Transcription

Standard Operating ProcedureforWriting PCA and PCI ReportsPG EnvironmentalCreated on behalf of the California State Water Resources ControlBoardApril 2019

Table of ContentsPart I: Introduction .1Part II: Report Template and Instructions .2i

AppendicesAppendix AAppendix BAppendix CExample PCA ReportExample PCI ReportBlank PCA Report Formii

Part I: IntroductionA. Purpose of the Standard Operating Procedure (SOP)This document outlines the process for developing summary reports to accurately recordfindings from Pretreatment Compliance Audits (PCAs) and Pretreatment ComplianceInspections (PCIs). Summarizing the findings from a PCA or PCI provides effectivefeedback to the publicly-owned treatment works (POTW) regarding the effectiveness of, andcompliance with, its approved pretreatment program. Using the report template provided inthis SOP will allow the report writer to concisely summarize a POTW’s program. The reporttemplate also provides regulatory citations applicable to each required component of thepretreatment program. This document does not cover procedures for auditing or inspecting aPOTW’s pretreatment program; detailed information on how to conduct a PCA or PCI can befound in EPA’s 2010 Guidance titled Control Authority Pretreatment Audit Checklist andInstructions 1. This SOP includes a report template and instructions to complete the template(Part II), an example PCA report (Appendix A), an example PCI report (Appendix B), and ablank PCA/PCI Report Form (Appendix C).B. Overview of the Reporting ProcessAs noted in the Control Authority Pretreatment Audit Checklist and Instructions, PCA andPCI follow-ups center on preparing the report and identifying the actions necessary to ensurethe POTW’s program is effective and compliant. The auditor should analyze the data asquickly as possible and draft the report so that it can be transmitted to the Control Authority(usually the POTW) in a timely manner. The auditor/inspector should also enter any WaterEnforcement National Data Base (WENDB), Required ICIS Data Element (RIDE), andReportable Non-Compliance (RNC) data, as appropriate, in the Integrated ComplianceInformation System (ICIS) database.C. Contents of the SOPPart II of this SOP describes how the report template is to be used. It provides instruction oncompleting specific sections of the report, as well including sample language. More detailedsample report language is provided as Appendix A (example PCA report) and Appendix B(example PCI report) of this SOP. Appendix C includes a Blank PCA Report Form, that canbe modified into a PCI Report Form.1See https://www3.epa.gov/npdes/pubs/final pca checklist and instructions %20feb2010.pdf1

ACRONYM AND ABBREVIATION LISTAcronym/AbbreviationTermAAAOApproval AuthorityAdministrative OrderBMPBest management practicesBMRBaseline Monitoring ReportCAControl AuthorityCERCLAComprehensive Environmental Remediation, Compensation and Liability ActCFRCode of Federal RegulationsCIUCategorical Industrial UserCSOCombined sewer overflowCWAClean Water ActCWFCombined Wastestream FormulaDMRDischarge Monitoring ReportDSSDomestic Sewage StudyEPExtraction ProcedureEPAU.S. Environmental Protection AgencyERPEnforcement Response PlanFDFFundamentally different factorsFTEFull-time equivalentFWAFlow-Weighted AveragegpdGallons per dayICISIntegrated Compliance Information SystemIUIndustrial UserIWSIndustrial Waste SurveyMGDMillion gallons per dayMSWMunicipal solid wasteN/ANot applicableNDNot determinedNOVNotice of ViolationNPDESNational Pollutant Discharge Elimination SystemNSCIUNonsignificant Categorical Industrial UserO&GOil and grease2

ACRONYM AND ABBREVIATION LIST t Implementation Review Task ForcePOTWPublicly owned treatment worksQA/QCQuality assurance/quality controlRCRAResource Conservation and Recovery ActRIDERequired ICIS Data ElementRNCReportable NoncomplianceSIUSignificant Industrial UserSNCSignificant NoncomplianceSUOSewer Use OrdinanceTCLPToxicity Characteristic Leachate ProcedureTMDLTotal maximum daily loadTOMPToxic Organic Management PlanTRCTechnical Review CriteriaTRETechnical Review EvaluationTRISToxics Release Inventory SystemTSDFTreatment, Storage, and Disposal FacilityTTOTotal toxic organicsUSTUnderground Storage TankWENDBWater Enforcement National Data BaseY/NYes or no3

