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
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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.
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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;
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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.
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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,
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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.
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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
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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.
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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
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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
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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:
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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.
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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).
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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.
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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
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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
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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
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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.
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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.
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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.
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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.
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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.
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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.
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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
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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.
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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;
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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.
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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;
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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.
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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.
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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.
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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.
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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.
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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.
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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:
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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.
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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
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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.
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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.
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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
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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
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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
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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.
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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
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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)
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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