the regulatory agencies of the waste substances involved and the origins of those wastes. This clause should also be included in any future permit developed for any facility that accepts wastes hauled from off-site for processing. 3.11 Photography was not allowed within the facility but some were taken from viewpoints outside the gates of the facility. Should there be any questions regarding the contents of this inspection report, please contact Mr. Najib Saadeh by phone at (714) 667-2300 or by e-mail at nsaadeh@eecworld.com. Appendices: A. Site Photographs (From outside the facility only) B. Indirect User Discharge Permit No. SSP019 APPENDIX A SITE PHOTOGRAPHS Industrial User Inspection Report: RP No. 5 Solids Handling Facility November 1, 2012 W2422.01T Santa Ana Watershed Project Authority A-1 EEC Photo 1 Photo 2 RP-5 Renewable Energy Project front gate Digesters and waste-receiving tanks (arrow) Photographed by John Parnell Photographed by John Parnell Photo 3 Digesters (Right Hand One in Use) Photographed by John Parnell Photo 4 Methane flame tower Photographed by John Parnell APPENDIX B DIRECT USER DISCHARGE PERMIT NO. SSP019 Industrial User Inspection Report Santa Ana Watershed Project Authority Audit Industrial User: San Bernardino Valley Municipal Water District Liquid Waste Hauler Disposal Station (operated by San Bernardino Municipal Water Department [SBMWD]) Industrial User Address: c/o City of San Bernardino’s Wastewater Reclamation Plant, 399 Chandler Place, San Bernardino, CA 92408 Industrial User Permit Number: 4E-04-S56 Industrial User Representative/s: Mr. Andy Coady, Environmental Control Officer, SBMWD Mr. Michael Plasencia, Environmental Control Technician, SBMWD Indirect/Direct User: Direct User Agency Area: San Bernardino Valley Municipal Water District, (SBVMWD) Agency Representative/s: Mr. Andy Coady, Environmental Control Officer, SBMWD Mr. Michael Plasencia, Environmental Control Technician, SBMWD Inspection Date: August 22, 2012, Scheduled Inspection EEC/PSI/Agency Inspector(s): Dr. John Parnell, Pretreatment Solutions, Inc. Mr. Najib Saadeh, Environmental Engineering & Contracting, Inc. Report Date: November 1, 2012 1.0 SCOPE AND PURPOSE On behalf of the Orange County Sanitary District (OCSD), Environmental Engineering & Contracting (EEC) performed an inspection of selected industrial users discharging into the Inland Empire Brine Line (IEBL; formerly known as the Santa Ana Regional Interceptor, SARI). This inspection is part of an audit of the pretreatment programs of the Santa Ana Watershed Project Authority (SAWPA) and its member agencies. To evaluate the performance of the pretreatment programs, industrial users were selectively inspected based on volume of wastewater discharged and/or industry type. The inspections were scheduled ahead of time with agency representatives. The agency representatives contacted the key personnel at the various facilities to confirm their availability and to describe the scope of the inspection and introduce the audit team. As part of the audit, all four liquid waste hauler (LWH) discharge stations within SAWPA’s service area were inspected. The current evaluation is one of a series of inspections of direct and indirect dischargers into the IEBL. Direct dischargers are typically close enough to construct a direct connection to the IEBL and produce enough waste to economically justify the connection cost. Indirect dischargers generate waste streams that are high in total dissolved solids and are not located close enough to the IEBL to make a direct connection. In general, the volume of wastewater discharged at LWH discharge stations varies. The quantity of liquid waste discharged at these stations can vary from one or two truckloads per week to 100,000 gallons per day in some cases. Liquid waste from indirect dischargers is disposed of at LWH discharge stations using a commercial liquid-waste hauler permitted by SAWPA. Industrial User Inspection Report: SBVMWD Liquid Waste Hauler Disposal Station November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 2 EEC On August 22, 2012, Environmental Engineering & Contracting, Inc. (EEC) completed a performance evaluation of the regulatory controls at the San Bernardino Valley Municipal Water District (SBVMWD) LWH Disposal Station. The discharge station is located inside the main gate on the grounds of the City of San Bernardino’s Wastewater Reclamation Plant (WRP) at 399 Chandler Place, San Bernardino, California 92408 (Appendix A, Site Photographs, Photo 1). The LWH discharge station is permitted by SBVMWD but is operated and managed by the City of San Bernardino Municipal Water Department (SBMWD). The inspection was conducted to evaluate whether SBVMWD has developed and implemented sufficient measures to ensure that discharges through the LWH discharge station in San Bernardino comply with the terms and conditions of all applicable agreements and regulations, including OCSD ordinances and 40 CFR 403. 