Common Terms and Phrases:Control AuthorityThe POTW, if the POTW's Submission for its Pretreatment ProgramSubmission has been approved in accordance with the requirements of §403.11; or the Approval Authority, if the Submission has not beenapproved. It is the entity that regulates IUs and can mean the EPA, State,or POTW.Approval AuthorityThe Director in an NPDES State with an approved State pretreatmentprogram and the appropriate Regional Administrator in a non-NPDESState or NPDES State without an approved State pretreatment program. Itis the entity that oversees CAs; can mean the EPA or the State.InterferenceA Discharge which, alone or in conjunction with a discharge or dischargesfrom other sources, both:(1)Inhibits or disrupts the POTW, its treatment processes oroperations, or its sludge processes, use or disposal; and(2)Therefore, is a cause of a violation of any requirement of thePOTW's NPDES permit (including an increase in the magnitude orduration of a violation) or of the prevention of sewage sludge useor disposal in compliance with certain statutes and regulationsPass ThroughA Discharge which exits the POTW into waters of the United States inquantities or concentrations which, alone or in conjunction with adischarge or discharges from other sources, is a cause of a violation of anyrequirement of the POTW's NPDES permit (including an increase in themagnitude or duration of a violation).4

Part II: Report Template & Instructions5

Pretreatment Compliance AuditSummary ReportRed font indicates instructions on how to complete the section; blue font indicates the language isspecific to an audit and will need to be modified or deleted if the template is being used for aninspection report (for example, audit, auditor, or PCA would be replaced with inspector,inspection, or PCI); sky blue font indicates explanatory comments, example language is in italics.Example language is not provided in this document for every section of the report. A completedexample report is provided as Attachment A (PCA) and Attachment B (PCI) of this SOP.NOTE: This template is for a PCA; to use the template for a PCI, change the words “audit” and“auditor” to “inspection” and “inspector,” respectively, and remove Part D, Legal AuthorityReview, and Attachment B. The report template follows the order of the audit checklist (and PCIchecklist with acknowledgement that the Legal Authority section does not apply).Discharger:Facility NameNPDES Permit No. CAxxxxxxxxCountyLocation:Street address. If physical address and mailing address are different, listboth and identifyContact:List primary contacts from the POTW that took part in the PCA; includeeach contact’s name and titleAudit Dates:Month, Day, YearAudited By:List all participants and identify affiliation (State, EPA, Contractor)6

AttachmentsAttachment AAttachment BAttachment XAttachment XIndustrial User Site Visit Data SheetsLegal Authority Review Checklist [This Attachment is for PCAs only][Name of Industry] Discharge Permit (if the only document you need toreference to support findings is the industrial user permit, use this format.)Nondomestic Discharger Information: [Name of Industry] (If you have sampledata, an inspection report, permit application, enforcement correspondence, etc.,that is necessary to support one of your findings, then use this 2nd option. Nameeach document as X-1, X-2. They don’t have to be listed individually here, butwould need to provide each with the report. This would include anydocumentation from the file review necessary to support report findings:discharge permit, SMRs, enforcement documentation, etc.)Note that the ICIS/WENDB and RNC worksheets completed as part of the PCA or PCI shouldnot be forwarded to the POTW as part of the report. It is not necessary to share them with thePOTW as they are tools for use by the Approval Authority (State or EPA) to insure programelements are entered into ICIS.7

I. Audit SummaryThe intent of this section is to give a very general summary of the activities that occurred. It should belimited to the identification of the audit/inspection team, the POTW contact, and a list of facilities forwhich file reviews and site visits were conducted. In addition, you can use this section to denote whenthe last PCI or PCA was conducted.Upon arrival, Water Board/Regional Water Board auditors [insert auditor(s) name] (Audit Team), metwith the City of [insert POTW name] (City’s or Control Authority’s) contact, (inert name of POTWcontact). The Audit Team discussed the purpose and format of the audit and interviewed the Cityrepresentative about the City’s pretreatment program. The Audit Team also evaluated [Remove thisstatement for a PCI] the City’s implementation procedures, enforcement response plan, and legalauthority. [Note that Audit or Auditor would be replaced with Inspection or Inspector for PCIs. Forsite visits, it’s imperative to distinguish between the City inspector and State inspector.]As part of the audit, the Audit Team reviewed the following files: Industry A (categorical industrial user [CIU] subject to 40 CFR 469.18 and 433.17) Industry B (Non-categorical significant industrial user [SIU])The Audit Team conducted inspections at the following SIUs: Industry A (CIU subject to 40 CFR 469.18 and 433.17) Industry B (Non-categorical SIU)The last review of the City’s pretreatment program was a pretreatment compliance audit (PCA)performed on May 25-26, 2016.8

