1 / 23

Pretreatment Annual Reports and Significant Noncompliance

Pretreatment Annual Reports and Significant Noncompliance. EPA Region VI Pretreatment Workshop Breakout Session #10 August 4, 2010. Annual POTW Reports [40 CFR § 403.12(i)]. POTWs with an approved pretreatment program are required to submit a report to the Approval Authority

franz
Télécharger la présentation

Pretreatment Annual Reports and Significant Noncompliance

An Image/Link below is provided (as is) to download presentation Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript

  1. Pretreatment Annual Reports and Significant Noncompliance EPA Region VI Pretreatment Workshop Breakout Session #10 August 4, 2010

  2. Annual POTW Reports[40 CFR § 403.12(i)] • POTWs with an approved pretreatment program are required to submit a report to the Approval Authority • Must include the POTW’s program activities • Includes all participating agencies (i.e. customer cities, multijurisdictional partners) • Shall be submitted annually

  3. Annual POTW Reports[40 CFR § 403.12(i)] • Updated list of IUs • Summary of IU compliance • Summary of compliance and enforcement actions taken • Summary of changes • Any other relevant information

  4. Updated list of IUs[40 CFR § 403.12(i)(1)] • Include an updated list of: • SIUs, • CIUs, and • IUs • Subject to reduced reporting requirements and • Non-significant CIUs (NSCIUs)

  5. Updated list of IUs[40 CFR § 403.12(i)(1)] • Need to include: • Name and addresses OR • List of deletions and additions keyed to a previously submitted list. • Provide an explanation of each deletion

  6. Updated list of IUs[40 CFR § 403.12(i)(1)] • The list shall identify: • which IUs are subject to categorical pretreatment standards and • specify which standards are applicable to each IU (i.e., 40 CFR 433.15, etc.)

  7. Summary of IU compliance[40 CFR § 403.12(i)(2)] • Need to include the status of IU compliance over the entire reporting period (i.e., pretreatment year)

  8. Summary of Compliance and Enforcement Actions Taken[40 CFR § 403.12(i)(3)] • Need to include a summary of all compliance and enforcement actions taken • Inspections conducted by the POTW at each facility • Sampling conducted by the POTW at each facility • Does not include sampling conducted by the SIU

  9. Summary of Changes[40 CFR § 403.12(i)(5)] • Include a summary of all changes to the approved pretreatment program not previously submitted to the Approval Authority • Strongly recommend that all modifications be submitted separately

  10. Any other Relevant Information Required[40 CFR § 403.12(i)(5)] • Pretreatment Performance Summary (PPS) Form • Need to include any additional information may requested in your NPDES permit and Approval Authority

  11. PRETREATMENT PERFORMANCE SUMMARY (PPS) I. General Information Control Authority Name____________________________________ Address _____________________________________________________________________ City State/Zip __________________________________________ Contact Person __________________________ Position ____ _____________________ Contact Telephone ___________ __ NPDES Permit Nos. __ ____________________ • Reporting Period ______________________ _________________________ • (Beginning Month and Year) (Ending Month and Year) Total Number of Categorical IUs ___________ Total Number of Significant Noncategorical IUs ___________ Total Number of Non-Significant (yet permitted) IUs _____ ____ II. Significant Industrial User Compliance SIGNIFICANT INDUSTRIAL USERS Categorical NonCategorical 1) No. of SIUs Submitting BMRs / Total No. Required. . . . . . . . . . . . . . . . / N/A 2) No. of SIUs Submitting 90-Day Compliance Reports / No. Required. . . . . . . / N/A 3) No. of SIUs Submitting Semiannual Reports / Total No. Required. . . . . . . . . . . / / 4) No. of SIUs Meeting Compliance Schedule / Total No. Required to Meet Schedule . . . . / / 5) No. of SIUs in Significant Noncompliance / Total No. of SIUs . . . . . . . . . . . . / / 6) Rate of Significant Noncompliance for all SIUs (categorical and noncategorical) . . %