1.1 General and Process Description The San Bernardino Valley Municipal Water District’s LWH discharge station provides a discharge point allowing indirect dischargers in the SBVMWD service area or any permitted LWH within the SAWPA service area to indirectly discharge wastewater into the IEBL. The LWH discharge station is located on the same property as the City of San Bernardino’s WRP and is composed of a concrete pad and a standalone office and storage complex with an overhanging roof area housing the hauler truck connection to the IEBL (Appendix A, Site Photographs, Photo 2). On the other side of the complex is a hauler truck connection to the septic line that leads directly into the WRP. The hauler truck connection to the IEBL consists of a square metal box structure with a valve and a hauler truck connector protruding from it. A red label affixed to the connector reads, “CAUTION BRINE LINE ONLY” and is referred to in the permit as Outfall 001 (Appendix A, Photos 3 and 4). The connection box is joined to a 6-inch lateral, which joins the IEBL at Reach IV-E. Access to the LWH discharge station is restricted. The truck driver must swipe a security card at the entrance gate and obtain verbal permission from a plant operator who will remotely operate the gate mechanism. A video camera mounted on a post inside the gate continuously monitors all vehicular activity through the access gate. Number plates can be recorded and verified by this means. The truck driver pulls up to the LWH discharge station and gives the three-section waste manifest to the plant operator. The plant operator is required to cross-check the names of the waste generator (Section 1 of the manifest) and the hauling company (Section 2 of the manifest) with a list of approved names pinned on the wall inside the office (Appendix A, Photo 5). Once the plant operator verifies that the generator and the hauler are approved to discharge, the plant operator instructs the truck driver to connect the truck’s discharge hose to the IEBL connector. The plant operator then briefly opens and closes the discharge valve to allow a sample of the wastewater to enter the metal box structure. The blue-colored automatic pH meter attached to the wall in the discharge bay reads the pH of the sample and the plant operator checks that the reading is between the 6.0 to 12.0 pH limit set by OCSD (Appendix A, Photo 6). If the pH is outside of the limit range, the plant operator refuses the load and calls the plant supervisor. The supervisor then issues a load reject notice and the other three LWH discharge stations are notified. If the pH is within the limits, the plant operator opens the discharge valve (red handle on Photo 4 of Appendix A) and allows the discharge to the IEBL to begin. A Mag Meter located inside the metal box records the flow rate on the display (center display) attached to the wall of the connection bay and a totalizer (top display) records the total discharge volume in gallons (Appendix A, Photo 6). Industrial User Inspection Report: SBVMWD Liquid Waste Hauler Disposal Station November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 3 EEC The plant operator then records the pH; the total flow volume; the operator’s name; the date; and the operator’s signature on Section 3 of the manifest (Appendix A, Photo 7). The white copy of the manifest is retained by the plant operator for SBMWD files, the yellow copy is sent to the LWH company, and the pink copy is to the generator. The truck driver then shuts the valve and disconnects the discharge hose and leaves the complex through the entrance gate, which opens automatically from the inside of the facility. In some instances, the control authority must collect extra samples of the wastewater discharge from some generators, in compliance with pretreatment regulations. In these cases, the plant operator is instructed which generator discharges to sample by SBVMWD or SBMWD. Records of sampling requirements and other details concerning permittees are written on a board in the plant operator’s office (Appendix A, Photo 8). SBVMWD issued a permit (No. 4E-05-S57) to SBMWD for emergency effluent discharges from the WRP to the IEBL. However, emergency discharges are allowed only after SAWPA and OCSD have been notified of the necessary emergency procedures. It was not ascertained if an emergency discharge has ever been necessary. By agreement with SAWPA, SBVMWD is responsible for the implementation of the pretreatment program for industries located in its jurisdiction. The SBVMWD is permitted to transport and discharge brine wastewater into the SBVMWD’s LWH Disposal Station, which is operated by the SBMWD. 1.2 Wastewater Sources The source of indirect wastewater discharged at the SBVMWD’s LWH Disposal Station is wastewater transported from all approved and permitted generators by all approved and permitted hauler companies. 1.3 Facility Process Wastewater Treatment System The wastewater is not treated at the SBVMWD LWH Disposal Station. Wastewater is pumped directly into the IEBL and does not undergo any treatment before it reaches the OCSD water treatment facility. 1.4 Wastewater Discharge The same wastewater that is received at the LWH discharge station is discharged to the IEBL without any treatment. 2.0 COMPLIANCE WITH FEDERAL CATEGORICAL STANDARDS The facility is not subject to any federal categorical standards. The facility is required to meet only the requirements specified in the permit issued by SBVMWD. 2.1 Compliance with Other Federal Pretreatment Requirements While the facility may not be subject to federal pretreatment requirements, limits that apply to dischargers with categorical standards also apply at this location. Industrial User Inspection Report: SBVMWD Liquid Waste Hauler Disposal Station November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 4 EEC 2.2 Compliance with Local Limits and Actions by the Agency The facility's most recent direct-user discharge permit (Permit No. 4E-04-S56) was issued to SBVMWD by SBVMWD. As is the case with all four LWH disposal stations within SAWPA’s service area, each member agency permits its own LWH discharge station. The station is operated and managed by SBVMWD. 3.0 SUMMARY OF FINDINGS 3.1 Overall, the SBVMWD LWH Disposal Station was observed to be clean and in good working order. 