II. Program DescriptionThis section is used to provide a summary of the POTW’s program. Include information on the size ofthe wastewater treatment facility, treatment provided, population serviced, and general numbers ofCIUs and SIUs (detailed breakdown is covered in the Section III). Use this section to discuss on-goingor recent violations and the current status toward resolution.The City owns and operates the [insert name] Wastewater Treatment Plant [WWTP] which serves apopulation of approximately 55,000. The City implements the pretreatment program that regulates 7SIUs in the City of [insert name] and [insert name of contributing agency/agencies if applicable]. Atthe time of the PCA, the City’s pretreatment program was being managed by the Chemist at theWWTP. The City was looking to hire a Water Resources Technician, the position intended to managethe City’s pretreatment program, which had been vacant since October 2016.The WWTP’s design capacity is 5 million gallons per day (MGD) and the average influent flow to theWWTP is between 2.5 and 3 MGD. The WWTP provides secondary treatment which consists of a gritremoval system, denitrification, an oxidation ditch, three clarifiers, ultraviolet disinfection, and asecondary equalization tank. The biosolids are hauled offsite by [insert company name].The City violated its NPDES permit in 2017 by exceeding its un-ionized ammonia discharge limit. Theviolation was traced back to probes that were not properly calibrated and was not caused bynondomestic dischargers.III. Industrial User (IU) CharacterizationUse this section to quantify the industrial dischargers subject to regulation by the City. Note that zerodischarging CIUs are not included in the set of SIUs. While the discharge permits should specify forthese facilities which regulation they are governed by, they should not be included in the reported totalof SIUs.IUs currently identified byIU Typethe Control Authority (CA)7Discharging Significant Industrial Users6Discharging Non-Categorical SIUs (as defined by the CA)1Categorical Industrial Users (CIUs)0Middle Tier CIUs0Zero-Discharging CIUs0Non-significant CIU (NSCIU)Other Regulated IUs (e.g. permitted IUs)0Describe: This could include groundwater remediation sites, foodservice establishments (FSEs), etc.Waste Haulers2Describe: List types of hauled waste the POTW allows. [septage,grease, recreational vehicle, leachate, etc.]9

IV. Findings Summary TableThis Section lists specific requirements and recommendations from the various questions addressed inSection V. By referencing the specific subsection, as shown here (‘C.4.a’), the reader knows where togo in the report to get more detail about a specific requirement or recommendation. The columns tothe right identify the finding by number, as they appear in the report. You will see in the samplereport that the Requirements are numbered separately from the Recommendations.Part V Section Reference – FindingC.4.a - The David’s Pinot Vineyard permit does not includethe 24-hour notification of violation and resamplingrequirement.C.4.b - The Raytheon permit does not include theapplicable federal pretreatment category.D.2.b - The sewer use ordinance (SUO) does notadequately define “significant 12V. EvaluationThis Section is a concise version of the information documented in the PCA/PCI checklist while onsite. Instructions on how to complete the PCA checklist can be found at the link provided in Part I ofthis document. Where a deficiency has been identified, the writer should include the Finding (seeexample in Section C.4.a below), any applicable regulatory citation, the identification of Requirementor Recommendation, and any corrective action necessary. Please note inclusion of a regulatorycitation is mandatory for deficiencies identified as Requirements, but not for Recommendations.The following sections describe program deficiencies and areas of concern identified during the auditprocess along with requirements, recommendations, and associated references to 40 CFR Part 403.A. CA Pretreatment Program Modification1. When was the last program modification? Did the CA notify the EPA of programmodifications? (40 CFR 403.18)B. IU Characterization1. Describe the CA’s procedure for identifying and locating IUs that might be subject to thepretreatment program. Has the CA identified and located all applicable IUs (non-categoricalSIUs, CIUs, NSCIUs, etc.)? (40 CFR 403.8(f)(2)(i))2. Has the CA identified the character and volume of pollutants contributed to the publiclyowned treatment works (POTW) by IUs subject to the pretreatment program?(40 CFR 403.8(f)(2)(ii))10