  12. III. Compliance Monitoring Program • SIGNIFICANT INDUSTRIAL USER • CategoricalNonCategorical • 1) No. of Control Documents Issued / Total No. • Required. . . . . . . . . . . . . . . . . . / / • 2) No. of Nonsampling Inspections Conducted. . • 3) No. of Sampling Visits Conducted. . . . . . • 4) No. of Facilities Inspected (nonsampling) . • 5) No. of Facilities Sampled . . . . . . . . . ____ _ • IV. Enforcement Actions • SIGNIFICANT INDUSTRIAL USERS • CategoricalNonCategorical • 1) No. of Compliance Schedules Issued / No. • of Schedules Required . . . . . . . . . . / / • 2) No. of Notices of Violations Issued to SIUs ______ • 3) No. of Administrative Orders Issued to SIUs • 4) No. of Civil Suits Filed. . . . . . . . . . ______ • 5) No. of Criminal Suits Filed . . . . . . . . ______ • 6) No. of Significant Violators (attach • newspaper publication). . . . . . . . . . . ______ • 7) Amount of Penalties (not surcharges) • Collected (total dollars / IUs assessed) . . . / / • 8) Other Actions (sewer bans, etc.). . . . . . • The following certification must be signed in order for this form to be considered complete: • I certify that the information contained herein is complete and accurate to the best of my knowledge. • Authorized Representative Date ________________ • Page 2

  13. Noncompliance Industrial Users - Enforcement Actions Taken Reporting month/year: __________, ____ to __________, ____ TPDES Permit No: _____________Permittee:_____________Treatment Plant: ____________ Overall SNC ___% SNC 10 based on: Effluent Violations____% Reporting Violations____% Narrative StandardViolations___% • 10# % • Pretreatment Standards [WENDB-PSNC] (Local Limits/Categorical Standards) • Reporting Requirements [WENDB-PSNC] • Narrative Standards • Please specify a separate number for each type of violation, e.g. report, notification, and/or NSCIU certification.

  14. PRETREATMENT PROGRAM STATUS REPORT UPDATED SIGNIFICANT INDUSTRIAL USERS LIST

  15. ENFORCEMENT ACTIONS TAKEN

  16. MONITORING RESULTS FOR THE ANNUAL PRETREATMENT REPORT REPORTING YEAR: __________, 20 TO __________, _20____ TREATMENT PLANT: City of ____ NPDES PERMIT #AR00____ _____ AVERAGE POTW FLOW: MGD % IU FLOW: % NUMBERSDERIVED BY ADEQ OR CONSULTANT

  17. MINIMUM QUANTIFICATION LEVELS (MQLs)

  18. FOOTNOTES TO INFLUENT / EFFLUENT MONITORING TABLE (1) It is advised that the influent and effluent samples are collected considering flow detention time through each plant. Analytical MQLs (or MALS) must be met for the effluent (and SHOULD be met for the influent) so the data can also be used for local limits assessment and NPDES application purposes. (2) This value was calculated during the development of TBLL based on State WQ criteria, EPA guidance and either ADEQ Pretreatment staff Excel spreadsheets or the Permittee’s consultant with concurrence from Pretreatment staff. (3) Record the name of any pollutant (40 CFR 122, Appendix D, Tables II, III, V) detected and the concentration at which they were detected. MAHL - Maximum Allowable Headworks Level / MAHC – Maximum Allowable Headworks Concentration WQ - “Water Quality Levels not to exceed” OR actual permit limit.

  19. Common Deficiencies • Not reporting all activities during the pretreatment year • SIU left during pretreatment year? • Still needs to be included • Updated Industrial Users List Table • Compliance Status reported incorrectly, or not at all, for “effluent limits” instead of using appropriate codes (C, NC, SNC). • SNC Publications • copies not showing newspaper name and date.

  20. Common Deficiencies • Influent and Effluent Monitoring Table • Daily Average Effluent Limit column • average effluent limit in the NPDES permit OR the applicable state Water Quality Standard calculated to an equivalent permit effluent limit • Not sampling for all the required pollutants • Not sampling at the required frequency • Not signed by CA’s authorized signatory • Not certified according to 40 CFR §122.22(d)

  21. QUESTIONS?

More Related