3.2 Copies of manifests were reviewed during the inspection. These manifests contained the pH readings and the total flow volumes for each discharge. The manifests were signed and dated by the plant operator and contained other details of the generator and the waste hauler company. The white copy of the manifest was retained by SBMWD, the yellow copy was retained by the waste hauler, and the pink copy was retained by the waste generator. No irregularities were detected with this manifest system, considering the gate-opening requirements and the pre- discharge checking for approved generators and haulers. It is the audit team’s opinion that this system is adequate in safeguarding the integrity of the discharges to the IEBL. 3.3 The pH meter and the flow meter were last calibrated by R.S. Instruments and Service on September 12, 2011, and were due for calibration again in September 2012. Annual calibration of the pH meter is insufficient, especially when considering the exposure of the pH probe to highly conductive wastewater. Calibration of the pH meter should refer to manufacturer’s specifications for this equipment, and more frequent calibration of the meter should be considered. 3.4 No samples of the wastewater discharged at the LWH discharge station are being collected for analysis by SBVMWD. Part 2A of the permit states that the permittee is not required to monitor wastewater to be discharged to the IEBL. The sampling that occurs at the discharge station is for generator compliance rather than SBVMWD’s monitoring. Sampling at the LWH discharge station is critical, and changes to the permit must be made to include a requirement for sampling and testing. The LWH discharge station’s compliance with the local limits to which it is subject must be demonstrated. Furthermore, in the case where more stringent categorical discharger limits apply, the LWH discharge station is also subject to these limits. Therefore, it is highly recommended that a regular or random sampling program at the LWH discharge station be implemented, in addition to the sampling at the loading point. Other member agencies have adopted procedures to sample LWH loads at the point of discharge into the IEBL. Once samples are collected, the control agency can then submit the samples for analysis based on suspected loads or random selection. In addition to monitoring compliance with local and categorical limits, the sampling of trucks loads at the LWH discharge stations is recommended because it raises the level of confidence that the LWH does not tamper with the load during transit. 3.5 The term liquid waste hauler (LWH) discharge station should be used throughout the permit and other documents because it better conveys that the station is only an intermediate destination before the wastewater is treated at OCSD’s treatment facility and subsequently released into the environment. Industrial User Inspection Report: SBVMWD Liquid Waste Hauler Disposal Station November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 5 EEC 3.6 The SBVMWD LWH discharge station’s most recent direct-user discharge permit (Permit No. 4E- 04-S56) was issued to SBVMWD by SBVMWD. In general, self-permitting is not recommended and does not always provide the desired control level to ensure compliance with regulatory controls. Should there be any questions regarding the contents of this inspection report, please contact Mr. Najib Saadeh by phone at (714) 667-2300 or by e-mail at nsaadeh@eecworld.com. Appendices: A. Site Photographs B. Direct User Discharge Permit No. 4E-04-S56 APPENDIX A SITE PHOTOGRAPHS Industrial User Inspection Report: SBVMWD Liquid Waste Hauler Disposal Station November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit A-1 EEC Photo 1 Entrance Gate to the San Bernardino Wastewater Reclamation Plant Photographed by John Parnell Photo 2 Liquid Waste Hauler Discharge Station Photographed by John Parnell Photo 3 Closer view of Discharge Station Connection Box Photographed by John Parnell Photo 4 Hauler Connection Point to IEBL Photographed by John Parnell Industrial User Inspection Report: SBVMWD Liquid Waste Hauler Disposal Station November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit A-2 EEC Photo 5 Lists of Permitted Users and Haulers on the wall in the Operator’s Office Photographed by John Parnell Photo 6 pH Controller and Mag Meter Equipment on wall of IEBL Connection Bay Photographed by John Parnell Photo 7 Manifest Form in Operator’s Office. Photographed by John Parnell Photo 8 Sampling Information on wall of Plant Operator’s Office. Photographed by John Parnell APPENDIX B DIRECT USER DISCHARGE PERMIT NO. 4E-04-S56 Industrial User Inspection Report Santa Ana Watershed Project Authority Audit Industrial User: Sierra Aluminum Company Industrial User Address: 2345 Fleetwood Drive, Riverside, CA 92509 Industrial User Permit Number: DS-001 Industrial User Representatives: Mr. Naro Kuch, Environmental Manager Mr. Randal Lunger, Production Supervisor Indirect/Direct User: Indirect Agency Area: Western Municipal Water District (WMWD) Agency Representatives: Mr. Benjamin Burgett, G & G, (Consultants to WMWD) Inspection Date: August 29, 2012, Scheduled Inspection EEC/PSI Inspectors: Dr. John R. Parnell, Pretreatment Solutions, Inc. Mr. Najib Saadeh, Environmental Engineering & Contracting, Inc. Report Date: November 1, 2012 1.0 SCOPE AND PURPOSE On behalf of the Orange County Sanitary District (OCSD), Environmental Engineering & Contracting (EEC) performed an inspection of selected industrial users discharging into the Inland Empire Brine Line (IEBL; formerly known as the Santa Ana Regional Interceptor, SARI). This inspection is part of an audit of the pretreatment programs of the Santa Ana Watershed Project Authority (SAWPA) and its member agencies. Industrial users were selectively inspected based on volume of wastewater discharged and/or industry type in order to evaluate the performance of the pretreatment programs. The current evaluation is one of a series of inspections of direct and indirect dischargers into the IEBL. Direct dischargers are typically close enough to construct a direct connection to the IEBL and produce enough waste to economically justify the connection cost. Indirect dischargers generate waste streams that are high in total dissolved solids and are not located close enough to the IEBL to make a direct connection. In general, the volume of wastewater discharged at liquid waste hauler (LWH) discharge stations varies. The quantity of liquid waste discharged at these stations can vary from one or two truckloads per week to 100,000 gallons per day in some cases. Liquid waste from indirect dischargers is disposed of at discharge stations using a commercial LWH permitted by SAWPA. On August 29, 2012, EEC completed a performance evaluation of the regulatory controls at the Sierra Aluminum Company (Sierra) facility located at 2345 Fleetwood Drive, Riverside. The facility is permitted and monitored by the Western Municipal Water District (WMWD; Appendix B, Indirect User Discharge Permit No DS-001). The inspection was conducted to evaluate whether Sierra has developed and implemented sufficient measures to ensure that discharges into the IEBL comply with the terms and conditions of all applicable agreements and regulations, including OCSD ordinances and 40 CFR 403. Industrial User Inspection Report: Sierra Aluminum Company November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 2 EEC 1.1 General and Process Description Sierra processes a mixture of primary aluminum ingots, scrap aluminum and secondary aluminum ingots in two industrial induction melting furnaces (Appendix A, Site Photographs, Photos 1 to 3). Liquid aluminum is poured into a vertical mold to form 22-foot-long aluminum logs by a process known as direct chill casting. The aluminum logs are then cut into shorter aluminum billets for use in one of three extrusion machines (Appendix A, Photo 4). Aluminum is extruded to form window and door frames for use in residential, commercial, and motorhome applications (Appendix A, Photos 5 and 6). No further processing, such as painting of parts or construction of window or door frames, is performed on-site. Currently, Sierra employs 130 workers. Approximately, a quarter of the employees work on a temporary basis. The plant has adopted three 8-hour shifts and operates 24 hours from Monday through Friday. No expansion of the business is anticipated in the next few years. The Sierra facility began discharging into the IEBL in 1992. 1.2 Wastewater Sources Process wastewater consists of cooling tower blowdown (from the direct chill casting process) and the direct-contact rinse water (used to clean the dies at the end of each production run; Appendix A, Photo 7). The wastewater discharged to the IEBL is therefore a mixture of rinse water from the die cleaning process, which is regulated by 40 CFR 467.36 (Core); cooling tower blowdown from the direct chill casting process, which is regulated by 40 CFR 467.36 (Direct Chill Casting Contact Cooling Water); and unregulated wastewater from the blowdown of cooling towers related to noncontact cooling water for the hydraulic oil in the extrusion machines. Wastewater used to quench a special aluminum alloy in the quench tank is not discharged to the IEBL. Reject reverse osmosis wastewater used for the special aluminum alloy and all domestic wastewaters are discharged directly to the City of Rubidoux sanitary sewer system. 1.3 Facility Process Wastewater Treatment System Wastewater streams from the various sources described above are mixed in the exterior 5,000-gallon waste tank. The evaporator has been removed from the system and final wastewater collects in the outside concentrated wastewater tank (Appendix A, Photo 8). A pH control system causes the wastewater mixture to precipitate out the solid aluminum hydroxide, which settles to the bottom of the tank. Periodically, this precipitate is drained from the bottom of the tank to a filter press that forms a nonhazardous sludge (Appendix A, Photo 9). The sludge is then transported off-site to a landfill. The connection system to the tanker trucks is located four feet above the bottom of the tank so that the wastewater hauled by HazMat Trans Hauling Company (HazMat) to the WMWD LWH discharge station is low in total suspended solids (TSS) (Appendix A, Photo 10). The removal of the aluminum hydroxide was introduced by Sierra in an effort to keep its wastewater disposal costs low. Industrial User Inspection Report: Sierra Aluminum Company November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 3 EEC 1.4 Wastewater Discharge Only the mixture of regulated wastewater streams from the die cleaning and direct chill casting processes and unregulated noncontact wastewater streams from the extruders is discharged to the IEBL. HazMat is the permitted hauler. 2.0 COMPLIANCE WITH FEDERAL CATEGORICAL STANDARDS The facility is correctly categorized as a Categorical Industrial User subject to 40 CFR Part 467 (Aluminum Forming Point Source Category), Subpart C, (Extrusion Subcategory) Paragraph 467.36 (Pretreatment Standards for New Sources; Existing Source for this category is prior to November 22, 1982). Pretreatment standards are production-based mass limits that are based on the wastewater discharge from the processing of 1 million pounds of aluminum. These standards are different for the core and direct chill casting processes described above. 