The City appears to have adequate knowledge regarding the character and volume of pollutantsdischarged to the WWTP by industrial users currently regulated by the City. The City is conductingannual inspections and sampling at its SIUs.3. Has the CA prepared and maintained a list of SIUs, as defined in 403.3(v)(1), along with theapplicable SIU criteria? Does the list indicate whether the CA has made a determinationthat an SIU is a NSCIU, as defined in 403.3(v)(2), rather than an SIU? Have modifications tothe list been submitted with annual reports?(40 CFR 403.8(f)(6))Yes, the City maintains a current list of SIUs which is included in the annual pretreatment programreport submitted to the Approval Authority. The list includes the SIU name, address, SIU permit numberand expiration date, compliance status, last inspection date, and last monitoring date.The City had not classified any nondomestic dischargers in the service area as NSCIUs at the time ofthe audit.C. Control Mechanism Evaluation1. Has the CA issued individual or general control mechanisms to all SIUs?(40 CFR 403.8(f)(1)(iii))2. Do the applications for general control mechanism contain all of the following?(40 CFR 403.8(f)(1)(iii)(A)(2))a.b.c.d.e.Contact infoProduction processesTypes of wastes generatedLocation for monitoringAny request for waiver for pollutants not present per 40 CFR 403.12(e)(2)3. Are general control mechanisms only issued for IUs where all of the following is true?(40 CFR 403.8(f)(1)(iii)(A)(1))a.b.c.d.e.Involve same/substantially similar types of operationsDischarge the same type of wasteSame effluent limitationsSame or similar monitoringThere are no CIU production-based standards, CIU mass limits, combined wastestreamformula, or net/gross calculations4. Do both individual and general control mechanisms include the following, where applicable?(40 C.F.R. §403.8(f)(1)(iii)(B))11

a. Statement of duration (5 years max)b. Statement of non-transferabilityc. Applicable effluent limits (local limits, categorical standards, best management practices(BMPs))d. Self-monitoring requirements Identification of pollutants to be monitored Sampling frequency Sampling locations/discharge points Appropriate sample types Reporting requirements Record-keeping requirementse. Statement of applicable civil and criminal penaltiesf. Compliance schedulesg. Notice of slug loading or potential problems at POTWh. Notification of spills, bypasses, upsets, etc.i. Notification of significant change in dischargej. 24-hour notification of effluent violationk. Submit resampling results within 30-daysl. Slug discharge control plan requirement, if required by POTWm. Certification statementsn. Sampling/analysis requirements (Part 136 or alternative)o. Reporting of additional samplingp. 90-day compliance reportFinding C.4.a – The David’s Pinot Vineyard permit does not include the 24-hour notification ofviolation and resampling requirement.Regulatory RequirementsThe federal regulations at 40 CFR 403.8(g)(2) require the permit to include the requirement for SIUs tonotify the CA within 24 hours of becoming aware of violations and to resample and submit resultswithin 30 days of becoming aware of the violation.Requirement 1The City is required to revise the David’s Pinot Vineyard permit to include the 24-hour notification andresampling requirement.Finding C.4.b – The Raytheon permit does not include the applicable federal pretreatment category.The Raytheon permit indicates that the facility is subject to 40 CFR 469.18 and 433.17. However, basedon the processes conducted at the facility, the applicable pretreatment category is only 40 CFR 469.18.The processes regulated under 40 CFR 433.17 do not apply to the facility because the metal finishingoperations occurring at the facility are integral to the process regulated under 40 CFR 469.18occurring at the facility.Regulatory Requirements12

The federal regulations at 40 CFR 403.8(f)(1)(iii)(B)(3) require permits to include effluent limits basedon applicable general pretreatment standards, categorical pretreatment standards, local limits, andstate and local law.The federal regulations at 40 CFR 433.10(b) indicate that if a facility is subject to the electrical andelectronic components categorical pretreatment standards and the other categories listed under 40CFR 433.10(b), then the 40 CFR Part 433 limits will not apply.Requirement 2The City is required to revise the Raytheon permit to indicate the federal pretreatment category andstandards applicable to the facility.Recommendation 1The Audit Team recommends that the City continue to monitor for the 433.17-regulated parameters toensure that Raytheon is compliant with the City’s local limits for those pollutants of concern.D. Legal Authority [For a PCI report, delete Section D, and rename Sections E-H as D-G]1. Does the SUO provide the CA adequate legal authority, consistent with 40 CFR 403.8(f)(1)?2. Are there any contributing jurisdictions discharging wastewater to the POTW? Does the CAhave an agreement in place that addresses pretreatment program responsibilities?3. What is the CA’s definition of significant noncompliance (SNC)?(40 CFR 403.8(f)(2)(viii))E. Application of Pretreatment Standards and Requirements1. Does the CA apply all applicable pretreatme