2.1 Compliance with Other Federal Pretreatment Requirements The facility is a categorical industrial user (CIU) subject to a federal categorical standard and, therefore, is a significant industrial user. Like any industrial user, the facility must comply with pretreatment requirements in 40 CFR 403, including, but not limited to, federal prohibitions in 40 CFR 403.5 and reporting requirements in 40 CFR 403.12. 2.2 Compliance with Local Limits and Actions by the Agency The permit contains both OCSD-required local limits and calculated production mass limits as examples of the categorical standards found in 40 CFR 467.36. Each time the samples are collected the actual values of the categorical standards will be calculated using the analytical results, wastewater volumes, and production data supplied by the permittee for the 24-hour period covered by the sampling event. The sample point is a spigot located on the 5,000 gallon Concentrated Wastewater Tank. WMWD issued Permit # DS-001, Effective Date: July 26, 2011, Expiration Date: July 25, 2013. The permit was originally prepared by G & G Environmental Compliance, Inc., on behalf of WMWD. The permittee performs quarterly compliance sampling when the first load is hauled each quarter. WMWD also samples quarterly. Monthly sampling is performed for surcharge purposes only. The permittee is required to sample quarterly and monthly for production standards and surcharge parameters, respectively. The Eastern Municipal Water District performs the sampling and G & G Environmental Compliance, Inc., (G & G) performs the inspections on behalf of WMWD on a quarterly basis. G & G uses a spreadsheet to calculate the production limits based on flows and production numbers on the day the sample is collected. 3.0 SUMMARY OF FINDINGS 3.1 The Sierra facility was found to be in clean operating condition. No immediate problems were identified. Industrial User Inspection Report: Sierra Aluminum Company November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 4 EEC 3.2 The water treatment system was found to be in good operating condition. No immediate problems were identified. 3.3 Sierra’s indirect discharge permit has been approved for structure and content by both, SAWPA and OCSD. Since the indirect discharge to the IEBL and OCSD’s Wastewater Treatment Plant originates from the permittee’s categorical industrial processes, the Permit must contain both the Categorical Limits which apply at the end of process and OCSD’s local limits which apply at the end of pipe discharge point. In this instance, the sample point represents both end of process and end of pipe discharge. 3.4 The monthly sample for May 2011 was not submitted as required. As a result, a notice of violation (NOV) was issued to the facility on July 1, 2011. According to the monthly WMWD LWH discharge station reports submitted to SAWPA, the facility has since been in compliance since. 3.5 As indicated in the diagram included in the permit, the blowdown from the cooling towers that circulates noncontact cooling water to the extrusion presses (to cool the hydraulic fluid) is not subject to regulation. Only contact cooling water streams are subject to the federal regulation. Thus, the reference to heat treatment contact cooling water is incorrect in the permit. 3.6 Sierra is correctly identified as a CIU subject to 40 CFR 467.36 (Core and Direct Chill Casting Production Limits). 3.7 The reference to press heat treatment contact cooling water is incorrect in the spreadsheet and should be removed from the calculation. The heat treatment noncontact cooling water should be monitored and treated as a dilution flow, and a combined waste stream formula should be developed to calculate the applicable limits for the total combined flows from the two regulated sources. The spreadsheet needs to be revised to remove the incorrect data and calculate an appropriate combined waste stream formula. The permittee will have to monitor the flows from each of the three mixing streams to be used in the modified spreadsheet. There are no other categorical operations. 3.8 The sample point on the concentrated wastewater tank described in the permit is both end of pipe and end of process, so 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 the federal regulations; the current permit does not require that the local limits be sampled. 3.9 The 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 and grease analysis may be used instead of the TTO analysis. 3.10 The permit states that a TTO certification is required (presumably in lieu of sampling), but federal regulations do not contain this requirement. Industrial User Inspection Report: Sierra Aluminum Company November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 5 EEC 3.11 The formula used in the calculation of the combined waste stream should be included in the permit, along with an explanation of the various waste streams involved. Production numbers are based on the production of 5,000 gallons of wastewater in the discharge tank at the time of collection by HazMat. The process followed by the permittee for obtaining the production volume for each load is neither clear nor documented. 3.12 In the permit, Note 2 in the discharge limitation table explains what is meant by the average limit. The federal categorical limit should have been included in the table, but was erroneously omitted. G&G Environmental Compliance, Inc. calculates the limit for each regulated constituent by obtaining the production level for the 5,000 gallons of wastewater in the tank; it is not clear how the production number is obtained. 3.13 The actual federal categorical limit should have been included in the discharge limitation table of the permit. Furthermore, the method for the calculation of the categorical limit should be revised. 3.14 The diagram of the wastewater treatment system included in the permit should be modified to reflect the removal of the evaporator system. 3.15 No best management practices were noted. Should there be any questions regarding the contents of this inspection report, please contact Mr. Najib Saadeh by phone at (714) 667-2300 or by e-mail at nsaadeh@eecworld.com. Appendices: A. Site Photographs B. Indirect User Discharge Permit No. DS-001 APPENDIX A SITE PHOTOGRAPHS Industrial User Inspection Report: Sierra Aluminum Company November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit A-1 EEC Photo 1 Scrap aluminum processed at the plant Photographed by John Parnell Photo 2 Aluminum melting furnaces viewed from outside of building Photographed by John Parnell Photo 3 Aluminum melting furnaces viewed from inside of building Photographed by John Parnell Photo 4 Aluminum billets Photographed by John Parnell Industrial User Inspection Report: Sierra Aluminum Company November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit A-2 EEC Photo 5 Aluminum extruder Photographed by John Parnell Photo 6 Aluminum extruder showing formed window frame Photographed by John Parnell Photo 7 Top section of the direct chill casting chamber Photographed by John Parnell Photo 8 5,000-gallon waste tank Photographed by John Parnell Industrial User Inspection Report: Sierra Aluminum Company November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit A-3 EEC Photo 9 Sludge press Photographed by John Parnell Photo 10 Connection system to tanker truck and sample point Photographed by John Parnell APPENDIX B DIRECT USER DISCHARGE PERMIT NO. DS-001 Industrial User Inspection Report Santa Ana Watershed Project Authority Audit Industrial User: Western Municipal Water District Liquid Waste Hauler Discharge Station Industrial User Address: 2480 Railroad Street, Corona, California Industrial User Permit Number: 4B-06-S60 Industrial User Representative: Mr. Fred Kittfer, Western Municipal Water District Inspector Indirect/Direct User: Direct User Agency Area: Western Municipal Water District Agency Representative/s: Mr. Fred Kipfer, Western Municipal Water District Inspector Inspection Date: September 10, 2012 EEC/PSI Inspectors: Mr. Najib Saadeh, Environmental Engineering & Contracting, Inc. Report Date: November 1, 2012 1.0 SCOPE AND PURPOSE On behalf of the Orange County Sanitary District (OCSD), Environmental Engineering & Contracting (EEC) performed an inspection of selected industrial users discharging into the Inland Empire Brine Line (IEBL; formerly known as the Santa Ana Regional Interceptor, SARI). This inspection is part of an audit of the pretreatment programs of the Santa Ana Watershed Project Authority (SAWPA) and its member agencies. To evaluate the performance of the pretreatment programs, industrial users were selectively inspected based on volume of wastewater discharged and/or industry type. The inspections were scheduled in advance with agency representatives in charge. The agency representatives contacted the key personnel at the various facilities to confirm their availability and to describe the scope of the inspection and introduce the audit team. As part of the audit, all four liquid waste hauler (LWH) discharge stations within SAWPA’s service area were inspected. The current evaluation is one of a series of inspections of direct and indirect dischargers into the IEBL. Direct dischargers are typically close enough to construct a direct connection to the IEBL and produce enough waste to economically justify the connection cost. Indirect dischargers generate waste streams that are high in total dissolved solids and are not located close enough to the IEBL to make a direct connection. In general, the volume of wastewater discharged at LWH discharge stations varies. The quantity of liquid waste discharged at these stations can vary from one or two truckloads per week to 100,000 gallons per day in some cases. Liquid waste from indirect dischargers is disposed of at discharge stations using a permitted commercial LWH permitted by SAWPA. On September 10, 2012, EEC completed a performance evaluation of the regulatory controls at the liquid-waste collection station located at the City of Corona Water Reclamation Facility No. 1 (Appendix A, Site Photographs, Photo 1). The collection station is permitted, operated, and managed by the Western Municipal Water District (WMWD). The inspection was conducted to evaluate whether SAWPA has developed and implemented sufficient measures to ensure that discharges through the LWH Industrial User Inspection Report: Western Municipal Water District Liquid Waste Hauler Discharge Station November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 2 EEC discharge station in Corona comply with the terms and conditions of all applicable agreements and regulations, including OCSD ordinances and 40 CFR 403. 1.1 General and Process Description The sole purpose of the WMWD LWH station is to be a discharge point to allow indirect dischargers in the WMWD or any permitted LWH within the SAWPA service area to indirectly discharge wastewater into the IEBL. The discharge point is designated as Outfall 001 and consists of a 15-inch lateral connection from the LWH discharge station to the IEBL (Appendix A, Photos 2 and 3). Access to the station is restricted. Prior to entering the City of Corona Water Reclamation Facility No. 1, the LWH truck driver must enter a security code to open the main entrance gate (Appendix A, Photos 4 and 5). Once inside the facility, the truck driver must enter another security code on the Programmable Logic Control (PLC) and stamp the date and time of entry on the manifest (Appendix A, Photo 6). A unique security code is assigned to each LWH company. The system provides a record of each waste load and the date and time the code is entered. The valve to the IEBL then opens and the driver starts discharging the load into the manhole. The valve allowing flow into the IEBL is designed to stay closed unless a recognized code is entered by an authorized LWH (Appendix A, Photo 7). After every discharge, fresh water automatically flushes the line and cleans the pH probe. If the pH meter detects a pH value outside the permitted range of 6.0 to 12.0, the valve will close, an alarm will sound, and a red light will start flashing (Appendix A, Photo 8). If the pH of a load is detected to be outside of the permitted range, the LWH is issued a Rejected Load Notice and all member agencies are immediately notified. Storm water collects around Outfall 001 but water cannot flow into the IEBL as long as the automatic valve remains closed. Once the truck is emptied, the driver deposits the manifest in a designated receptacle (Appendix A, Photo 9). A WMWD representative collects the manifests at the beginning and at the end of each week and delivers them to G&G Environmental Compliance, Inc. (G&G). WMWD has retained G&G to assist in managing WMWD’s pretreatment program related to the IEBL. When preparing the monthly invoice for each indirect user, G&G personnel verify that for each discharge, the corresponding manifest is accounted for. Instructions for operating the valve are posted in English and Spanish next to the PLC board inside the facility (Appendix A, Photo 10). Procedures for sampling and testing of discharged wastewater do not include any sampling of loads at the point of discharge. Samples are collected only at the site from which the wastewater originates. The service area of the WMWD collection station in Corona comprises the area under the jurisdiction of the WMWD. By agreement with SAWPA, WMWD is responsible for the implementation of the pretreatment program for industries located in its jurisdiction and permitted to transport and discharge brine wastewater into the LWH discharge station. The industries currently permitted to transport wastewater to the WMWD LWH discharge station are listed under Attachment A of the Direct User Discharge Permit for the WMWD LWH discharge station (Appendix B, Direct User Discharge Permit No. 4B-06-S60). Industrial User Inspection Report: Western Municipal Water District Liquid Waste Hauler Discharge Station November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 3 EEC 1.2 Wastewater Sources The source of the wastewater is the wastewater transported by the LWHs and discharged at Outfall 001. 1.3 Facility Process Wastewater Treatment System The wastewater is not treated at the LWH discharge station. It flows by gravity through the IEBL and does not undergo any treatment before it reaches the OCSD water treatment facility. 1.4 Wastewater Discharge The same wastewater that is received at the LWH discharge station is discharged into the IEBL without any treatment. 2.0 COMPLIANCE WITH FEDERAL CATEGORICAL STANDARDS The facility is not subject to any federal categorical standards. The facility is required to meet only the requirements specified in the permit issued by WMWD. 2.1 Compliance with Other Federal Pretreatment Requirements While the facility may not be subject to federal pretreatment requirements, limits that apply to dischargers with categorical standards also apply to this location. 2.2 Compliance with Local Limits and Actions by the Agency The facility’s most recent direct-user discharge permit (Permit No. 4B-06-S60) was issued to WMWD by WMWD. As is the case with all four liquid-waste collection stations within SAWPA’s service area, each member agency permits and monitors its own collection station. 3.0 SUMMARY OF FINDINGS 3.1 Overall, the WMWD LWH discharge station at the City of Corona Water Reclamation Facility No. 1 was observed to be clean and in good working order with one exception (see Section 3.2 below). 3.2 During 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. 3.3 In the WMWD permit, the facility where the LWH discharge 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.” 3.4 No documentation was provided verifying that the automatic valve would close if the pH value were 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. Industrial User Inspection Report: Western Municipal Water District Liquid Waste Hauler Discharge Station November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 4 EEC 3.5 No documentation was provided verifying the proper operation of software at the LWH discharge station. Part 1, I of the permit requires that WMWD submit a quarterly report to SAWPA verifying the proper functioning of the software. According to SAWPA, the City of Corona staff monitors the software performance but the monitoring is not documented. 3.6 No documentation was provided as evidence that WMWD is conducting annual training for all of the permitted liquid-waste haulers. Part 1, L of the permit requires that WMWD review and conduct annual training for all permitted LWHs to review the safeguards, procedures, and recordkeeping requirements. SAWPA provided a list of the attendees at a meeting/training held on April 23, 2009. SAWPA also informed EEC that new LWHs receive individual training at their primary LWH discharge station, but no records of such training were provided. 3.7 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. SAWPA provided quarterly field service reports for the calibration of a pH meter but the reports are all dated October 2, 2012, for service performed in October 2011, January 2012, April 2012, and July 2012. The reports indicate that the work was performed for the City of Corona’s Department of Water and Power and the billing address used is the actual address for the City of Corona’s Department of Water and Power offices. Furthermore, the Certificates of Instrument Performance corresponding to the service reports are not signed by an authorized service representative. As for the flow meter calibration, SAWPA provided three flow meter verification certificates, but the certificates were not dated or signed. The certificates require two signatures: one from the operator and one from the inspector; however, the certificate was not signed by either party. 3.8 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 finally 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. Manifests must be better protected at the collection station to avoid the loss of or damage to manifests. 3.9 No samples of the wastewater discharged at the LWH station are being collected. Part 2 of the permit states, “permittee is not required to monitor wastewater to be discharged to the IEBL System.” However, sampling at the LWH station is essential and changes to the permit must be made to make sampling and testing a requirement. The LWH station is subject to local limits and compliance with these limits must be demonstrated. Furthermore, the LWH station is also subject to more stringent limits, where they apply, for categorical dischargers. Therefore, in addition to the sampling at the loading point, a regular or random sampling program at the LWH station must be implemented. Other member agencies have adopted procedures to sample LWH loads at the point of discharge into the IEBL. Once samples are collected, the control agency can then submit the samples for analysis based on suspected loads or random selection. In addition to monitoring compliance with local and categorical limits, sampling of wastewater on trucks at the LWH stations increases confidence that the LWH does not tamper with the load during transit. Industrial User Inspection Report: Western Municipal Water District Liquid Waste Hauler Discharge Station November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit 5 EEC 3.10 Under the Permit Special Conditions Part 5.D.3, the Dart Container Corporation is required to immediately notify WMWD of any concerns or issues. Dart Container Corporation is a permitted direct discharger located approximately 1.0 mile from the LWH discharge station. It appears that the direct discharge permit was prepared using Dart Container Corporation’s industrial user permit as a template, rather than a clean template, and not all required changes were made. 3.11 Terms referring to the station are not consistent throughout the permit document. Typically, “collection station” is used, but at least in one instance the term “truck dump station” was used. Furthermore, instructions posted on-site, such as valve operating instructions and emergency contact information, refer to the station as “dump station” or “truck dump station.” The term “liquid waste hauler discharge station” should be used throughout because it better represents that the station is only an intermediate destination before the wastewater is treated at OCSD’s treatment facility and subsequently released into the environment. The term dump is more suitable for waste destined for a landfill and does not relay the importance of compliance to ultimately protect both the IEBL and the OCSD water treatment facility. 3.12 The WMWD LWH discharge station’s most recent direct-user discharge permit (Permit No. 4B- 06-S60; Appendix B) was issued to WMWD by WMWD. In general, self-permitting is not recommended and, as reflected in the findings described above, does not always provide the desired control level to ensure compliance with regulatory controls. In addition, no records of quarterly monitoring of the collection station were submitted as required in Part 3.B of the permit. Should there be any questions regarding the contents of this inspection report, please contact Mr. Najib Saadeh by phone at (714) 667-2300 or by e-mail at nsaadeh@eecworld.com. Appendices: A. Site Photographs B. Direct User Discharge Permit No. 4B-06-S60 APPENDIX A SITE PHOTOGRAPHS Industrial User Inspection Report: Western Municipal Water District Liquid Waste Hauler Discharge Station November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit A-1 EEC Photo 1 City of Corona Water Reclamation Facility No. 1 Photographed by Najib Saadeh Photo 2 Outfall 001 and truck designated unloading location Photographed by Najib Saadeh Photo 3 Closer view of Outfall 001 Photographed by Najib Saadeh Photo 4 View of main entrance gate from inside facility Photographed by Najib Saadeh Industrial User Inspection Report: Western Municipal Water District Liquid Waste Hauler Discharge Station November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit A-2 EEC Photo 5 PLC board at main entrance Photographed by Najib Saadeh Photo 6 PLC board inside facility with adjacent date/time stamper Photographed by Najib Saadeh Photo 7 Valve to the brine line Photographed by Najib Saadeh Photo 8 Alarm system Photographed by Najib Saadeh Industrial User Inspection Report: Western Municipal Water District Liquid Waste Hauler Discharge Station November 1, 2012 W2422.01T Santa Ana Watershed Project Authority Audit A-3 EEC Photo 9 Manifest collection location Photographed by Najib Saadeh Photo 10 Valve operating instructions Photographed by Najib Saadeh APPENDIX B DIRECT USER DISCHARGE PERMIT NO. 4B-06-S60